Privacy Policy

1. INTRODUCTION

CAPAdata ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (the "Website") or use our services.

We collect and process pension performance data from UK pension providers ("Data Providers") and make this information available through our Website, including our proprietary CAPAdata Benchmark. We also provide an AI-powered research assistant service that operates exclusively on historical Corporate Adviser research and reports. This Privacy Policy covers the data we collect from our users, how we handle the pension performance data provided by our Data Providers, and our AI service operations.

Please read this Privacy Policy carefully. By accessing or using our Website, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

This privacy policy should be read alongside, and in addition to, our Terms and Conditions.

2. DEFINITIONS

In this privacy policy, the following definitions are used:

"Data" means collectively all information that you submit to us via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws.

"Cookies" means a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website.

"Data Protection Laws" means any applicable law relating to the processing of personal Data, including but not limited to the UK GDPR and any national implementing laws, regulations and secondary legislation.

"UK GDPR" means the General Data Protection Regulation as it forms part of UK law.

"User" or "you" means any third party that accesses the Website.

"Website" means the website that you are currently using and any sub-domains of this site unless expressly excluded by their own terms and conditions.

3. SCOPE OF THIS PRIVACY POLICY

This privacy policy applies only to our actions and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

For purposes of the applicable Data Protection Laws, we are the "data controller". This means that we determine the purposes for which, and the manner in which, your Data is processed.

4. INFORMATION WE COLLECT

4.1 User Data

We may collect the following categories of personal information from users of our Website:

  • Identity Information: Name, job title, employer
  • Contact Information: Email address, telephone number, postal address
  • Account Information: Username, password, account preferences
  • Technical Information: IP address, browser type, device information, operating system, time zone setting, referring/exit pages, clickstream data
  • Usage Information: Information about how you use our Website, including page views, time spent on pages, search queries
  • Marketing and Communications Information: Your preferences in receiving marketing from us and your communication preferences
  • Payment Information: Billing address, payment method details (processed securely by third-party payment processors)

4.2 Pension Performance Data

We collect aggregated and anonymized pension performance data from Data Providers, including:

  • Pension fund performance metrics
  • Returns data
  • Fee structures
  • Asset allocations
  • Risk metrics
  • Investment category information (including "young saver," "pre-retirement," and "at retirement" categories)
  • Other statistical information related to pension fund performance

4.3 AI Service Data Processing

Our AI-powered research assistant processes:

  • Historical Corporate Adviser research reports and publications (10+ years of content)
  • User queries and interaction patterns with the AI service (for service improvement)
  • AI-generated responses and their accuracy ratings
  • Usage analytics related to the AI service functionality

Important Note: The AI service operates in a completely ring-fenced environment and only processes the specified Corporate Adviser Library Research content contained within the site being operated to provide this service. It does not have access to user personal data, external websites, or any other data sources beyond our controlled repository.

5. HOW WE COLLECT INFORMATION

5.1 Data Given to Us by You

We collect your Data in a number of ways, including when you:

  • Contact us through the Website, by telephone, post, email or through any other means
  • Register with us and set up an account to receive our services
  • Complete surveys that we use for research purposes (although you are not obliged to respond to them)
  • Make payments to us, through this Website or otherwise
  • Elect to receive marketing communications from us
  • Use our services, including the AI-powered research assistant

5.2 Data Collected Automatically

When you access the Website, we automatically collect certain information, including:

  • Information about your visit to the Website, including your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content
  • Data via cookies, in line with the cookie settings on your browser (see the "Cookies" section below)
  • AI service usage patterns, including queries made and interaction frequency (for service optimization)

5.3 AI Service Data Collection

When you use our AI research assistant:

  • We collect your queries to generate appropriate responses
  • We may collect feedback on AI response quality to improve the service
  • We monitor usage patterns to ensure fair access and system performance
  • All AI interactions are logged for quality assurance and service improvement

Data Isolation: The AI service processes queries and generates responses based solely on our ring-fenced repository of Corporate Adviser content. No personal data or external content is accessible to the AI system.

5.4 Collection from Third Parties

We receive pension performance data directly from Data Providers through secure data transfers on a quarterly basis. This data is provided under contractual arrangements with each Data Provider.

6. HOW WE USE YOUR INFORMATION

6.1 User Data

We may use the personal information we collect from users for:

  • Internal record keeping
  • Providing and maintaining our services
  • Processing subscriptions and payments
  • Personalizing your experience on our Website
  • Improvement of our products and services
  • Communicating with you about your account or subscription
  • Sending you technical notices, updates, and support messages
  • Transmission by email of marketing materials that may be of interest to you (with your consent)
  • Responding to your inquiries and providing customer service
  • Contact for market research purposes which may be done using email, telephone, fax or mail
  • Conducting research and analysis to improve our services
  • Detecting, preventing, and addressing technical issues or fraudulent activity
  • Complying with legal obligations
  • Operating and improving our AI research assistant service
  • Analysing AI service usage to optimize performance and user experience

6.2 AI Service Data Usage

We use AI service-related data to:

  • Generate responses to your research queries
  • Improve the accuracy and relevance of AI-generated content
  • Monitor system performance and ensure fair usage across all users
  • Develop and refine our AI algorithms and models
  • Ensure the security and integrity of the AI service
  • Provide usage analytics and service optimization

Transparency Note: Our AI service uses a hybrid approach combining automated processing with human oversight to ensure quality and accuracy of responses.

6.3 Pension Performance Data

We use the pension performance data collected from Data Providers to:

  • Create comparative analyses and reports
  • Develop the CAPAdata Benchmark for various investment categories (including "young saver," "pre-retirement," and "at retirement")
  • Generate industry insights and trends
  • Provide data visualization tools
  • Compile aggregated statistics for publication

The CAPAdata Benchmark is created by aggregating and averaging performance data within specific investment categories. It is not a regulated benchmark under the UK Benchmarks Regulation and is provided for informational and comparative purposes only.

7. LEGAL BASIS FOR PROCESSING

Under the UK GDPR, we process your personal information on the following legal bases:

  • Consent: Where you have given explicit consent to process your personal data for specific purposes (such as marketing communications)
  • Contractual Necessity: Where processing is necessary for the performance of a contract with you or to take steps at your request to enter into such a contract
  • Legitimate Interests: Where processing is necessary for our legitimate interests, provided your fundamental rights do not override these interests
  • Legal Obligation: Where processing is necessary to comply with our legal obligations

8. DATA SHARING AND DISCLOSURE

We may share your Data with the following groups for the following reasons:

  • Service Providers: Third-party service providers who perform services on our behalf, such as payment processors, cloud hosting providers, analytics providers, customer support services, and email service providers. These service providers are contractually obligated to use your information only as directed by us and in accordance with this Privacy Policy.
  • Group Companies: Any of our group companies or affiliates to understand our audience profile and develop better products and services.
  • Professional Advisors: Our employees, agents and/or professional advisors to understand our audience profile and develop better products and services.
  • Business Transfers: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you of any change in ownership or uses of your information.
  • Legal Requirements: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency) or to facilitate the detection of crime or the collection of taxes or duties.
  • With Your Consent: We may share your information with third parties when we have your consent to do so.

AI Service Data Sharing: Data processed by our AI service (user queries and AI responses) is not shared with external parties. All AI processing occurs within our secure, ring-fenced environment. We may share aggregated, anonymized usage statistics about the AI service for business reporting purposes, but these do not contain any personally identifiable information.

9. DATA SECURITY

We implement appropriate technical and organizational measures to protect your information against unauthorized or unlawful processing and against accidental loss, destruction, or damage. These measures include:

  • Access to your account is controlled by a password and username that is unique to you
  • We store your Data on secure servers
  • Encryption of sensitive data
  • Regular security assessments
  • Access controls and authentication procedures
  • Staff training on data protection
  • Secure data transfer protocols
  • Ring-fenced AI processing environment with no external data access
  • AI service monitoring and audit trails
  • Regular security reviews of AI system architecture

AI Service Security: Our AI research assistant operates in a completely isolated environment with no access to external systems, user personal data, or unauthorized content. All AI processing is logged and monitored for security purposes.

If you suspect any misuse or loss or unauthorized access to your Data, please let us know immediately by contacting us via the email address provided in the "Contact Information" section.

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

10. DATA RETENTION

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfill the purposes outlined in this Privacy Policy or until you request that the Data be deleted.

Specific retention periods:

  • Account Information: Retained for the duration of your account plus 24 months after account closure
  • Subscription Data: Retained for the duration of your subscription plus 7 years for tax and accounting purposes
  • Usage Data: Retained for up to 36 months
  • AI Service Data: User queries and AI responses retained for up to 24 months for service improvement; aggregated usage analytics retained for up to 60 months
  • Pension Performance Data: Historical data is retained indefinitely for trend analysis and benchmarking purposes

Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

11. YOUR DATA PROTECTION RIGHTS

Under UK data protection laws, you have the following rights in relation to your Data:

  • Right to Access: Request copies of the information we hold about you at any time, or that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive."
  • Right to Correct: Have your Data rectified if it is inaccurate or incomplete.
  • Right to Erase: Request that we delete or remove your Data from our systems in certain circumstances.
  • Right to Restrict Processing: "Block" us from using your Data or limit the way in which we can use it.
  • Right to Data Portability: Request that we move, copy or transfer your Data.
  • Right to Object: Object to our use of your Data including where we use it for our legitimate interests (including AI service processing)

Note on AI Service Rights: You have the right to request access to your AI service interaction history and to request deletion of your AI queries and responses, subject to our legitimate interests in maintaining service quality and security.

To exercise any of these rights, or to withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us using the details provided in the "Contact Information" section.

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

12. COOKIES AND TRACKING TECHNOLOGIES

12.1 About Cookies

This Website may place and access certain Cookies on your computer. We use Cookies to improve your experience of using the Website and to improve our range of services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.

All Cookies used by this Website are used in accordance with current UK Cookie Law.

Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling us to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

12.2 Types of Cookies We Use

  • Necessary Cookies: Help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
  • Preference Cookies: Enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
  • Statistics Cookies: Help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
  • Marketing Cookies: Used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.
  • AI Service Cookies: Used to maintain AI service sessions and remember user preferences related to the research assistant functionality.

12.3 Cookie Control

You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalization settings.

For more information generally on cookies, including how to disable them, please refer to aboutcookies.org.

13. INTERNATIONAL DATA TRANSFERS

We primarily store and process your information within the United Kingdom and the European Economic Area (EEA). However, some of our service providers may be based outside these regions.

When we transfer your personal information outside the UK or EEA, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards, such as:

  • Standard Contractual Clauses approved by the UK government
  • Adequacy decisions from the UK government
  • Binding corporate rules

14. CHILDREN'S PRIVACY

Our Website is not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us, and we will delete such information from our files.

15. LINKS TO OTHER WEBSITES

This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This Privacy Policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

16. CHANGES OF BUSINESS OWNERSHIP AND CONTROL

We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

We may also disclose Data to a prospective purchaser of our business or any part of it. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

17. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Last Updated" date, and the updated version will be effective as soon as it is posted. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Privacy Policy on your first use of the Website following the alterations.

18. CONTACT INFORMATION

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

CAPAdata Ltd.
Email: info@capadata.co.uk
Phone: 020 3916 5974
Address: 167-169 Great Portland Street, 5th Floor, London England, W1W 5PF

19. COMPLAINTS

If you have a complaint about our use of your personal information, please contact us in the first instance. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.

This Privacy Policy was last updated on 4th June 2025.