ETNA RESEARCH EXPRESSLY DISCLAIMS ALL WARRANTIES, EXPRESSED OR IMPLIED, AS TO THE ACCURACY OF ANY THE CONTENT PROVIDED, OR AS TO THE FITNESS OF THE INFORMATION FOR ANY PURPOSE.
ETNA RESEARCH is a provider of market research, signals and analytics. It is neither a broker-dealer nor an investment advisor. ETNA RESEARCH makes no representation regarding the advisability of investing in any investment fund, other investment vehicle, security or other financial product regardless of whether or not it is based on, derived from, or included as a constituent of any ETNA RESEARCH research. ETNA RESEARCH bears no responsibility or liability for any business decision, input, recommendation, or action taken based on ETNA RESEARCH research or any products based on, derived from, or included as a constituent of any such research. This content is not intended as an offer to sell or a solicitation of any investment product or service to any person in any jurisdiction in which such offer or solicitation is not authorized or to any person to whom it would be unlawful to make such offer or solicitation.
This information has been prepared by ETNA RESEARCH for informational purposes only. This information should not be construed as investment, legal and/or tax advice. This information was produced by and the opinions expressed are those of ETNA RESEARCH as of the date of writing and are subject to change. Any research is based on ETNA RESEARCH proprietary research and analysis of global markets and investing, including opinions that are expressed based on statistical forecasting from historical data. The information and/or analysis presented have been compiled or arrived at from sources believed to be reliable, however ETNA RESEARCH does not make any representation as their accuracy or completeness and does not accept liability for any loss arising from the use hereof. There is no assurance that such events or targets will be achieved, and may be significantly different than that shown here. The information presented, including statements concerning financial market trends, is based on current market conditions, which will fluctuate and may be superseded by subsequent market events or for other reasons. Neither ETNA RESEARCH nor its third party content providers shall be liable for any errors, inaccuracies or delays in content, or for any actions taken in reliance thereon.
Broad based securities indices may be included in this report as benchmarks to provide context reflecting general market results during the period. ETNA RESEARCH may propose certain securities that are not represented by such indices. Accordingly, no representations are made that the performance or volatility of securities mentioned in the research will track or reflect any particular index. Broad-based securities indices are un-managed and are not subject to fees and expenses typically associated with managed accounts or investment funds. The number and types of securities found in the index can differ greatly from that of current or past ETNA RESEARCH research. Investments cannot be made directly in an index. Due to differences in actual account allocations, account opening date, timing of cash flow in or out of the account, re-balancing frequency, transaction costs, fees and various other transaction-based or market factors, a client’s actual return may be materially different than those derived from the research. The performance results for individuals following the strategy could also differ based on differences in treatment of dividends received, including the amount received and whether and when such dividends were reinvested.
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Important information and who we are
At Etna Research Limited (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.
The individuals from which we may gather and use data can include:
Third parties connected to your customers
and any other people that the organisation has a relationship with or may need to contact.
Who is Your Data Controller
Etna Research Limited is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us on email at firstname.lastname@example.org or sent in a letter to Sg House, 6 St. Cross Road, Winchester, SO23 9HX, United Kingdom.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Processing Data on Behalf of a Controller and Processors’ responsibility to you
In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:
Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases);
Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
Maintain a record of all categories of processing activities carried out on behalf of a Controller;
Cooperate, on request, with the supervisory authority in the performance of its tasks;
Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
Notify the Controller without undue delay after becoming aware of a Personal Data Breach;
LEGAL BASIS FOR DATA COLLECTION
“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:
Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
Billing Data: This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.
Financial Data: These are your banking details e.g. your account number and sort code.
Transactional Data: This is information of details and records of all payments you have made for our services or products.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
The Legal Basis for Collecting That Data
There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:
“Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
“Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
“Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
“Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.
HOW WE USE YOUR PERSONAL DATA
We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.
Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.
Marketing and Content Updates
You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.
Change of Purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US
How Does Etna Research Limited Protect Customers' Personal Data?
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Etna Research Limited to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
Opting Out Of Marketing Promotions
You can ask us to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.
How to Request your Data and the Process for Obtaining it
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
YOUR DATA AND THIRD PARTIES
Will We Share Your Data With Third Parties?
We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors or affiliates (subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions).
We may also share Personal Data with interested parties in the event that Etna Research Limited anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.
HOW LONG WILL WE RETAIN YOUR DATA FOR?
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
AGE LIMIT FOR OUR USERS
You must not use Etna Research Limited unless you are aged 18 or older. If you are under 18 and you access Etna Research Limited by lying about your age, you must immediately stop using Etna Research Limited.
This website is not intended for children and we do not knowingly collect data relating to children.
INTERNATIONAL TRANSFER OF DATA
Your information may be stored and processed in the US or other countries or jurisdictions outside the US where Etna Research Limited has facilities. We are currently storing data in the EU and so, by using Etna Research Limited, you are permitting and consenting to the transfer of information, including Personal Data, outside of the US.
NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY
All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.).
Our staff are not authorised to contract on behalf of Etna Research Limited, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a Etna Research Limited address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Etna Research Limited rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Etna Research Limited legal department.
provide greater transparency or in response to:
feedback from customers, regulators, industry, or other stakeholders;
changes in our products;
changes in our data processing activities or policies;
any change of the Applicable Regulations and /or the doctrine of the competent supervisory authority.
Effective Date: May 12, 2022
ETNA RESEARCH LIMITED
71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
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CONTROL OF COOKIES
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OTHER TRACKING TECHNOLOGIES
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