EURONOVA ASSET MANAGEMENT UK LLP - Website Privacy Policy

Website Privacy Policy

Welcome to the Euronova Asset Management UK LLP website privacy policy.

Our website is intended not for individual investors but for corporate bodies such as professional investors and eligible counterparties corporate bodies.

Nevertheless, Euronova Asset Management UK LLP (Euronova) respects data privacy and is committed to protecting your personal data. We also work closely with our business partner organisations to ensure that personal data is processed in accordance with the law.

This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you briefly about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy

This privacy policy aims to give you information on how Euronova collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Euronova Asset Management UK LLP is the controller and responsible for any personal data we collect that concerns you.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Euronova Asset Management UK LLP.

Email address: sarah.loudon@euronam.co.uk

Postal address: 7-9, North St David Street, St Andrew Square, Edinburgh, EH2 AW.

Telephone number: +44 [0]131 524 9456

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.

We are registered with the ICO with number Z3204643.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in December 2023.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about a living individual from which that person can be identified (directly or indirectly). 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 as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us]
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

If you do not provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
1. apply for our products or services;
2. create an account on our website;
3. subscribe to our service or publications;
4. request marketing to be sent to you;
5. give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies[, server logs] and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below such as: Technical Data from the following parties:
analytics providers such as Google based outside the UK;
search information providers based outside the UK.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services based outside the UK.
Identity and Contact Data from data brokers or aggregators based outside the UK;
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending any third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We collect and use personal data only where we have identified a lawful basis for doing so under the UK GDPR and Data Protection Act 2018.

The key lawful bases we rely on are

(i) that we have a legitimate interest in collecting and processing the data for our business and that processing is necessary and is not outweighed by your interests; and

(ii) in order to perform a contract we already have with you or which we intend to enter into with you.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased similar goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time via email addressed to sarah.loudon@euronam.co.ukWhere you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can manage your general preferences regarding browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please ask to see our Cookies Policy.

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.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in this notice.

Third Parties such as fund administrators with whom we have a contractual relationship. There is more detail about these third parties in section 10 below.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to process your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our written instructions.

6. INTERNATIONAL TRANSFERS

We may share your personal data within Euronova and with Euronova Asset Management Ltd. This may involve transferring your data outside the UK.

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

The transfer of your personal data is to acountry that have been deemed by the ICO to provide an adequate level of protection for personal data.
The transfer of your personal data involves certain third party service providers, in which case we will use specific contract terms approved for use in the UK which give personal data the same protection it has in the UK.
The contract terms referred to above now include the use of an International Data Transfer Agreement (IDTA) in the form published by the ICO or an Addendum to the EU’s standard contractual clauses (also published by the ICO.
We may also use as alternative safeguards, a certification service, as permitted by the UK GDPR.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. DATA SECURITY

We have put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used , altered, disclosed or accessed in an unauthorised way.

We keep these measures under review in order to ensure we are giving the data appropriate protection.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it.

Where those purposes include satisfying any legal, regulatory, tax, accounting or reporting requirements there may be specific periods for which are obliged to retain your information before deleting it.

We may retain your personal data for a longer period than would otherwise be the case in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. This is to ensure we can respond effectively to that complaint or manage the litigation effectively.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the ICO’s website for further details of these rights.

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data]
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us. There is further information about your rights on the ICO website. They are not all “absolute” rights. Some are only available in specific situations and with legal limitations.

No fee usually required

In most situations, the law prohibits us from charging you when you exercise your rights. You will not have to pay a fee in order to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is “manifestly” (clearly) unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your 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.

Time limit to respond

We try to respond promptly to all legitimate requests and in any event within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10 MORE DETAIL ON THIRD PARTIES

Service providers acting as processors who provide IT and system administration services
Fund Managers.
Professional advisers acting as processors or controllers including lawyers, bankers, auditors ,compliance consultants and insurers.
HM Revenue & Customs, regulators and other authorities [acting as processors controllers or joint controllers] based [in the United Kingdom] [who require reporting of processing activities in certain circumstances].
The Financial Conduct Authority.

Euronova Asset Management UK LLP is a limited liability partnership registered in Scotland (No SO300762). Euronova Asset Management UK LLP is an independent Investment Manager based in Edinburgh, Scotland and is authorised and regulated by the Financial Conduct Authority (FRN448288).