Contents
Data protection privacy notice
What is personal information?
Who we are
What types of information do we use?
Consequences of not providing some types of information
How do we collect information about you?
How we will use your personal information
Marketing
Who we share your information with
Sending your information outside of the EEA
Storing your information
Automating decision making
Your rights
Security
Data protection privacy notice
We are committed to protecting your personal information and ensuring we respect your privacy. This Privacy Notice explains how we will look after and use any personal information that we collect about you.
What is personal information?
Personal information means any information about you from which you can be identified. Examples of personal information include your name, home address, national insurance number, date of birth, telephone number and e-mail address but it also includes other pieces of information which can be used to identify you, either directly or indirectly, such as a cookie.
Who we are
WHEB Asset Management is the Controller of the personal information you provide to us. If you have any questions about this Privacy Notice or the information we hold about you please contact our Finance, Compliance & Operations Manager, using the details set out below:
Full name of legal entity: WHEB Asset Management LLP
Contact: Laura Grenier (Director of Operations)
Email address: laura.grenier@whebgroup.com
Postal address: 7 Cavendish Square, London W1G 0PE
Contact telephone numbers: +44(0)20-3219 3413
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. We would however appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
What types of information do we use?
We collect information in the course of providing our financial services to you. The information which we collect, use, store and transfer about you are:
Instructions or requests (for example if you ask for investment advice or to be added to a mailing list);
Contact details, including name, email address, mailing address, telephone number(s), employer information;
Information in relation to the provision of services by us to you.
Our products and services are not intended for children and we will not knowingly collect any data related to children.
We do not collect any special categories of personal data. 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 or biometric data.
Consequences of not providing some types of information
Where we need to collect your personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to provide the goods or services you asked for. In this case we may have to cancel the product or services but we will tell you if this is the case.
How do we collect information about you?
Typically, we will collect information from you when you contact us directly or provide information in order for us to provide our products and services. We collect information from and about you in the following ways:
Through direct interactions when you give us your personal information by filling in forms or during correspondence with us. This includes when you:
Subscribe to our services;
Meet with us in person or talk to us face to face;
Request marketing materials or other information in relation to our products and services.
Through using our website when we collect information using cookies or similar technologies which tell us about your equipment, browsing actions and patterns.
Through third parties such as introducers / personal advisers / personal representatives.
How we will use your personal information
We only obtain, use and keep personal information where we need it for a specific purpose. We set out in the table below the ways in which we plan to use your personal information. We are only able to use your personal information if we have a proper legal reason or basis for doing so. This is called a legal basis and the regulations require that we have a legal basis so that your privacy is protected. Most commonly we will use your information in the following ways:
We have a legal obligation. We need to use your personal information to comply with laws that assist in the prevention of financial crime and to comply with regulatory obligations. For example, this might include confirming your identity and source of wealth, as well as ensuring we provide you with necessary information so you understand the risk of the financial services we can provide.
We have asked for, and you have provided, consent to use your information. Please note that you can withdraw your consent at any time – this is part of how the law protects your interests.
We, or a third party, have a legitimate interest in processing the information and your interests and fundamental right do not override those interests. For example, processing your information for marketing purposes or to provide further information on the services and products we provide.
We set out in the table below all the ways we plan to use your personal information and the legal bases we rely on to do so. We also explain what our legitimate interests are where appropriate:
| Purpose | Lawful Basis for processing including our legitimate interests |
|---|---|
| To provide you with regular information about your investment | To fulfil our regulatory obligations and/or enhance the minimum information required for regulatory purposes. |
| To contact you about other products and services we think you may be interested in | Necessary for our legitimate interests – to develop our products and services and grow our business. |
| To use data to improve our website | Necessary for our legitimate interests – to understand how our customers interact with our website |
| To report possible criminal acts or threats to public security to a competent authority | To fulfil our statutory or regulatory obligations. |
We will only use your personal information for the reason for which we collected it. We will only use it for another reason if we believe that new reason is compatible with the original purpose. If we do need to use your personal information for a non-related purpose we will tell you about it and explain the legal basis which allows us to do so.
Marketing
Consent
We will always seek your consent to use your personal information for electronic marketing (including marketing calls, texts, emails, faxes, cookies or similar technology). We will very clearly explain why we are seeking your consent and ensure that you are provided with a simple method of providing this – usually via our website or terms of business.
You are free to change your mind at any time by contacting us using the contact details set out on page 3 above.
Legitimate interest
We can use your personal information to send you non-electronic marketing communications if we believe we have a ‘legitimate interest’. We are required to make an assessment with regards to the benefits for us weighed against how appropriate it is to contact you in this way and whether it would be unfair to you. We believe that as a commercial enterprise we do have a legitimate interest in contacting you about our products or services and we will only do so if we decide it would be of interest or beneficial for you.
Cookies
Cookies are small text files placed on your computer (or other device where you access the internet) used to collect information on your activities online. They can also be used as part of website functionality – for example if you use online services to access fund information so you should be careful about accepting, deleting or removing them. We can collect information about the device you are using to access the internet, your IP address and website browser (for example). Cookies can tell us what information you were looking at, for how long, which internet sites interest you which are useful for us particularly for marketing our products and to ensure we are delivering the right service to clients.
For example, cookies can tell us how many visitors to the website accessed the information and tools we provide. It may be the information on our website is not clear and we need to improve it – or there may be a genuine need to improve our range of products in the interests of our customers.
If you have concerns about cookies this web site explains how you can delete and control the cookies that are stored on your computer: https://www.aboutcookies.org/
Who we share your information with
We may need to provide information to third parties for a variety of reasons, for example, we may need to provide information to assist in the detection or prevention of crime or for the purpose of safeguarding national security. Please refer to the table in the section ‘How we will use your personal information’ which explains how we use your data. The third parties we share your information with are as follows:
FundRock Partners Limited
SS&C Financial Services International Limited
FundRock Management Company S.A.
Société Générale Securities Services
Sending your information outside of the EEA
The regulations which have been put in place to protect your privacy apply throughout the EEA. The EEA is the European Economic Area which includes all the countries in the European Union plus Iceland, Liechtenstein and Norway. This means that any country within the EEA must meet the same privacy standards as the United Kingdom. All the personal information that we hold about you will be processed in the United Kingdom.
Storing your information
As a financial services provider we will typically have a contract with you and will need to keep your personal information (updated to ensure accuracy) to fulfil our contract. We also need to comply with EU and UK law, which often requires us to keep certain records – which will include certain personal information – for several years.
Our policy is to keep records for up to seven years after you are no longer a client. We will ensure all records are safely destroyed if we no longer need to retain them. We review our retention periods for personal information on a regular basis. We will tell you if we change the retention period.
When we decide how long we will retain your personal information, we will take into account the amount, nature, sensitivity of your information and how we want to use it as well as the potential risk of harm being caused from unauthorised use or disclosure.
Automating decision making
We do not use automated decision making.
Your rights
You are provided with a number of different rights under the data protection laws in relation to your personal information. These allow you:
To access your information;
To request that we correct your information;
To request that we erase your information;
To object to the processing of your information;
To request a restriction in the processing of your information;
To request a transfer of your information; and
To withdraw your consent.
If you wish to exercise any of these rights please contact us immediately using the contact details set out above. Please note that you will not have to pay a fee to access your personal information or to exercise any of the other rights. We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or we may refuse to deal with your request. We may also need to seek further information from you to confirm your identity before we release any personal information. This does not affect your right to make a complaint.
Security
We have put in place appropriate security measures to protect your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have a procedure to deal with any suspected personal data breach and will notify you, and other parties where we are legally required to do so.