What information do we collect about you?
If you are an individual investor in one or more of our funds:
- Personal information about you, e.g. name, age, title, date of birth, nationalities, tax residencies, National Insurance Number, Unique Taxpayer Reference (where applicable)
- Contact information, e.g. email, phone number, address, postcode
- Company information, in cases where this is appropriate e.g. employer company name, company registration number, company address, job title at company
- Appropriateness information, e.g. client categorisation, net worth, average annual earnings
- Event attendance information (where applicable), e.g. attendance at events, special dietary requirements
- Online technical information automatically captured when you visit the Website, e.g. IP address, traffic data, location data, weblogs and other communication data. We will not store or use this information except as required for system administration of our web server. See the section “Cookies and other technical information” in our Privacy Policy for further details
- Verification/identification information e.g. passport/driving licence numbers, tax certificate records and any other personal information contained within these documents (e.g. photos, gender, age, nationality, date of birth). Note that this may include ‘special categories’ of data about you (as denoted in the Data Protection Act 2018) such as your racial or ethnic origin, as well as personal data relating to any past criminal convictions and offences.
- Contractual information, e.g. details about your products and benefits, such as your investment requests, investment allocation data, amount invested
- Financial information, e.g. your current investments and investment experience
Why do we collect your personal information and on what grounds?
| Purpose for processing | Legal basis |
| Processing your investment application (whether completed or incomplete) | Performance of a contract |
| Verifying your identity and preventing fraud (e.g. completing our Anti-Money Laundering checks) | Compliance with our legal obligations
Performance of a contract or for taking steps at your request prior to entering into a contract with you |
| Fulfilling any legal or regulatory obligations (e.g. producing HMRC or international tax reports, performing suspicious transactions checks, providing bi-annual investment reports to the FCA and providing copies of shareholder information as required by s116 of Companies Act 2006) | Compliance with our legal obligations |
| Completing any requests you make | Performance of a contract |
| Administering your transactions and holdings | Performance of a contract |
| Keeping you updated about your investment with regular reports | Performance of a contract |
| Maintaining a backup of the investment register for business continuity purposes | Our legitimate interests (business continuity) |
| Managing our relationship with you | Performance of a contract |
| Assessing and developing our products, systems, prices and brand, including by researching our customers’ opinions and exploring new ways to meet their needs | Our legitimate interests (market research and improving our business offering) |
| Sending you marketing emails and contacting you about our products and services | Your consent (if received) |