ONLINE PRIVACY AND COOKIES POLICY
This Privacy and Cookies Policy applies to http://ghef.greshamhouse.com/ (the “Website”) which is operated by Gresham House Asset Management Limited (“GHAM”, “Gresham House”, “we”, “us” and “our”). GHAM is registered in England and Wales under company number 09447087 and has its registered office at 5 New Street Square, London, United Kingdom, EC4A 3TW. GHAM main trading address is at 5 Cheapside, London EC2V 6AA.
For the purposes of this Privacy and Cookies Policy (the “Policy”), we are the data controller of your personal information. This is because we are the organisation which (either acting alone or jointly with others) determines why and how your personal information is processed. By personal information, we mean information which, either by itself or when combined with other information that we hold, or which is available to us, can be used to identify you.
This Policy explains how we collect, use and disclose personal information about you when you visit the Website and when you contact us, whether by e-mail, post, fax or telephone – these are the contact options which you have and which we mention on the Website. The information you provide to us through the Website will be collected by us but may then be shared with other entities in the Gresham House Group and used for the same purposes mentioned in this Policy (below). For this reason, all references below to Gresham House, “we”, “our” and “us” in this Policy include the Gresham House Group, unless distinguished in the text.
What categories of personal information do we collect?
When you visit our Website, we may automatically collect standard internet and website log information and details of patterns about how website visitors behave. The information we may collect includes information about your Internet Service Provider, your operating system, browser type, domain name, the Internet Protocol (IP) or MAC address of your computer (or other electronic Internet-enabled device), your access times, the website that referred you to us, the web pages you request and the date and time of those requests. This may allow us to find out which parts of the Website are popular or should be developed. In addition, if you have accessed the Website via a link in one of our marketing e-mails (see below), we may also collect your e-mail address.
The main purpose of the Website is to provide information about what we do and the investment opportunities that we offer, and so there are limited ways in which you can interact with us on the Website. However, it is possible for you to contact us using the “Contact Us” function on our Website from which you can send us a message and provide your contact email address for us to get in touch with you in response.
Where you interact with us using our Contact Us function, we may collect the following personal information from you (depending on the information you choose to provide) and we will use this for the purposes mentioned in this Policy (below):
• your name;
• your personal or work-related e-mail address (depending on which you choose to submit to us, including by the “Contact Us” function on the Website – see below);
• your personal or work-related contact details (depending on which you choose to submit) such as your telephone number(s), fax numbers and postal address; and/or
• any other personal information you choose to provide us with in connection with your message to us in the “Contact Us” function on the Website, which may relate to matters such as your investment preferences or our portfolio services and how they apply to you.
We ask that you do not provide us with any ‘special categories of personal data’ when using our Contact Us function. This means information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and data concerning your health, sex life or sexual orientation. We do not consider any of this information relevant to what we do via the Website. We do not wish to process it. We would need your explicit consent in order to justify our processing of it.
We will collect your personal information from you when you voluntarily provided it to us. We may also collect it where lawful to do so from (and combine it with information from) third parties. If these are public sources of information – we will make that clear.
How do we process your personal information?
We may use information about you for the following purposes:
• to respond and/or deal with your request or enquiry;
• to improve our products and services and to ensure that content from the Website is presented in the most effective manner for you and for your computer (or other electronic Internet-enabled device);
• to administer the Website;
• for internal record keeping;
• to contact you (directly, either by GHAM or any other member of the Gresham House Group or through a relevant partner or agent) by e-mail or phone for any of the above reasons;
• to carry out direct marketing including e-mail marketing (see below – we may sometimes need your explicit consent for this, in particular where it cannot be justified by legitimate interests);
• where necessary as part of any restructuring or sale our business or assets;
• to perform any contract GHAM or any other member of the Gresham House Group has with you;
• for compliance with our legal, regulatory and other good governance obligations; and
• to analyse trends and customer journeys in using and accessing our Website.
This list is not intended to be exhaustive and may be updated from time to time as business needs and legal requirements dictate. Some of the personal information that we maintain will be kept in paper files, while other personal information will be included in computerized files and electronic databases.
Monitoring of communications
We may monitor and record calls, email, text messages, social media messages and other communications within the parameters of what is permitted by law. We will do this for compliance with regulatory rules, self-regulatory practices or procedures relevant to our business, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures, and for quality control and staff training purposes.
In addition, telephone calls between us and you in connection with your enquiries may be recorded to make sure that we have a record of what has been discussed and what your instructions are. We may also record these types of calls for the quality control and staff training purposes mentioned above.
Processing your personal information: our legal basis and purposes
The legal basis which relates to our use and other processing of your personal information under data protection laws may include (as relevant):
1. Processing that is necessary for performance of a contract with you or to take steps at your request prior to entering into a contract. This includes administering and managing your investor portal account and services relating to that, updating your records, tracing your whereabouts to contact you about your investment (as relevant); we may also rely on this lawful reason for the sharing of personal information with third parties (see ‘sharing of your personal information’ below) if they are data controllers under the data protection laws;
2. Processing that is necessary for our own legitimate interests or those of third parties (such as the other entities which are part of the Gresham House Group) – such as:
a) For management and audit of our business operations, including accounting;
b) When we monitor emails, calls and other communications and activities in relation to your investor portal account (see above);
c) To deal with our good governance requirements;
d) For market research and analysis, developing statistics, including for automated decision making as may be relevant to this activity (see below);
e) For our own direct marketing communications which we send to you about our own products and services, including for automated decision making as may be relevant to this activity (see below); and
f) We may also rely on this lawful reason for the sharing of personal information with third parties (see ‘sharing of your personal information’ below) if they are data controllers under the data protection laws.
3. Processing that is necessary to comply with a legal obligation– such as:
a) To process your request for personal information or when you seek to exercise your rights under data protection laws;
b) For compliance with legal and regulatory requirements;
c) For establishment and defence of legal rights;
d) For activities relating to the prevention, detection and investigation of crime;
e) To verify your identity;
f) When we monitor emails, calls and other communications and activities on your investor portal account (see above); and
g) We may also rely on this lawful reason for the sharing of personal information with third parties (see ‘sharing of your personal information’ below) if they are data controllers under the data protection laws.
4. Processing that is based on your Consent– such as:
a) When you request that we disclose your personal information to a third party;
b) For our direct marketing communications about products and services available from the Gresham House Group or from other third parties;
c) When we process special categories of personal data about you (see above for what this means). Consent for this type of data, where it is relied upon as the lawful reason for processing it, must be explicit consent; and
d) We may also rely on this lawful reason for the sharing of personal information with third parties (see ‘sharing of your personal information’ below) if they are data controllers under the data protection laws.
5. Processing that is necessary for reasons of substantial public interest on the basis of laws that are applicable to us which are proportionate to the aim pursued and which respect your rights. We may also rely on this lawful reason for the sharing of personal information with third parties (see ‘sharing of your personal information’ below) if they are data controllers under the data protection laws.
Withdrawing your consent
You are free at any time to withdraw your consent where that is relied upon as the lawful reason for processing your personal information. If you do this and if there is no alternative lawful reason which justifies our processing of your personal information for a particular purpose, this may affect what we can do for you.
Do you share my personal information with third parties?
Your personal information will be made available for the purposes mentioned above (or as otherwise notified to you from time to time), on a ‘need-to-know’ basis, including for instance to responsible management, accounting, legal, logistics, audit, compliance, information technology and other corporate staff who properly need to know these details for their functions within the Gresham House Group. Please note that certain individuals who will see your personal information may not be based at the addresses of the members of the Gresham House Group or in your country (please see below).
We may share personal information within the Gresham House Group as needed for reasonable management, analysis, planning and decision making, including in relation to taking decisions regarding the expansion and promotion of our product and service offering, order or customer request fulfilment and for use by those companies for the other purposes described in this Policy.
Your personal information may also be made available to third parties (within or outside the Gresham House Group) providing relevant services under contract to any member of the Gresham House Group (see below for further details).
Third parties in this context means any entity within the Gresham House Group, providers to the Gresham House Group of responsible management, accounting, legal, logistics, audit, compliance, information technology, marketing and other services. This may also include providers of call centres, data storage and database hosting services, IT hosting and IT maintenance services. These companies may use information about you to perform functions on our behalf.
Your personal information may also be made available to third parties or partners where necessary as part of any restructuring of Gresham House or any member of the Gresham House Group or sale of any of our business or assets. We will not sell your personal information to any third party other than as part of any such restructuring or business or asset sale.
Will my personal information be transferred abroad?
Your personal information may be transferred outside the UK and the European Economic Area. Whilst some countries already have adequate protections for personal information under applicable laws, in other countries steps will be necessary to ensure appropriate safeguards apply to maintain the same levels of protection as are needed under data protection laws applicable to us in the UK.
Safeguards include contractual obligations imposed on the recipients of your personal information. Those obligations require the recipient to protect your personal information to the standard required in the European Economic Area. Safeguards also include requiring the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing and where the framework is the means of protection for the personal information.
Criteria used to determine the retention period
We need to keep your personal information for as long as necessary to fulfil the purposes for which it was collected (and those purposes are as described above). This includes retaining it in order to comply with legal and regulatory requirements and in case of claims. If you would like further information about our data retention policy, contact Andrew Hampshire, Chief Operating Officer at email@example.com.
The criteria we use to determine data retention periods for your personal information includes the following:
• Retention in case of queries. We will retain some of it in case of queries from you;
• Retention in case of claims. We will retain some of it for the period in which you might legally bring claims against us;
• Retention in accordance with legal and regulatory requirements. We will retain some of it after your agreement with us has come to an end based on our legal and regulatory requirements.
Your rights under applicable data protection law
Your rights are as follows (noting that these rights do not apply in all circumstances and that data portability is only relevant from May 2018):
• The right to be informed about your processing of your personal information;
• The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed;
• The right to object to processing of your personal information;
• The right to restrict processing of your personal information;
• The right to have your personal information erased (the “right to be forgotten”);
• The right to request access to your personal information and to obtain information about how we process it;
• The right to move, copy or transfer your personal information (“data portability”); and
• Rights in relation to automated decision making including profiling.
You have the right to complain to the Information Commissioner’s Office. It has enforcement powers and can investigate compliance with data protection laws: https://ico.org.uk/. You can contact Andrew Hampshire, Chief Operating Officer at firstname.lastname@example.org for more details on all the above.
Whether providing your personal information is required by law or contract and whether it is obligatory
If you are a private investor, we will be unable to provide you with our asset management related investment services or to process your application relating to it without your personal information. This means that it is necessary for us to have most of it specifically to be able to enter into our contract with you. If you are a wealth manager or professional investor then our contract will not be with you instead it will be with your organisation or the individual for whom you are making investments – this means the personal information you provide to us including through the Website (such as your business-related contact details) is not required by a contract – instead it is needed so that we can administer the application/investments for your organisation / that other individual.
In all cases we will not be able to reply to request for information through the Contact Us function on our Website unless you identify yourself and give your email address when you make your enquiry – in this way providing the personal information is obligatory. But it is not required by law or contract.
Data anonymisation and use of aggregated information
Your personal information may be converted into statistical or aggregated data which cannot be used to identify you, then used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described above.
What choices do we offer you with regard to direct marketing?
We may wish to provide you with information about new products, services, promotions and offers, which may be of interest to you and may invite you to take part in market research or request feedback on our products and services and our products and services and/or those of the Gresham House Group. This communication may occur by e-mail, telephone, post or SMS. We will obtain your consent and advise you of how to opt-out of receiving such communications where we are required to do so in accordance with applicable law, for example by clicking the “unsubscribe” link on any email that we send to you or by emailing Sally Savery at email@example.com at any time.
We may also use your home address, phone numbers, email address and social media (e.g. Facebook, Google and message facilities in other platforms) to contact you according to your preferences.
Please note that marketing communications are not the same as “information only” communications and so consents are not usually required in order for us to communicate with you about the services you have enquired about or have signed up to obtain through the Website, using contact details you have provided for this purpose.
The Gresham House Group
The members of the Gresham House Group are available to view at www.greshamhouse.com.
What are cookies?
Cookies are small, often encrypted, text files that are used by websites to perform certain functions.
Information supplied to us using cookies helps us to analyse the profile of our visitors and provide you with a better online experience.
This information will often constitute your personal information, and when it does not we may combine the information we collect by cookies with the personal information that we have collected from you in order to learn more about how you use Website and to improve our Services. A full list of cookies and how we use them can be found below in the section “Cookies we use”.
How to control and delete cookies
Cookies can be controlled, blocked or restricted through your browser settings. Information on how to do this can be found within the Help section of your browser. All cookies are browser specific. Therefore, if you use multiple browsers or devices to access websites, you will need to manage your cookie preferences across all of these elements.
There are also several online resources that can give you more information on cookies and how you can control them within a variety of different web browsers. You can visit either http://www.aboutcookies.org or http://www.allaboutcookies.org for more information.
If you are using a mobile device to access the Website, you will need to refer to your handset instruction manual or other help/settings resource in order to find out how you can control cookies on your particular device.
Please note: if you restrict cookies, you may experience a loss of functionality while on the Website.
Cookies we use
We use the following categories of cookies on our Website:
Strictly necessary cookies - These are cookies that are essential for the operation of our Website. They include, for example, cookies that enable you to navigate to the correct pages, if we make any updates to the way the website works. These include cookies which enable us to report on full customer journeys made on our Website.
Performance cookies - These cookies collect information about how visitors use our Website, enable us to understand if any errors have occurred, and allow us to test new features. We don’t collect information that identifies the visitor directly, as the data is aggregated and anonymous. We only use this information to improve how the Website works.
Functionality cookies - These cookies help enable specific functionality on the Website to improve your experience, for example remembering your preferences, detecting if a service has already been offered to you (such as surveys), or storing more complex information (such as the specific investment product(s) you have viewed most recently or most often).
Targeting/advertising cookies - These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website more relevant to your interests. They are also used to track the effectiveness of advertising campaigns.
Cookies set by third party sites
To enhance our content and to deliver a more enriching online experience for our users, we sometimes embed images and videos from other websites on the Website.
We currently use and may in future use content from sites such as Google, LinkedIn, and Hubspot. You may be presented with cookies from these third-party websites. Please note that we do not control the dissemination of these cookies and you should consult the relevant third-party website for information on how these cookies are used and how you can control them.
We may also embed social sharing icons throughout our Website. These sharing options are designed to enable users to easily share our content with their friends using a variety of different social networks. These social sharing sites may set a cookie when you are logged into their service. Please note that we do not control the dissemination of these cookies and you should consult the relevant third-party website for information on how these cookies are used and how you can control them.
Changes to this Policy
We keep this Policy under regular review. We may, without notice to you, change this Policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. The date at the top of this Policy will be updated accordingly. We encourage you to check the date of this Policy when you visit the Website for any updates or changes.
This Policy only extends to the Website and does not, therefore, extend to your use of, provision of data to and collection of data on any website not connected to us to which you may link by using the hypertext links within this website.
If you have any questions about this Policy, please contact John-Paul Preston at firstname.lastname@example.org.