Introduction
We are committed to helping our investors reach their financial goals and to treating investors, clients and contacts fairly and with respect. This includes maintaining your trust and confidence by handling your personal data and information with respect and enabling you to self-manage the communications you receive from Liontrust Asset Management PLC, Liontrust Fund Partners LLP, Liontrust Investment Partners LLP, Liontrust Portfolio Management Limited and Liontrust International Luxembourg (SA) (collectively, "Liontrust"). It is important that you know what personal information Liontrust holds about you and how it is used, and this Privacy Notice has been written to explain this.
Liontrust processes personal data for a variety of purposes. We collect this personal data directly from you, for example, if you are an investor in our funds, if you visit our website, if you submit your contact details to receive marketing communications from us, if you submit event-related data to attend our events, or share information on yourself with us as part of a job application. We may also obtain your personal data via publicly available sources. This privacy notice is intended to cover all of the above-mentioned scenarios.
If you would like any further information or have any questions on the processing of your information, please email us at dataprotection@liontrust.co.uk.
What is personal data and what does it cover?
In this privacy notice, “personal data” means any information relating to an individual who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data or an online identifier. Personal data also refers to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of an individual. It includes special categories of personal data (special category data) from which we can determine or infer an individual's:
- Racial or ethnic origin
- Political opinions
- Religious or philosophical beliefs
- Membership of a trade union
- Genetic data
- Biometric data
- Physical or mental health or condition
- Sex life or sexual orientation
It also includes personal data relating to criminal convictions and offences.
Your rights in relation to personal data
You have the following rights in relation to your personal data:
- To access the personal data held by Liontrust about you
- To have your personal data corrected, for example, if it is incomplete or incorrect
- To opt out of receiving marketing communications at any time
- To restrict or object to the processing of personal data or request for your personal data to be erased(in certain circumstances and subject to applicable law)
- To receive a copy of the personal data which you have provided to Liontrust, in a structured, commonly used and machine-readable format (known as “data portability”) (in certain circumstances and subject to applicable law)
- Where you have provided personal data voluntarily, or otherwise consented to its use, the right to withdraw your consent
- The right to complain to a data protection authority (additional detail provided below under “How to complain”)
If you have a query or wish to exercise your rights, please contact us at dataprotection@liontrust.co.uk.
What personal data do we process?
We collect personal data that you provide voluntarily, for example, when using our website and completing online forms to contact us, subscribing to a newsletter, using one of our online advisor tools, subscribing to receive marketing communications from us, investing in our funds, participating in surveys, registering for events that we are organising or applying for a job at Liontrust.
The information we collect about you may include the following:
- Contact details (name, address, telephone number and email address)
- Job title, job level or job function, role
- Data on the company you work for, including regulatory details – e.g. FCA authorisation information on the company and its regulated individuals
- Demographic information, such as industry, country, postcode, preferences and interests
- Other information relevant to client surveys or similar research
- Information relating to events captured through event-related forms, such as dietary restrictions, hotel and flight information, registration/participation status, media interview attendance, previous event experience and gender
- Information pertinent to fulfilling our services to you
- Information on how you use our website, e.g. how many times you visit, the duration of your visit, the pages you view, videos you watch, files you download, links you click
- Information on the device(s) you use to visit our website, e.g. whether you are using a computer, a tablet or a smartphone, your screen resolution, your operating system, your browser, your IP address, server log file information
- Your basic profile information, this is determined by your selections when you first arrive on our website e.g. your country of location and visitor type
- Your preferences, e.g. Liontrust teams and funds you have told us you are interested in, pages you have bookmarked
- Your interactions with our marketing communications, e.g. whether an email has been opened and/or clicked
- Information on your interactions with us
For investors in Liontrust funds, the following additional information may be held to allow us to provide our services to you and meet regulatory requirements:
- Identity verification. We will use information provided by third parties (e.g. fraud prevention agencies) when verifying the identity of our fund investors and when carrying out anti-money laundering checks. Such information may include their nationality and identification records (e.g. passport information). It may also include some details about any criminal convictions and any allegations regarding criminal activity that relate to the individual, as well as details of status as a politically exposed person
- Contractual details, including information we have collected as part of the products and services we provide to you
- Financial information, such as payment-related information
- Where permitted in accordance with local law, we may also in some circumstances record telephone conversations
- Any other personal data that you voluntarily choose to provide to us in your interactions with us
In addition to the above, the Liontrust website uses cookies so that we can provide you with the best possible user experience. We use Google Analytics to track your usage of our website and third party cookies to track the performance of our adverts. You can read more about the cookies we use and how to manage them here.
Purposes for which we process your personal data
- To provide services to you
- To administer our relationship and maintain contractual relations
- For accounting and tax purposes
- For marketing and business development
- To comply with our legal and regulatory obligations
- To establish, exercise or defend legal rights
- For historical and statistical purposes
- To administer and manage our website, including to confirm and authenticate your identity, and prevent unauthorised access to restricted areas of our site
- To personalise and enrich your browsing experience by displaying content (including targeted advertising) that is more likely to be relevant and of interest to you
- To analyse the data of visitors to our site and site traffic information
- To capture metrics about the journey of users within our site
- To determine the company, organization, institution or agency that you work for or with which you are otherwise associated
- To develop our business and services
- To provide you with marketing communications
- To conduct benchmarking and data analysis (for example, regarding usage of our site and demographic analyses of visitors of our site)
- To understand how visitors use the features and functions of our site
- To monitor and enforce compliance with applicable terms of use
- To enable teams managing events to coordinate their email campaigns and event notifications more effectively
- To allow for event and webinar sign-up
- To allow for content download and lead capturing
- To allow services and information to be delivered effectively to you
- Any other purpose for which you provided information to Liontrust
Legal grounds for processing personal data
We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
- Our legitimate interest in the effective delivery of information and services to you, and the effective and lawful operation of our businesses
- Our legitimate interest in developing and improving our site, and your user experience
- Where we need to perform a contract we are about to enter into or have entered into with you
- Where we need to comply with a legal obligation
- Explicit consent of users of our services, including investors, and visitors to our website. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending 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.
Keeping your personal data up-to-date
We maintain the accuracy and completeness of the personal data we hold. It is important that you inform us of any updates to your contact details or other personal data so that we have the most up-to-date information about you. Please contact the person you usually deal with at Liontrust. You can also contact dataprotection@liontrust.co.uk.
Use of third parties
Where personal data is being processed by a third party on Liontrust’s behalf, Liontrust will have contractual arrangements in place to protect any such personal data - in line with the applicable data protection laws and regulation. Where any processing is done outside of the UK Liontrust will ensure appropriate protections are in place to safeguard your data privacy before any processing commences.
Protecting your data
Liontrust protects the confidentiality and security of information it obtains in the course of its business. Access to such information is limited, and policies and procedures are in place that are designed to safeguard the information from loss, misuse and improper disclosure.
Data retention
Our policy is to retain personal data only for as long as it is needed for the purposes described in the section “Purposes for which we process personal data.” Note that retention periods vary in different jurisdictions and are set in accordance with local regulatory and legal retention requirements. In order to meet our professional and legal requirements, to establish, exercise or defend our legal rights, and for archiving and historical purposes we may need to retain information for longer periods of time.
How to complain
If you want to make a complaint in relation to our data processing activities, please contact dataprotection@liontrust.co.uk. If you are not satisfied with our response, you can raise a complaint with the Information Commissioners Office.
Changes to this privacy notice
We will occasionally update this privacy notice to reflect changes in our practices and services. When we post changes to this privacy notice, we will revise the “last updated” date at the top of this privacy notice. If we make any material changes in the way we collect, use, and share personal data, we will notify you by prominently posting notice of the changes on the website. We recommend that you check this page from time to time to inform yourself of any changes in this privacy notice.
