Liontrust Privacy Notices
Our main UK Privacy Notice can be found below. The following additional Privacy Notices are also available:
Introduction
We are committed to maintaining your trust and confidence by handling your personal data with respect and enabling you to self-manage the communications you receive from Liontrust. In addition, it is important that you know what personal data Liontrust holds about you and how it is used.
When we use the term “Liontrust” in this Privacy Notice (or “we”, “us” or “our”), we mean any of Liontrust Asset Management Plc, Liontrust Fund Partners LLP or Liontrust Investment Partners LLP, which each act as a controller of personal data and is legally responsible for deciding how and for what purpose your personal data is used. This notice (“Privacy Notice”) provides information about how each Liontrust collects and processes your personal data in compliance with applicable data protection laws, including the UK Data Protection Act 2018 and the EU General Data Protection Regulation as it forms part of retained UK law (the “UK GDPR”) and the EU General Data Protection Regulation (the “GDPR”) as well as other applicable national laws (together the “Data Protection Laws”).
This Privacy Notice also sets out your rights with respect to your personal data.
If you would like any further information or have any questions on the control and processing of your information, please email us at dataprotection@liontrust.com.
What is personal data?
In this Privacy Notice, personal data means any information relating to a living 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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
Who this privacy notice applies to
This Privacy Notice applies to individuals outside our organisation with whom we interact, including but not limited to visitors to our website; clients and their staff; vendors and service providers; visitors to our offices and registrants for Liontrust’s events.
If you engage with us regarding a potential career at Liontrust, please refer to our Applicant Privacy Notice for details of how we will collect and process your personal data.
If you are a member of Liontrust’s staff, please refer to the privacy notice for Liontrust staff which is available on Liontrust’s Policy Portal.
Given the nature of our website, we do not expect to collect the personal data of anyone under 16 years old. If you are aware that any personal data of anyone under 16 years old has been inadvertently collected or shared with our website, please let us know as soon as you can (see ‘How to contact us’ below) so that we can delete that data.
How we obtain your personal data
Liontrust collects and processes personal data from a variety of sources and for a number of different purposes.
Directly
We may collect personal data directly from you, for example if you are an investor (or potential investor) in our funds, if you visit our website, if you submit your contact details to receive marketing communications from us, or if you submit event-related data to attend our events.
When you visit the Liontrust website, you may be asked to provide certain information about yourself including your name and contact details to access restricted sections of our website content.
Indirectly
Cookies, which collect information about you and your use of the website, are in use on our website. Cookies are small amounts of data that are transferred to your computer or device by our web servers. Cookies help us recognise you and your device and store some information about your preferences or past actions. We use Google Analytics to track your usage of our website and third party cookies to track the performance of our adverts. Liontrust has a Cookie Policy which describes the cookies used, how they operate and how you may disable them. We may also obtain your personal data from third parties such as credit reference agencies and public registers.
What personal data do we collect and process?
The personal data we collect about you depends on the particular activities carried out through our website.
The information we collect about you may include the following:
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Type of information |
Details |
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Information about you |
Name, address, date of birth, gender, marital status, nationality, country of residence, payment details (inc. account numbers, bank statements), identity verification documents, information relating to tax residency status, preferred language, IP addresses, job title, place of employment, your professional online presence, dietary requirements, information on how you use our website, information on the devices you use to visit our website, information on your preferences and interaction with us.
|
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Information to contact you |
Name, address, telephone number and email address. |
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Information to identify you (“Identity Verification”) |
Name, address, photographs, passport and/or driving license details, electronic signatures. |
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For investors in Liontrust funds, information to allow us to provide our services to you and meet regulatory requirements |
Identity Verification documentation, transaction history, industry experience, sources of funds, 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; payment information.
|
Why we collect and we process your personal data
Under Data Protection Laws, we can only use your personal data if we have a proper reason, which will include one or more of the following lawful bases:
- Where you have given us consent to process your personal data for specific purposes such as for the sending of direct marketing communications to you via email or text message. Your consent can be withdrawn at any time.
- For our legitimate interests or those of a third party. This includes where we have a business or commercial reason to process your data, provided that we have first determined that your rights do not override these interests.
- To comply with legal and regulatory obligations to which we are subject.
- For the performance of a contract with you or to take steps at your request before entering into a contract.
The table below explains what we use your personal data for and why.
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What we use your personal data for |
Our reason |
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Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us |
To comply with our legal and regulatory obligations. For our legitimate interests in to preventing or minimising fraud that could be damaging for you and/or us. |
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Managing contractual relations |
To perform our contract with you or to take steps at your request before entering into a contract. This includes the provision of information to our investors in our funds and to our clients to whom we provide investment management services, we collect and process contact information in order to ensure that investors in our funds receive relevant updates relating to their investments. |
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Communications with you not related to marketing, including about changes to our terms or policies or changes to our Funds or services or other important notices |
Depending on the circumstances:
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Marketing Liontrust, its funds and our events |
Where applicable laws and regulations allow, we (i) provide marketing materials, and event invitations to, and hold events for, investors, potential investors, wealth managers and product distributors on the basis of consent or of Liontrust’slegitimate intereststo grow and sustain its business; and (ii) carry out online tracking and targeted marketing and advertisements will be carried out by using cookies on the Liontrust website where we have your consent. |
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Ongoing legal obligations |
Liontrust is subject to laws and regulation in the UK and EU. We may need to hold and process your personal data to ensure that we are in compliance with the law and regulations in these jurisdictions. |
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To administer and manage our website |
Depending on the circumstances:
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Information for marketing purposes
We use your information to identify services and events that we think may be of interest to you. We will only send you marketing messages where you have consented to such contact, or where the services and events are similar to those that we have already provided to you or in which you have expressed an interest.
You have the right to ask us not to not send you marketing messages, and you can also let us know at any time that you wish to change your mind and to start receiving such messages. You can do this:
- by replying directly to the marketing message;
- in case you wish to withdraw from all marketing communications, you can also unsubscribe from all marketing by clicking the appropriate link in any email you receive; or
- at any time by contacting us (see the “How to contact us” section below).
Keeping your personal data up-to-date
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 us via the details in the “How to contact us” section below.
Use of third parties and the transfer of your personal data outside of the UK
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 Data Protection Laws.
It is sometimes necessary for us to transfer your personal data to countries outside the UK and /or sometimes outside the European Economic Area (EEA) too. Where personal data is transferred outside of the UK and/or the EEA, we ensure that this is done using specific legally-approved safeguards that comply with Data Protection Laws and ensure that your information is protected to the same standards as it is in the UK and EEA. We currently transfer data to the following countries outside of the EEA:
- the US;
- India; and
- Australia..
You can request further details of these safeguards by contacting us (see the “How to contact us” section below).
Keeping your personal data secure
We have appropriate security measures to prevent Personal Data from being accidentally lost, used or accessed, altered or disclosed in an unauthorised way. We limit access to your personal data to those who have a genuine need to access it who will only process your personal data on our instructions and are subject to a duty of confidentiality. Policies and procedures are in place that are designed to safeguard the information from loss, misuse and improper disclosure.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website. Any transmission is at your own risk. If you want detailed information on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How we share your personal data
We may share your personal data within the Liontrust group of companies (the companies listed at the top of this privacy notice) including to better understand our investors and their needs, for the purposes of statistical analysis and research, and to improve our services and offerings. Liontrust Europe S.A in Luxembourg operates under its own privacy notice.
We share your personal data outside the Liontrust group of companies:
- with our service providers, suppliers, sub-contractors and partners;
- with advertising networks (in order to allow you to receive relevant advertisements);
- with our professional advisors such as auditors, accountants and legal advisors;
- With regulatory and law enforcement authorities (for example the FCA and HMRC)where we are required to do so by applicable law or regulation or for the purposes of the prevention of fraud, money laundering or other crime; and
- with relevant third parties in connection with the sale or potential sale of all or part of our business or assets.
How long we keep your personal data for
Our policy is to retain personal data only for as long as it is needed for the purposes described in the section “Why we collect and we process your personal data.”
Our retention periods are set in accordance with applicable rules and standards which may include local regulatory and legal retention requirements and we maintain internal policies and procedures to ensure that data is reviewed and deleted or anonymised in line with these rules and standards. Details of retention periods for different aspects of your personal data are available in our retention policies which you can request by contacting us using the details in the “How to contact us” section below.
If you are an investor, your information will usually be retained for a period of seven years after you cease to invest with us, but may be retained for longer if required to comply with applicable laws or regulations, or if necessary for the purposes of establishing or defending our legal rights. We may also retain your information for longer if we have a legitimate interest in doing so for archiving or historical purposes or for statistical or research purposes, in which case we will always take steps to anonymise information to the maximum extent possible.
Your Rights
You are entitled to exercise certain rights in relation to your personal data. These rights may be subject to statutory restrictions, where they are applicable. The rights include:
- The right to access your data;
- The right to rectify any errors in your data;
- The right, in certain circumstances, to erase your data;
- The right to restrict the processing of your data;
- The right, in certain circumstances, to object to your data being processed;
- The right to withdraw consent; and
- The right to complain.
If you want to exercise any of these rights, then please contact us using the details in the “How to contact us” section below.
Responses to requests to access your data under UK GDPR and EU GDPR are free. However, please be aware that if a request is considered manifestly unfounded, excessive or repetitive, we reserve the right to charge a reasonable fee for access. We will respond to your request within one month of receipt of your request. In certain cases, this may not be possible (for example, if the request covers a wide range of information and sources or systems) in which case we will inform you of this and the timeframe within which we will be able to respond.
Where data is provided by you on the basis of consent, you are within your rights to withdraw that consent at any time. Withdrawal of consent may result in benefits that were otherwise provided to you being withdrawn.
Please note that where your personal data is processed for the purposes of our legitimate interests, you have a right to object to such processing and Liontrust will no longer process the personal data until it can be demonstrated that we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
We may also request that you provide us with any information necessary to confirm your identity before we respond to any request you make.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data by using the details in the “How to contact us” section below. We hope we will be able to resolve any issues you may have.
If you are not satisfied with our response to your complaint or believe our processing of your personal data does not comply with data protection law, you also have the right to lodge a complaint with the Information Commissioner in the UK.
The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
If you are in the EU you have the right to complain to your local supervisory authority or to our lead supervisory authority:
Commission nationale pour la protection des données, Service des réclamations
15, Boulevard du Jazz, L-4370 Belvaux, Grand Duchy of Luxembourg
Changes to this privacy notice
We may update this Privacy Notice from time to time and will publish an up-to-date copy of the Privacy Notice from time to time on the website. We recommend that you check this page from time to time to inform yourself of any changes in this Privacy Notice.
If you would like this Privacy Notice in another format (for example audio, large print, braille) please contact us using the details in the “How to contact us” section below.
How to contact us
You can contact us here at Liontrust if you have any queries, concerns or complaints on the content of this Privacy Notice, or our approach to data protection by using any of the following methods:
By email: dataprotection@liontrust.com
By post: 2 Savoy Court, London WC2R 0EZ
By telephone: +44 (0) 207 412 1700
