ONLINE PRIVACY AND COOKIES POLICY

This Online Privacy and Cookies Policy applies to http://www.greshamhouse.com/ (the “Website”) and the Investor Portal (https://secureportal.greshamhouse.com/login?returnurl=%2f) (the “Investor Portal”) which are both operated by Gresham House Asset Management Limited (“GHAM”, “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.

For the purposes of this Online 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, sign up for and use the Investor Portal, sign up through the “Want to stay updated?” box on the Website’s homepage, interact with us using our “Contact Us” functions in the Website or Investor Portal, or contact us by e-mail, post, or telephone.

Your personal information 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. For more details on the Gresham House Group follow this link: http://greshamhouse.com/

You should read this Policy, so you know what personal information we collect about you, what we do with it and how you can exercise your rights in connection with it. You should also read any other privacy notices that we give you, that might apply to our use of your personal information in specific circumstances from time to time.

If you have any question about this Policy or wish to exercise any of the rights mentioned in it, please contact Andrew Hampshire via e-mail at A.Hampshire@greshamhouse.com or via phone at +44 (0)20 3837 6277.

Financial advisors or other intermediaries 

You may have been introduced to us by your financial advisor, private bank or other intermediary. When such intermediaries process your personal information on our behalf, this Policy will apply, as well as the other fair processing information you will have received from us. When such intermediaries process your personal information as data controllers in their own right, their own privacy policy and notice will apply, and you should ask them for a copy if you do not have one by the time you are introduced to us.

What categories of personal information do we collect?

When you visit our Website and the Investor Portal[1], 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 portal username, 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 or Investor Portal 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.

When you contact us by e-mail, post, or telephone, we may collect the following personal information from you (depending on the information you choose to provide) and we will use it for the purposes mentioned in this Policy (below):

  • your name;
  • your personal or work-related e-mail address (depending on which you choose to give to us);
  • your personal or work-related contact details (depending on which you choose to give to us) such as your telephone number(s), fax numbers and postal address; and
  • any other personal information you choose to give to us in connection with your communication to us via e-mail, mail, or telephone call, which may relate to matters such as your investment preferences or our portfolio services and how they apply to you.

Where you interact with us using our “Contact Us” function on our Website or the Investor Portal, we may collect the following personal information from you (depending on the information you choose to provide) and we will use it for the purposes mentioned in this Policy (below):

  • your name;
  • your log-in details for the Investor Portal (when you interact with us using our “Contact Us” function on the Investor Portal);
  • your personal or work-related e-mail address (depending on which you choose to submit to us);
  • 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 which may relate to matters such as your investment preferences or our portfolio services and how they apply to you. 

When you sign up through the “Want to stay updated?” box on the Website’s homepage, we may collect the following personal information from you and we will use it for the purposes mentioned in this Policy (below):

  • your personal or work-related e-mail address (depending on which you choose to submit to us);
  • the capacity in which you are interested in staying updated (either Corporate Advisor, Family Office, Institutional Investor, Wealth Manager, Private Investor, Forest Owner, Forestry Manager, or Investor Consultant); and
  • the type of products which interest you (public equity, private equity, forestry, infrastructure and housing, renewables and new energy, long term investment solutions, co-investment).

When you request access to the Investor Portal through the “request access” function on the log in page of the Investor Portal, we may collect the following personal information from you and we will use it for the purposes mentioned in this Policy (below):

  • your name;
  • your investor status with the Gresham House Group;
  • your personal or work-related e-mail address (depending on which you choose to submit to us);
  • any other personal information you choose to provide us with in connection with your request to access the Investor Portal which may relate to matters such as your investment preferences or our portfolio services and how they apply to you.

Such information may be reflected in the Investor Portal once you have gained access to it.

We ask that you do not provide us with any ‘special categories of personal data’ when you interact with us using our “Contact Us” function on our Website or the Investor Portal, when signing up to access the Investor Portal, or when contacting us via e-mail, mail, or telephone call. ‘Special categories of personal data’ 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 wish to process it. We would need your explicit consent in order to justify our processing of it.

[1] Please note that, if you are investor, or co-investor alongside, any entity of the Gresham House Group, the Investor Portal will contain some of the personal information you provided to us when you first came to us as an investor/co-investor, including your investment portfolio. We have explained how we process such personal data in our processing notice included in your on boarding documentation.

How is your personal information collected?

We will collect your personal information from you when you voluntarily provide it to us. We may also collect it where lawful to do so from and combine it with information from the following third parties:

  • through your intermediaries such as your financial advisor, broker, private bank or other intermediary; or
  • from publicly available sources such as internet search engines or social media.

How do we process your personal information?

We may use personal information about you for the following purposes:

  • to respond and/or deal with your requests or enquiries including, where applicable, the set up and administration of your investment;
  • to improve our products and services and to ensure that content from the Website and Investor Portal is presented in the most effective manner for you and for your computer (or other electronic Internet-enabled device);
  • to administer the Website and Investor Portal;
  • for internal record keeping;
  • to contact you by e-mail or phone;
  • to carry out direct marketing (see below – we may sometimes need your consent for this, in particular where it cannot be justified by legitimate interests);
  • where necessary, as part of any restructuring or sale of our business or assets;
  • to perform any contract GHAM or any other member of the Gresham House Group has with you or to take steps at your request prior to entering into a contract;
  • to maintain the security and integrity of our systems and platforms (and detect and prevent actual or potential threats to the same);
  • for compliance with our legal, regulatory and other good governance obligations;
  • to analyse trends and customer journeys in using and accessing our Website and Investor Portal;
  • for management and audit of our business operations (including credit and risk management, insurance, training and similar administrative purposes);
  • for market research and analysis, and developing statistics;
  • for activities relating to the prevention, detection and investigation of crimes;
  • when you request that we disclose your personal information to a third party;
  • for establishment and defence of legal rights;
  • for compliance with instructions, orders and requests from law enforcement agencies or courts;
  • to monitor emails, calls and other communications with you (see section below “Monitoring of communications”);
  • to verify your identity, where relevant;
  • when you seek to exercise your rights under data protection law.

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 computerised files and electronic databases.

Monitoring of communications

We may monitor and record telephone calls, emails, and other communications with you 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 particular, where we are required by the Financial Conduct Authority’s regulatory regime to record certain telephone lines (as relevant) we will do so. In addition, where appropriate and having regard to applicable data protection law, our monitoring may check for obscene or profane content in communications. In addition, telephone calls between us and you in connection with your enquiries or requests may be recorded to make sure that we have a record of what has been discussed and what your instructions or requests are. We may also record these types of calls for the quality control and staff training purposes mentioned above.

Legal bases for our processing of your personal information

We are required by law to set out in this Policy the legal bases on which we rely in order to process your personal information. The legal bases which relate 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 youor 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.

We may also rely on this lawful reason for the sharing of personal information with third parties (see section ‘Sharing of your personal information’ below);

2) Processing that is necessary for our own legitimate interestsor those of third parties (such as the other entities which are part of the Gresham House Group) – such as:

  • for management and audit of our business operations (including credit and risk management, insurance, training and similar administrative purposes);
  • when we monitor emails, calls and other communications with you (see section above ‘Monitoring of communications’);
  • to deal with our good governance requirements;
  • for market research and analysis, and developing statistics;
  • where relevant, for our direct marketing communications about products and services available from the members of the Gresham House Group;
  • to respond and/or deal with your requests or enquiries;
  • to improve our products and services and to ensure that content from the Website and Investor Portal is presented in the most effective manner for you and for your computer (or other electronic Internet-enabled device);
  • to administer the Website and Investor Portal;
  • for internal record keeping;
  • to analyse trends and customer journeys in using and accessing our Website and Investor Portal;
  • for establishment and defence of legal rights;
  • where necessary as part of any restructuring or sale of our business or assets; and
  • to maintain the security and integrity of our systems and platforms (and detect and prevent actual or potential threats to the same).

We may also rely on this lawful reason for the sharing of personal information with third parties (see section ‘Sharing of your personal information’ below).

3) Processing that is necessary to comply with a legal obligation – such as:

  • when you seek to exercise your rights under data protection laws;
  • for compliance with legal and regulatory requirements;
  • for establishment and defence of legal rights and for compliance with instructions, orders and requests from law enforcement agencies or courts;
  • for activities relating to the prevention, detection and investigation of crimes;
  • to verify your identity, where relevant; and
  • when we monitor or record telephone calls or other communications with you (where relevant) (see section above ‘Monitoring of communications’).

We may also rely on this lawful reason for the sharing of personal information with third parties (see section ‘Sharing of your personal information’ below).

4) Processing that is based on your consent – such as:

  • when you request that we disclose your personal information to a third party;
  • where relevant, for our direct marketing communications about products and services available from the members of the Gresham House Group;
  • when we process special categories of data about you (see above for what this means). Consent for this processing must be explicit consent.

We may also rely on this lawful reason for the sharing of personal information with third parties (see section ‘Sharing of your personal information’ below).

Withdrawing your consent

You have the right at any time to withdraw your consent where that is relied upon as the lawful reason for processing your personal information. To withdraw your consent, please email Andrew Hampshire at a.hampshire@greshamhouse.com.

If you withdraw your consent and if there is no alternative lawful reason which justifies our processing of your personal information for the purpose or purposes you originally agreed to, we will no longer process your personal information for that purpose or purposes.

Who do we share your personal information with and why?

Your personal information may 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 management, accounting, legal, logistics, audit, compliance, information technology and other corporate staff who need to know these details for their functions within GHAM or the Gresham House Group. Please note that certain individuals who will see your personal information may not be based in the UK or in your country (see below).

We may share personal information within the Gresham House Group as needed for management, analysis, planning and decision making, including in relation to taking decisions regarding the expansion and promotion of our product and service offering, as part of our regular reporting activities on company or group performance, for the purpose of regulatory reporting, in the context of a business reorganisation or group restructuring exercise, 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 to GHAM and/or the Gresham House Group.

Third parties in this context means any member of the Gresham House Group and providers to GHAM or the Gresham House Group of 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 or for us.

We may disclose specific personal information upon lawful request by courts and other judicial bodies, government authorities, law enforcement and regulatory authorities where required or permitted by applicable law. Personal information may also be released to external parties in response to legal process, and when required to comply with applicable laws and regulations, or to enforce our agreements, corporate policies, or to protect the rights, property or safety of our businesses, our employees, agents, customers, and others, as well as to parties to whom you authorise us to release your personal information.

We may share your information with fraud prevention agencies and we may contact the FCA, industry bodies and any other organisation that you have told us are associated with you to confirm the accuracy of information which you have provided.

Your personal information may also be made available to third parties or partners where necessary as part of any restructuring of the Gresham House Group or sale of any of our businesses 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.

We may transfer your personal information outside the European Economic Area (see  below).

Will my personal information be transferred abroad?

We may transfer your personal information outside the UK and the European Economic Area (EEA), including Guernsey and South Africa.

In relation to the transfer of personal information to Guernsey, the European Commission has issued an adequacy decision in respect of Guernsey. This means that Guernsey is deemed by the European Commission to provide an adequate level of protection for your personal information, which means we can transfer personal information to Guernsey without having to put in place additional measures to ensure an adequate level of protection of personal information.

Whilst some countries already have adequate protections for personal information under applicable laws, in other countries (such as South Africa) 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.

We will only make transfers of personal information outside the EEA if:

  • the country to which the personal data is to be transferred ensures an adequate level of protection for personal data;
  • we have put in place appropriate safeguards to protect your personal data, such as an appropriate contract with the recipient;
  • the transfer is necessary for one of the reasons specified in data protection legislation, such as the performance of a contract between us and you;
  • Binding Corporate Rules or US Privacy Shield apply; or
  • you explicitly consent to the transfer.

For more information about what are those appropriate safeguards and how to obtain a copy of them or to find out where they have been made available, email Andrew Hampshire at a.hampshire@greshamhouse.com.

Criteria used to determine the retention period

We need to retain your personal information for as long as necessary to fulfil the purposes for which it was collected (and those purposes are as described above), including for the purposes of satisfying any legal or regulatory requirements and in case of claims. If you would like further information about our data retention policy, email Andrew Hampshire at A.Hampshire@greshamhouse.com.

The criteria we use to determine data retention periods for your personal information include the following:

  • retention in case of queries. We will retain some of it in case of queries from you. For instance, if you send to us a query, we will retain your personal information for as long as necessary for us to ensure that your query has been addressed exhaustively;
  • retention in case of claims. We will retain some of it for the period in which you might legally bring claims against us; and
  • retention in accordance with legal and regulatory requirements. We will retain some of it based on our legal and regulatory requirements.

Your rights under applicable data protection law

Your personal information is protected under data protection law and you have a number of rights which you can enforce against us as your data controller. Your rights under data protection law are as follows (please note that some of these rights do not apply in all circumstances):

  • the right to be informed, includingabout our processing of your personal information. This is the reason for this Policy;
  • the right to have your personal information corrected if it is inaccurateand to have incomplete personal information completed;
  • the right to objectto processing of your personal information. This right allows you to object to processing for purposes of direct marketing, to processing based on legitimate interests and to processing for purposes of statistics;
  • the right to restrict processingof your personal information;
  • the right to have your personal information erased(the “right to be forgotten”);
  • the right to request accessto your personal information and to obtain information about how we process it;
  • the right to receive, move, copy or transfer your personal information(“data portability”); and
  • rights in relation to automated decision-makingincluding profiling.

If you want more information on your privacy rights or if you would like to exercise any of your privacy rights, please contact Andrew Hampshire via e-mail at A.Hampshire@greshamhouse.com.

We encourage you to let us know if you have any concern about how we are processing your personal information, so we can try to resolve your concerns.

You have the right to complain to a supervisory authority. The supervisory authority in the UK is the Information Commissioner’s Office (ICO) (https://ico.org.uk/). The ICO has enforcement powers and can investigate compliance with data protection laws.

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 perform the contract with you or to be able to enter into our contract with you.  If you are a wealth manager or acting on behalf of your organisation or of an individual for whom you are making investments 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 or Investor Portal (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 or the Investor Portal, or to send you updates through the “Want to stay updated?” function on our Website, unless you provide the personal information requested when using those functions, in these ways 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 via e-mail about our products and services or the products and services of the Gresham House Group 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 or the products and services of the Gresham House Group. 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 Andrew Hampshire at A.hampshire@greshamhouse.com at any time.

The Gresham House Group

The members of the Gresham House Group are available to view at www.greshamhouse.com.

COOKIES

What are cookies?

Cookies are small, often encrypted, text files that are used by websites to perform certain functions.

How do we use cookies?

Information supplied to us using cookies helps us to analyse the profile of our visitors and provide you with a better online experience.

We use cookies to track how you use our Website by providing usage statistics. Cookies are also used to serve ads to you based upon your browsing history and previous visits to the Website.

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.

Social Sharing

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 may modify or amend this Policy from time to time. We encourage you to check this webpage regularly so that you can read the up to date version of this Policy. If we make substantive or material changes to this Policy, we will inform you by notice on the Website or via other appropriate channels in accordance with the requirements of data protection law.

This Policy only extends to the Website and the Investor Portal 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.

Contact/address details

If you have any questions about this Policy, please contact Andrew Hampshire at A.Hampshire@greshamhouse.com.