Privacy notice | Liontrust Asset Management PLC

Privacy Notice

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.

It is important that you know what personal information Liontrust Asset Management PLC holds about you and how it is used, and this Privacy Notice has been written to explain this. If you would like any further information or have any questions, please email us at dataprotection@liontrust.co.uk.

 

Who we are


We are a specialist fund management company. Our Head Office address is 2 Savoy Court, London, WC2R 0EZ and we also have offices in Edinburgh and Luxembourg.
 We manage a range of funds and portfolios for both UK and international investors.

 

What data do we hold?

Fund investors

We hold data that fund investors provide to us by filling in forms or by corresponding with us by phone, email or otherwise. This data may include:

  • Contact details (name, address, telephone number and email address).
  • Financial and debit card information, credit history and identification records.
  • Where permitted in accordance with local law, we may also in some circumstances record telephone conversations.
  • Identity verification. We will use information provided by third parties (e.g. fraud prevention agencies) when verifying the identity of fund investors and when carrying out anti-money laundering checks. Such information may include some details about any criminal convictions and any allegations regarding criminal activity that relate to the individual, as well as details of their status as a politically exposed person. It may also include their nationality and identification records (e.g. passport information).
 
Financial intermediaries

We hold data on financial intermediaries, such as pension fund consultants, discretionary fund managers, wealth managers and financial advisers. This data may include:

  • Contact details (name, telephone number and email address).
  • The name and address of the firm they are employed at and their role. We may also hold the contact’s regulatory authorisation details.
  • Activity with our sales team (e.g. face-to-face meetings and telephone calls).
  • Email preferences.
  • Interactions with centralised emails (e.g. whether an email has been opened and/or clicked).
  • Pages viewed on our website.
  • Investments in Liontrust funds or portfolios (where this data are available).

Journalists

We hold data on journalists sourced from third party databases. This data may include:

  • Contact details (name, address, telephone number and email address).
  • Passport details.


We do not hold or process any data on financial intermediaries that has special protections under GDPR.

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.

 

How do we use the data we hold?

Fund investors

Fund investors’ personal data may be processed by the fund or Liontrust (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:

  • To facilitate the opening of their account with the fund, the management and administration of the investors’ holdings in the fund and any related account on an ongoing basis (the “Services”), which are necessary for the performance of their contract with the fund. This includes without limitation the processing of redemption, conversion, transfer and additional subscription requests and the payment of distributions.
  • To carry out anti-money laundering checks and related actions which the fund considers appropriate to meet any legal obligations imposed on the fund relating to, or the processing in the public interest or to pursue the fund’s legitimate interests in relation to, the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an ongoing basis, in accordance with the fund's anti-money laundering procedures.
  • To report tax related information to tax authorities in order to comply with a legal obligation.
  • To monitor and record calls and electronic communications for:
    1. the processing and verification of instructions;
    2. the investigation and fraud prevention purposes;
    3. crime detection, prevention, investigation and prosecution;
    4. to enforce or defend the fund and its affiliates, itself or through third parties to whom it delegates such responsibilities, or rights in order to comply with any legal obligation imposed on the fund;
    5. to pursue the fund’s legitimate interests in relation to such matters; or
    6. where the processing is in the public interest.
  • To disclose information to other third parties, such as service providers of the fund, auditors, regulatory authorities and technology providers, to comply with any legal obligation imposed on the fund or to pursue the legitimate interests of the fund.
  • To monitor and record calls for quality, business analysis, training and related purposes to pursue the legitimate interests of the fund to improve its service delivery.
  • To update and maintain records and fee calculation.
  • To retain AML and other records of individuals to assist with the subsequent screening of them.
  • Which are necessary to comply with the fund or Liontrust’s legal obligations and/or which are necessary for the fund or Liontrust's legitimate interests indicated above and/or the processing is in the public interest.

     

Financial intermediaries

The data we hold allow us to efficiently and effectively manage our existing and prospective relationships with financial intermediaries. We also send personalised email communications to intermediaries containing relevant content such as insights and thought leadership from our fund managers, fund commentaries, company news and event invitations. Recipients of these emails have the ability to change their email preferences or unsubscribe from all communications at any time by clicking the ‘Manage email preferences or unsubscribe’ link found at the bottom of every email we send.

Our lawful basis for holding and processing this data is legitimate interests. Intermediaries have a responsibility to their clients to research and keep up to date with funds, economies and markets. The communications provided by Liontrust are informative for intermediaries and keeps them updated so they can keep their own clients informed. They may not come across this information and data in any other way. Furthermore, intermediaries are given plenty of opportunities to unsubscribe from centralised emails and to manage their own email preferences.

We do not share the data we hold with any other parties except as set out above.


Journalists

Journalists’ data may be used by the company for the following purposes

  • To distribute company press releases
  • To invite journalists to meet our spokespeople
  • To invite journalists to events
  • To highlight relevant news, spokespeople who may be of interest, to send blogs, e-alerts or comment
  • If we are working with another firm on joint projects we may share these details
  • Some business trips may require your personal details to be stored by the company to help with the travel arrangements.


Where has our data come from?

Fund investors

Fund investors or someone representing them, for example a financial adviser, an employer or the business they work for, may give us information about the investor by completing forms (both physical and electronic visitors), concluding contractual arrangements or by contacting us by phone, email or otherwise. We may also receive their personal information from a third party where they have obtained the investor’s consent to share such information. Alternatively the fund investor will have provided the information to us directly.

Financial intermediaries

The source of the majority of our data is Matrix Solutions / Financial Clarity. When registering with MyLocalAdviser.co.uk, individuals are asked if they consent to their data being passed to selected third parties, including Liontrust. We receive this data from Matrix Solutions / Financial Clarity on a monthly basis where it is uploaded to our CRM system. Depending on the data received, new records are created and existing ones are updated as necessary.

The other sources of data are:

  • Data provided directly by intermediaries to our sales team or another Liontrust representative.
  • Other third parties e.g. event organisers.

Journalists

The majority of emails are sourced from a third party database, Roxhill. Some data has been provided directly by the journalists.


Your rights as a data subject


As a data subject, you have a number of rights, as follows:

  • Right to be informed. This Privacy Notice provides details on the data we hold and how we use it. Where we receive data via a third party, we will notify these data subjects via email within 30 days to provide notification that we hold their data and to outline how we will process it.
  • Right of access. You have the right to obtain confirmation that your data is being processed and access to your personal data.
  • Right to rectification. You have the right to have any inaccurate personal data rectified, or completed if it is incomplete.
  • Right to erasure. You have the right to have your personal data erased. Please note that some details will be required to remain on a suppression list to ensure that we do not add your details to our CRM system at a later date.
  • Right to restrict processing. You have the right to request the restriction or suppression of your personal data. This is an alternative to requesting the erasure of your data.
  • Right to object. You have the right to object to direct marketing. Email recipients can access our email preference centre to change their email preferences or unsubscribe from all emails by clicking the ‘Manage email preferences or unsubscribe’ link found at the bottom of every email we send.


Please contact
dataprotection@liontrust.co.uk if you wish to exercise one of your data subject rights.

Please note, as our lawful basis for processing personal data is legitimate interests, the right of data portability does not apply.

 

Data retention

Fund investors

We will only retain fund investors’ personal information for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal or regulatory requirements.

As a regulated business, there are record retention obligations on us. We retain fund investors’ personal data to comply with these obligations.

Financial intermediaries

Records will be held indefinitely unless we are instructed by the financial intermediary to restrict processing or to erase the data as set out above.

Journalists

Records will be held indefinitely unless we are instructed by the journalist to restrict processing or to erase the data as set out above.


How to contact us


If you have any questions or would like further information
in relation to this Privacy Notice or your personal data, please contact us at dataprotection@liontrust.co.uk.

 

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.

 

This Privacy Notice was last updated on 07/09/2018.
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