This Privacy Notice (“Notice”) applies to Quilter Investors Limited and the funds which it operates, each of which shall be a separate data controller for the purposes of GDPR (as defined below). References in this notice to “Quilter Investors”, “we”, “us” and “our” are to the individual entity which collects your personal data.
We are committed to protecting your privacy and ensuring that your personal data is collected and used appropriately, lawfully and transparently.
This Notice explains:
- who we are
- what personal data we collect
- how we use your personal data and on what legal basis
- who we share your personal data with and why
- how we keep your personal data secure
- your rights
- how to contact us
Who We Are
Quilter Investors provides cross-border investment solutions, asset management and discretionary management services.
Quilter Investors is subject to EU Regulation 2016/679 (“GDPR”), and the UK Data Protection Act 2018 which supersedes the Data Protection Act 1998.
Please read this Notice carefully as it describes the types of personal data we may collect from you or that you may provide and the legal basis and practices for Quilter Investors’ processing of your personal data is set out in this Notice. This Notice forms part of, and should be read in conjunction with the Terms and Conditions of use of our website www.quilterinvestors.com (“Website”).
What Personal Data We Collect
Personal data means information by which you may be personally identified directly or indirectly; this includes your name, address, phone number and other information. We collect certain personal data about you when you use our Website, contact us about products and services, complete a fund application form, or register to receive one of our mailings. The type of personal data we collect will depend on the purpose for which it is collected and will include:
- your contact details
- information to verify your identity
- financial and bank details
- details set out in the fund application forms
We may collect personal data directly from you. For example, we ask for personal data at the start of our relationship (eg: when you complete a fund application form) and in subsequent communications in order to check your identity. This is a legal requirement in some jurisdictions and is important to help safeguard you and us against potential crime.
Where we provide our services or products to trusts, we collect personal data on the beneficiaries and trustees. Where we provide our services to companies we may collect personal data on directors, shareholders and beneficial owners of the company.
We keep your personal data only for as long as is necessary for the purpose for which it was collected, or for legal or regulatory reasons. Personal data will be securely disposed of when it is no longer required, in accordance with our data retention and disposal policies, which can be made available on request.
How We Use Your Personal Data (Purpose of Processing) and on What Legal Basis
We process your personal data for the following purposes:
To perform our contract with you and to support and maintain that relationship. This includes the following:
- assessing and processing application forms
- providing our products and/or services to you, including the management of our relationship with you
- monitoring or recording of telephone calls with you
- record keeping to ensure our products and/or services operate within the law and relevant regulatory requirements
To comply with legal and regulatory requirements. These requirements include the following:
- confirming your identity for regulatory purposes;
- detecting and preventing fraud, crime, money laundering, terrorist financing, bribery or other malpractice.
For specific business purposes which are in our legitimate interests without affecting your rights and freedoms to enable us to provide you with appropriate products and services and a secure experience. Our business purposes include providing communications which we think will be of relevance to you. You have the right to object to us processing your personal data for such business purposes and in certain circumstances we will ask for your consent.
Basic identifiers about you (e.g. your name and address) is matched with information from Experian Marketing Services to create demographics and infer customer ‘types’ so that we can define groups based on factors like interests, age, location and more. This helps us better understand our customers in order to adapt and improve our products and services. If you would like to know more about the information we receive from Experian Marketing Services, you can visit their website which explains who Experian Marketing Services are, what they do and why.
Who We Share Your Personal Data with and Why
We share your personal data with trusted third parties, who perform tasks for us and help us to provide our products and/or services to you, and with other agencies where required by law, court order or regulation. These include:
- other companies within the Quilter group
- third parties who perform tasks for us to help us provide services and products to you on our behalf (eg: investment administration services; verification of your identity in line with money laundering or other requirements)
- regulatory or government agencies
- professional advisers
- any successor to all or part of our business. For example, in the event of a merger, acquisition, divestiture, change of control or liquidation of Quilter Investors or part of its business (or in anticipation of such an event), we may share your personal data as part of that transaction where required in order to fulfil our obligations in this Notice.
How We Keep Your Personal Data Secure
We are committed to ensuring the confidentiality of the personal data that we hold and continue to review our security controls and related processes to ensure that your personal data remains secure.
As part of the services we offer you, the personal data you provide to us may be transferred to countries outside the country in which the personal data was first provided. Where these countries do not have data protection laws equivalent to ours, we will ensure that third parties receiving the personal data have provided adequate safeguards and agree to treat your personal data with the same level of protection as in the country in which the personal data was first provided.
When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal data is kept secure and prevented from unauthorised or accidental access, processing, copying, modification, erasure, loss or use.
Under applicable data protection law, you have the right to ask us:
- for a copy of the personal data we hold about you
- to update or correct your personal data
- to delete your personal data
You also have the right to:
- object to the processing of your personal data
- object to automated decision making and profiling
- data portability
If you wish to request a copy of the personal data we hold about you please contact us using the details below.
More information about your data protection rights can be found by contacting the Information Commissioner’s Office or relevant local supervisory authority (see details below).
How to Contact Us
If you have questions about this Notice, need further information about our privacy practices, or wish to give or withdraw your consent to the receipt of marketing information, change your preferences to receive marketing communications or update or correct your personal data, please contact us through your usual Quilter Investors contact or as set out below. You can also use the addresses below to raise a complaint about how we have handled your personal data.
Head of Regulatory Operations
Quilter Investors Limited
Millennium Bridge House
2 Lambeth Hill
Email address: firstname.lastname@example.org
If you are not satisfied with our response you can lodge a complaint with the Information Commissioner’s Office on their helpline 0303 123 1113 or at https://ico.org.uk/concerns/.