INDEPENDENT FRANCHISE PARTNERS, LLP PRIVACY NOTICE

ABOUT THIS NOTICE

Independent Franchise Partners, LLP (“we” or “us”) is committed to protecting and respecting your privacy. This notice (together with any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us as a data controller.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 1998, and, from 25 May 2018, the General Data Protection Regulation, (or any other applicable data protection legislation) (together, the “Act”), the data controller under this Notice is Independent Franchise Partners, LLP of Level 1, 10 Portman Square, London, W1H 6AZ, United Kingdom.

INFORMATION WE MAY COLLECT FROM YOU

We may collect and process the following data about you:

  • Information you give us.

    We may collect and process your personal data if you are an individual who is connected with an investor, or a service provider to an investor (for example a director, officer, employee, representative, shareholder, investor, client, beneficial owner or agent):-

    • in connection with an investment (or a prospective investment); or

    • as a result of any associated interactions with us (including the initial or subsequent application for shares, and including the recording of electronic communications or phone calls where applicable) or via our website http://www.franchisepartners.com/ (the “Website”); or

    • by virtue of you otherwise providing us with personal data, including as a consequence of entering into an Investment Management Agreement with us.

    You may give us information (including personal data) about you by filling in forms on the Website, when meeting with us in person or by corresponding with us by phone, e-mail or otherwise. The information you give us may include your name, title, address, e-mail address, investment holdings, phone number, bank details, tax forms, details relating to your investment activity, date of birth and copies of identification documents such as your driving licence and/or passport, as well as any other personal data you choose to give us.

    Use of the Website does not require you to submit your personal data to us, but if you are registered on the Website, we will also collect your name and contact details, including where relevant your job title, business contact details and details of any organisations that you represent, your log in details, and any personal data contained in free text boxes that you fill in, including any enquiries or comments that you submit via the Website.

  • Information we collect about you.

    With regard to each of your visits to our Website we may automatically collect the following information:

    • technical information, including the IP address used to connect your computer or device to the internet, your browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and

    • information about your visit to the Website, including the full URL clickstream to, through and from the Website (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

    We may collect any phone number used to call us.

    We may also collect information about individuals connected with our service providers (for example directors, officers, employees, representatives, or agents) as a consequence of us engaging that service provider. We will treat such personal data in accordance with this notice.

  • Information we receive from other sources.

    We also work closely with third parties (including, for example, investment consultants, business partners, sub-contractors in technical services, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

USES MADE OF THE INFORMATION

Where you are an individual connected with an investor (including a prospective investor), or (in respect of points 5, 9, 10, 11, 12 and 13 below) a visitor to our Website, we use information held about you for the following purposes:

  1. to facilitate the opening of an investment account with us or with the funds whose portfolios we manage, the management and administration of underlying investments and any related account on an on-going basis (the “Services”), and to provide you with other information, products and other services that you request from us from time to time, which are necessary for the performance of any contract with us;

  2. to carry out anti-money laundering checks and related actions which we consider appropriate to meet any legal obligations imposed on us, where necessary for the performance of a task carried out in the public interest or to pursue our legitimate interests in relation to:-

    • preventing fraud, money laundering, terrorist financing, bribery, corruption or tax evasion; and

    • preventing the provision of financial and other services to persons who may be subject to economic or trade sanctions,

    in accordance with our anti-money laundering procedures;

  3. to report tax related information to tax authorities in order to comply with a legal obligation;

  4. (i) processing and verification of instructions, (ii) fraud investigation and prevention, (iii) crime detection, prevention, investigation and prosecution, (iv) to enforce our rights, to defend ourselves or to comply with any legal obligation imposed upon us, whether directly or through third parties to whom we delegate such matters, (v) to pursue our legitimate interests in relation to such matters or (vi) where the processing is in the public interest;

  5. to disclose information to other third parties such as our service providers, auditors, regulatory authorities and technology providers in order to comply with any legal obligation imposed on us or in order to pursue our legitimate interests;

  6. to monitor and record calls for quality control, business and statistical analysis, training or to improve service delivery;

  7. to update and maintain records and fee calculations and for internal records management;

  8. to retain anti-money laundering and other records of individuals to assist with subsequent screening where this is necessary;

  9. to improve our products and services and the Website and ensure that content from the Website is presented in the most effective manner for you and for your device;

  10. to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

  11. to allow you to participate in interactive features of the Website, when you choose to do so;

  12. as part of our efforts to keep the Website and related IT architecture safe and secure, including for the investigation of any alleged security breaches, and

  13. to identify you when you contact us.

We use this information for the purposes set out in paragraphs 6 to 13 above only where this is necessary for our legitimate interests or those of a third party, and where such legitimate interests are not overridden by your interests, fundamental rights or freedoms.

If you are an individual connected with one of our service providers, we may use your personal data for general contract management purposes where this is necessary for our legitimate interests or those of a third party and such legitimate interests are not overridden by your interests, fundamental rights or freedoms.

Accordingly, you understand that we may use your personal data for these purposes, provided that we act in a fair, transparent and accountable manner and take appropriate steps to prevent such activity having any unwarranted impact on you and also noting your right to object to such use, as discussed below.

Given the specific purposes for which we envisage using your personal data, we do not anticipate being required to obtain your consent to do so. Should we wish to use your personal data for other specific purposes that require your consent, we will contact you to request this.

COOKIES

The Website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse the Website and also allows us to improve the Website. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy.

DISCLOSURE OF YOUR INFORMATION

We will not transfer, disclose, sell or distribute your personal data to third parties other than as set out in this notice, unless we have your permission or are otherwise required or permitted to do so by law.

We may disclose your personal data:

  • to third parties including our suppliers, sub-contractors, and technical services providers, as required for our everyday business purposes, including to provide you with the information, products or services you request.

  • to analytics and search engine providers that assist us in the improvement and optimisation of the Website;

  • to competent authorities (including tax authorities), courts and bodies as required by law or where requested; or to protect the rights, property, or safety of Independent Franchise Partners, LLP, its customers, or others. This may include exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction;

  • to an authorised financial advisor or investment consultant or other third parties that you involve in the administration of your investments;

  • to credit reference agencies in order to carry out money laundering and identity checks and comply with legal obligations;

  • if Independent Franchise Partners, LLP or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

WHERE WE STORE YOUR PERSONAL DATA

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our service providers. Such staff may be engaged in, among other things, the provision of support services. Where your personal data is transferred outside the EEA, in particular to any jurisdiction which is not deemed to offer equivalent protection to your personal data as provided for under the Act, we will always ensure that such transfers and any subsequent processing of your personal data will be carried out in full compliance with the Act. This may include us entering into the EU Standard Contractual Clauses for the transfer of data from controllers to processors, the template text of which is available here.

THIRD-PARTY SITES

The Website may, from time to time, contain links to and from the websites of our business partners, affiliates and other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies. We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

YOUR RIGHTS

It is within your rights under applicable law, in certain cases, to request access to your personal data that we process, to request details about such personal data, including the purposes and potential recipients of this data, to have such personal data rectified or deleted, to restrict or object to the processing of your personal data, as well as to request a copy of your personal data in a standardised format so that it can be provided to another vendor.

Please note that the right for your data to be erased (the "right to be forgotten") that applies in some contexts under the Act is not likely to be applicable to most, if not all, of the personal data you provide to us in relation to an investment, given the specific nature of the purposes for which we use that data, as described above.

If you live or work in an EU Member State, you may also have the right to lodge a complaint with your national or local data protection authority or that of the place of the alleged infringement if you consider that the processing of personal data relating to you carried out by us infringes the Act.

Further rights are covered in the EU Standard Contractual Clauses referenced above.

Where you have provided (and we have relied upon) your consent to process your personal data, you may withdraw your consent at any time by contacting us at the address stated below and (where no other legal basis exists upon which we can process your data) we will apply your preferences going forward. However this will not affect the lawfulness of any processing carried out before you withdrew your consent. In some circumstances, withdrawing your consent or objecting to the processing of your personal data, or requesting its deletion, will mean that you cannot take advantage of certain Services or investment opportunities, and we may need to suspend or terminate your access to the Services or to the Website.

Where we require your personal data to comply with AML or other legal requirements, failure to provide this information means we may not be able to accept an investment.

If you wish to exercise any of your legal rights set out above, please contact privacy@franchisepartners.com or write to The General Counsel, Independent Franchise Partners LLP, Level 1, 10 Portman Square, London W1H 6AZ, UK.

As we must be able to identify the person making the request, we may require you to confirm your request by different means, by contacting us at the address stated above. Due to technological constraints and/or information security considerations, it may be inappropriate to use social media to supply information in response to any request by you for access to information, and so please provide an alternative delivery address for our response.

RETENTION OF INFORMATION

We will retain your personal data for as long as required to perform the Services, to deal with subsequent enquiries or disputes, or longer where additional legal/regulatory obligations require us to do so.

CHANGES TO OUR PRIVACY NOTICE

Any changes we may make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.

CONTACT

As we do not process personal data on a large scale, we are not required to designate a data protection officer. However, questions, comments and requests regarding this privacy notice are welcomed and should be addressed to privacy@franchisepartners.com or The General Counsel, Independent Franchise Partners LLP, Level 1, 10 Portman Square, London W1H 6AZ, UK.

10th May 2018

© Independent Franchise Partners, LLP, All Rights Reserved. Registered in England and Wales, Partnership No. OC344319.

Issued by Independent Franchise Partners, LLP, authorised and regulated by the Financial Conduct Authority in the United Kingdom. Independent Franchise Partners, LLP is registered with the United States Securities and Exchange Commission. The information displayed on this website is for eligible counterparties and professional clients only and is not for retail clients. The services described may not be available to you, or suitable for you. Nothing in this document constitutes investment advice nor does it represent any offer to provide services to buy or sell securities of any kind. Investments in the portfolios managed by Independent Franchise Partners, LLP may fall as well as rise and investors may not be able to recover their invested capital.