Privacy Policy

Who Are We?
Seilern Investment Management Limited (“SIM”) is committed to maintaining, protecting and respecting your privacy. You can visit our website without telling us who you are or revealing any information about yourself. However, if you do give us any personal information about yourself or others, we promise to treat it securely, fairly and lawfully.

The Data Controller
For the purpose of the Data Protection Act 1998 (“the Act”), the data controller of the personal data you submit to this site is SIM. We are responsible for, and control the processing of, your personal information.  Further information can be obtained by contacting us. (See the “How to Contact Us” section below.)

The Data Subject

What Our Policy Covers
This Privacy Policy Statement (the Privacy Policy) covers without limitation, the home page, splash page and all other pages under the domain name WWW.SEILERNINVEST.COM (“our Site”) and all content contained on those pages. This Privacy Policy (together with our Terms of Use and 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 and used by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. If you do not agree with the terms of this Privacy Policy, please do not use our Site, WWW.SEILERNINVEST.COM.

Information We May Collect From You

Information you give us
You may give us information about you by filling in forms on our site or forms that we have given to you to fill in or by corresponding with us via phone, email, facsimile or otherwise. This includes information you provide when you register to use our Site, log in to a service, subscribe to a service and when you report an issue with our Site. The information you give us may include:

  • Your name;
  • Your email address;
  • Your phone number;
  • Your date of birth;
  • Your client number or unique investor identification number;
  • Your gender;
  • Your financial information;
  • The information about your investment strategies and objectives;
  • Your credit card information;
  • Your medical information; and
  • Any further personal information required as part of a product application or which you share through our Site.

Information we collect about you

Each time you visit our Site we may automatically collect the following information:

  • Technical information including the internet protocol (“IP”) address used to connect your computer to the internet, your log-in information, browser type and version, browser plug-in types and versions, time zone setting, operating system and platform; and
  • Information about your visit, including the Uniform Resource Locators (“URL”) clickstream to, through and from our Site (including date and time); items you searched for; page response times; download errors, length of time spent on pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page and any phone number used to call us.

Information we receive from other sources

We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, and criminal and civil records check agencies). We receive personal data from these third parties from time to time. We may combine this information with information you give to us and information we collect about you. We may use this information and combined information for the purposes set out above (depending on the types of information we receive).

Monitoring and recording communications

We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of  quality assurance, training, fraud prevention and compliance with our obligations under applicable legislation.

Personal information about other individuals

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

  • Give consent on his/her behalf to the processing of his/her personal data;
  • Receive on his/her behalf any data protection notices; and
  • Give consent to the processing of his/her personal data which may include all of the information listed above.

Cookies

Our Site uses cookies to distinguish you from other users of our Site and to make the Site work more efficiently. A “cookie” is a small file of letters and numbers that a website can store on the browser or hard drive of your computer. Some cookies are deleted when you close down your browser. These are known as “session cookies”. Others remain on your device until they expire or you delete them from your cache. These are known as “persistent cookies” and enable us to remember things about you as a returning visitor.

For further information about how to control and disable cookies in your browser please visit: WWW.ABOUTCOOKIES.ORG.UK.

Alternatively, you can search the internet for other independent information on cookies. Cookies may be required to allow you to access and participate in certain areas of our Site. The cookies we store on your computer do not contain any personally identifiable information. There are different types of cookies used for different purposes. The cookies our Site uses are listed below under the cookie categories recommended by the International Chamber of Commerce.

  • Strictly necessary cookies
    These are cookies that are required for the operation of our Site. They include, for example, cookies that may enable you to log into secure areas of our Site or to fulfil an action requested by you when you are logged on. Without these cookies we are unable to provide some products or services that you might request. Other strictly necessary cookies keep our Site secure. Even if you say no to cookies on this Site, we will continue to use these essential cookies.
  • Performance or analytical cookies
    These cookies allow us to improve our Site by recognising and counting the number of visitors to our Site and to see how visitors move around our Site while they are using it. These analytics will help us improve the way our Site works, for example by letting us know how we need to adapt our Site to ensure users can easily find what they are looking for. If you disable these cookies you will still be able to use most of our online services, but some might not work as you expect if you do not allow us to store and access cookies on your device.

Cookies We Use

Function Cookie Name(s) Further information
SIM Website: Www.Seilerninvest.Com
Keeping an anonymous record of how visitors use the website __utma
__utmb
__utmc
__utmz
The Google Analytics software is described at:
Http://Www.Google.Co.Uk/Intl/En/Analytics/Privacyoverview.Html

To opt out of being tracked by Google Analytics across all websites, visit:
Http://Tools.Google.Com/Dlpage/Gaoptout

Allowing the server to identify whether the browser is using Javascript has_js Identifies whether a browser has Javascript enabled to display Javascript elements or go to non-Javascript.
Remembering Google Analytics choice gainc Determines whether the user wants Google Analytics cookie to run.
Allowing the server to maintain a session for the duration of a user’s visit to the Seilern Invest website PHPSESSID This cookie is essential for functions such as forms that depend on visiting pages or taking actions in a particular sequence. It will be deleted when you close your browser, or after a period of inactivity. More information on sessions is available at: Http://Www.Php.Net/

Managing and blocking cookies

If you want to remove any cookies already set, you can do so from your browser. You can find out how to do this by going to the help menu in your browser or by visiting www.aboutcookies.org.uk or by searching the internet for other independent information on cookies. You can also block cookies from your browser. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site.

How We Use Your Information

We use information which you have given to us and we have collected and hold about you in the following ways:

  • To carry out our obligations arising from any contracts entered into between you and the SIM and to provide you with the information, products and services that you request from us;
  • To comply with our legal obligations to carry out identity and anti-money laundering checks;
  • To provide you with information about other products and services that we offer that are similar to those that you have already purchased or enquired about;
  • To provide you, or permit selected third parties to provide you with information about products or services we feel may interest you;
  • To notify you about changes to our service;
  • To improve our Site to ensure that content from our Site is presented in the most effective manner for you and for your computer;
  • To administer our Site and for internal operations including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • To allow you to participate in interactive features of our service, when you choose to do so;
  • As part of our efforts to keep our Site safe and secure; and
  • To measure or understand the effectiveness of marketing communications, advertising and or financial promotions we serve to you and others, and to deliver relevant marketing communications, advertising and or financial promotions to you.

Marketing

We would like to send you information by post, email, telephone, text message (“SMS”) or automated calls about our products and services which may be of interest to you. We will only ask whether you would like us to send you marketing communications when you tick the relevant boxes when you signed up with us or filled out a form on our Site.

If you have consented to such receive marketing communications from us, you can opt out at any time.  See the “Your Rights” section below for further information.

Identity Checks And Anti-Money Laundering Monitoring

We may do an identity and/or credit check on you:

  • So that we can verify your identity;
  • Make credit decisions about you and members of your household; and
  • To prevent and detect fraud and money laundering.

Our search will be recorded on the files of the credit reference agency.

We may also disclose information about how you conduct your account to credit reference agencies and your information may be linked to records relating to other people living at the same address with whom you are financially linked.

Other credit businesses may use your information to:

  • make credit decisions about you and the people with whom you are financially associated
  • trace debtors, and
  • prevent and detect fraud and money laundering

If you provide false or inaccurate information to us and we suspect fraud, we will record this.

If you want to see your identity check and or credit file, please contact us using the contact information below and we will provide you with the details of the agencies which we use so that you can contact them directly to obtain the relevant information.

Disclosure Of Your Information

We may share your personal information with:

  • Other companies affiliated with us;
  • Our agents and service providers (including custodians);
  • Credit reference agents – see “Credit Checking” section above;
  • Our business partners in accordance with the “Marketing and opting out” section above;
    • Suppliers and sub-contractors for the performance of any contract we enter into with them or you;
    • Analytics and search engine providers that assist us in the improvement and optimisation of our Site;
  • In the event that we buy or sell any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • Law enforcement agencies in connection with any investigation to help prevent unlawful activity;
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, where requested by regulatory agencies, or in order to enforce or apply our Terms of Use and other agreements or to protect the rights, property or safety of SIM. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
  • Financial institutions and other similar organisations that we deal with in the course of the services we offer; and
  • Auditors, accountants, legal counsel or contractors or other advisers auditing, assisting with or advising on any of our business purposes, in any jurisdiction where we operate.

When we share your information with third parties they will process your information either as a data controller or as our data processor and this will depend on the purpose of our sharing the personal data. We will only share your personal data in compliance with the applicable data protection legislation.

A list of our selected third parties with whom we may share your information is available by contacting us at INVESTORRELATIONS@SEILERNINVEST.COM.

Where We Store Your Personal Data

All information you provide to us is stored on our secure servers located in our London office, with backup outsourced to our IT provider, who utilise Arcserve UDP to back up on site servers, using a local storage repository and an offsite replica. Where you have a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential.

Transfers Of Your Information Out Of The EEA

When you signed up for our Services and entered into the agreement with us in respect of those Services you agreed that we may transfer your personal data to countries located outside the European Economic Area (“EEA”), for the purposes as set out in your agreement with us. Rest assured that we will always ensure any transfer is subject to appropriate security measures to safeguard your personal data including entering into European Commission (“EC”) approved contracts that that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.

Details of any third parties located outside of the EEA to which your personal data is transferred will be communicated to you in accordance with the terms of the agreement with you. We do not transfer your information outside of the EEA other than in accordance with an agreement you have with us.

Security

What we do

We will use technical and organisational measures to safeguard your personal data, for example:

  • Access to your account is controlled by a password and user name that are unique to you;
  • We store your personal data on secure servers; and
  • Payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology).

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet.

If you have any particular concerns about your information, please contact us (see “How to Contact Us” section below).

What you can do

You are responsible for keeping your password, user name and other log-in identity details secure and confidential. If you want detailed information on how to protect your 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.

Other Websites

Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that 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

You have:

  • The right to ask us to stop contacting you with direct marketing
    Even if you have accepted the processing of your personal data for marketing communication purposes (by ticking the relevant box), you have the right to ask us to stop processing your personal data for such purposes.Let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone).You can exercise this right at any time by contacting us at INVESTORRELATIONS@SEILERNINVEST.COM.
  • The right to request a copy of your information
    You can request a copy of your information which we hold (this is known as a “Subject Access Request” or “SAR”).If you would like a copy of some or all of your information, please contact us at INVESTORRELATIONS@SEILERNINVEST.COM; and let us know the specific information you want a copy of, including any account or reference numbers, if you have them.Any subject access request may be subject to a reasonable fee to cover the cost of providing you with details of the information we hold about you.
  • The right to correct any mistakes in your information
    You can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please contact us at INVESTORRELATIONS@SEILERNINVEST.COM; and let us know the specific information that is incorrect and the specific information you want it replaced with.
  • The right to request we cease processing your information
    You may request that we cease processing your personal data.  If you make such a request, we shall retain only the amount of personal data pertaining you that is necessary to ensure that no further processing of your personal data takes place.

The right to request deletion of your information

You can ask us to erase all your personal data (also known as the “right to be forgotten”) in the following circumstances:

  • It is no longer necessary for SIM to hold that Personal Data with respect to the purpose for which it was originally collected or processed;
  • You wish to withdraw your consent to us holding and processing your personal data;
  • You object to us holding and processing your personal data (and there is no overriding legitimate interest to allow us to continue doing so);
  • The personal data has been processed unlawfully; or
  • The personal data needs to be erased in order for us to comply with a particular legal obligation.

Unless we have reasonable grounds to refuse to erase your personal data, all requests for erasure shall be complied with.

Changes To Our Privacy Policy

We may change this Privacy Policy from time to time. Any changes to our Privacy Policy in the future will be posted on our Site and where appropriate notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.

How To Contact Us

If you have any questions about this Privacy Policy or the information we hold about you please send an email to INVESTORRELATIONS@SEILERNINVEST.COM or write to us at the Data Protection Officer, Seilern Investment Management Limited, 43 Portland Place, London, W1B 1QH; or call us on +44 (0) 20 7494 1996.