Introduction

This Privacy Policy explains how Ardevora Asset Management LLP (“Ardevora”, “our”, “we”, or “us”) collects, uses, shares and otherwise processes your personal data in accordance with applicable data protection laws and the General Data Protection Regulation (“GDPR”) which is effective from the 25th May 2018.

Data collection

We may collect the following data (“Personal Data”) from or about you:

  • Contact data such as name, email address, postal address, phone number;
  • Data about your business such as your role, job title and company name; and
  • Data about your interests in our services or products.

Use of Personal Data

We use this Personal Data for our legitimate business interests including:

  • Performance of a contract: so that we can administer and manage performance of our contract with you.
  • Compliance with our legal and regulatory obligations: such as regulatory and tax reporting and the prevention of fraud, money laundering terrorist financing, bribery and corruption.
  • Pursuit of Ardevora’s legitimate business interests: So we are able to continually improve our offering and delivery of service to you and to send you requested product or service information, for example, our factsheets and Quarterly Reviews.
  • Consent for marketing: As Ardevora has a legitimate business interest in providing you with marketing information regarding our products we do not require consent unless you are an individual. However should you wish not to receive such information you have a right to ask not to
    receive it by contacting us at clientservice@ardevora.com.

Sharing and transfer of data

When using your Personal Data as described above we may share your Personal Data with third parties and other Data Processors for the purposes outlined above. We shall ensure that written contracts are in place with such parties to ensure the safeguarding of Personal Data.

We may share Personal Data with competent authorities (including tax authorities), regulatory bodies, courts or as required or requested by law.

Where such disclosure may involve the transfer of Personal Data to jurisdictions outside of the European Economic Area (EEA), this will be made in accordance with the requirements GDPR. Where such transfers are made to countries that do not have an adequacy decision of the European Commission in place, appropriate safeguards, for example the EU standard contractual clauses, will be put in place.

Individual data rights

You have the right to ask Ardevora whether it processes your Personal Data and to request a copy of it. In certain circumstances you also have the following rights:

  • the right to object to the processing of your Personal Data,
  • the right to rectify your Personal Data,
  • the right to restrict the use of your Personal Data; and
  • the right to port your Personal Data to another Data Controller.

In cases where you have provided consent for the processing of data you have the right to fully or partly withdraw your consent at any time.

You have the right to request to not receive direct marketing at any time.

You also have the right to lodge a complaint with the supervisory authority if you consider that the processing of Personal Data by Ardevora is contrary to GDPR or any applicable data protection laws.

Retention

We will retain your information for the longer of the period we are required to do so by law, as is reasonably necessary for the purpose (for example to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements), or as needed to provide your services.

Use of cookies

Ardevora’s website like most other website uses “cookies”. Cookies are used to collect information about how visitors use our site. They are small files that your web browser places on your computer’s hard drive. Cookies allow us to remember your preferences and help us to improve the site through the use of web analytics. You have the option of setting your browser to reject cookies.

Changes to this Privacy Policy

We may update this Privacy Policy at any time to reflect changes to our information practices and we will make an updated copy of this Privacy Policy available here.

Further information

If you require further information about this Privacy Policy or the way in which Ardevora process your data please contact clientservice@ardevora.com.

You are now leaving the Ardevora website and entering a website not operated by us. Ardevora provides links to external websites that you may find helpful, however the provision of this link does not constitute a recommendation or advice.

Ardevora accepts no responsibility for the accuracy or content of the website that you are about to access, or for any action that you take as a result of accessing this website.

Please ensure that you have read and understand the Terms and Conditions of such third party website and contact the operator of the site should you have any queries.