Ardevora Asset Management LLP (“Ardevora”) is committed to protecting your personal information and your privacy.  This Privacy Policy explains how Ardevora collects, processes and looks after your personal data in accordance with applicable data protection legislation.

We may collect and process the following personal data from or about you:

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

We process your personal data for our legitimate business interests, our legal and/or regulatory obligations and/or contractual obligations including:

• Pursuit of Ardevora’s legitimate business interests so we are able to provide and promote our products and services and continually improve our offering and delivery of our service to you and to send you requested product or service information, for example, our factsheets and quarterly reviews.
• Managing our business: managing, administrating and protecting our business including maintaining accounts and records, administering and managing our business relationships and managing and supporting our employees.
• Performance of contracts so that we can administer, manage and perform our contracts.
• Compliance with our legal and regulatory obligations: such as tax reporting and regulatory obligations including but not limited to the preventing fraud, money laundering, terrorist financing, bribery and corruption.
• To send you requested product or service information and to market to you, for example by sending factsheets to you or hosting events.

Generally, we do not rely on consent as a legal basis for processing personal data.   Please note that you have the right at any time to withdraw consent for marketing or the right to ask not to receive marketing material by contacting us at clientservice@ardevora.com.

When processing your personal data, we may share your personal data with third parties and other data processors for the purposes of carrying on our legitimate business interests or complying with legal, regulatory or contractual obligations.  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 but not limited to tax authorities, regulatory bodies, courts or as required or requested by law.

Wherever possible we do not transfer your personal data outside the UK or European Economic Area (EEA). In certain circumstances, we may use third party service providers based outside the UK or EEA to process your personal data.  Where this occurs, we will ensure a similar degree of protection is provided to your personal data by transferring it to countries that have been deemed to provide an adequate level of protection or ensure there is an agreement in place with any processor to ensure suitable safeguards are in place including that any personal data will only be processed for the purposes of that agreement and on our instruction.

We take precautions to ensure your data is not subject to unauthorised access. Some of the steps we take include limiting access to systems and email via increased security measures; ensuring our employees, agents, contractors and other third parties are aware of their responsibilities towards protecting personal data and are subject to a duty of confidentiality.

Under data protection law, you have the following rights:

• the right of access – you have the right to ask us for copies of your personal information.
• the right to rectification – you have he right to ask us to rectify personal information you think Is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• the right to erasure – you have the right to ask us to erase your personal information in certain circumstances.
• the right to restrict processing – you have the right to ask us to restrict the processing of your personal information in certain circumstances.
• the right to data portability – you have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

In cases where you have provided consent for the processing of personal data you have the right to fully or partly withdraw your consent at any time by contacting us at clientservice@ardevora.com.

If you have any concerns about our use of your personal data, you can raise your concern to us at clientservice@ardevora.com.

You can also complain to the UK supervisory authority for data protection issues, the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your personal data.  Further details can be found at the ICO’s website: www.ico.org.uk.

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.