Privacy notice

Introduction

This is SCIO Capital LLP’s privacy notice.

SCIO Capital LLP respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format, so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are

2. The data we collect about you

3. How is your personal data collected?

4. How we use your personal data

5. Disclosures of your personal data

6. International transfers

7. Data security

8. Data retention

9. Your legal rights

10. Glossary

1. Important information and who we are

Purpose of this privacy notice
This privacy notice aims to give you information on how SCIO Capital LLP collects and processes your personal data through our relationship with you and/or your use of this website, including any data you may provide through this website when you sign up to our investor newsletters and reports or browse through our website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller
SCIO Capital LLP is the controller and responsible for your personal data (collectively referred to as ‘SCIO’, ‘we’, ‘us’ or ‘our’ in this privacy notice).

If you have any questions about this privacy notice, including any requests to exercise your legal rights in respect of your personal data, please contact us using the details set out below.

Contact details
Our full details are:

SCIO Capital LLP
General Data Protection Regulation
Email address: data@scio-capital.com
Postal address: 30 Broadwick Street, London W1F 8JB, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes at any time during your relationship with us.

Website third party links
This website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes home and business address, delivery email address and telephone numbers.
  • Employment Data includes your position, title, employment history and experience, specialism and qualifications.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, email address and first and last names.
  • Usage Data includes information about how you use our website which is anonymised.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Fund Data includes investor reports, monthly and public reports on funds managed by the us.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to end our business relationship and cancel any services you obtain from us, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by contacting and corresponding with us by post, phone, email or otherwise. This includes (but is not limited to) personal data you provide when you:
    • request marketing to be sent to you;
    • subscribe to our service or publications;
    • subscribe for any shares in any funds we manage;
    • are about to enter into a contract with us or there is a contract between us including where you:
      • appoint us to provide you with investment advice or discretionary management services;
      • provide services to us;
      • apply for employment with us;
    • provide information to us about investments;
    • create an account on our website;
    • give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from the following parties:
      • analytics providers such as Google based outside the EU;
    • Identity and Contact, Financial and Transactional Data from service providers relating to your investments such as BNP Paribas Securities Services Luxembourg SCA and MDO Management Company S.A. both based inside the EU.
    • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
    • Identity and Contact Data from publicly available sources such as websites following a Google or other search engine companies, based inside and outside the EU.

    4. How we use your personal data

    We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

    • Where we need to perform the contract, we are about to enter into or have entered into with you.
    • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
    • Where we need to comply with a legal or regulatory obligation.

    Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

    Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message if applicable. You have the right to withdraw consent to marketing at any time by contacting us.

    Purposes for which we will use your personal data
    We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

    Purpose/activity Type of data Lawful basis for processing including basis of legitimate interest
    To deal with you as a potential client of SCIO or a potential investor in a financial product advised or managed on a discretionary basis by SCIO (a) Identity
    (b) Contact
    (c) Financial
    (a) Necessary to comply with a legal obligation (including any regulatory requirements)
    (b) Necessary for our legitimate interests (to define types of customers for our products and services and to grow our business)
    To manage our relationship with you which will include:
    (a) Notifying you about changes to our terms or privacy policy
    (a) Identity
    (b) Contact
    (c) Profile
    (d) Marketing and Communications
    (a) Performance of a contract with you
    (b) Necessary to comply with a legal obligation (including any regulatory requirements)
    (c) Necessary for our legitimate interests (to keep our records updated)
    To provide you with the information you may require to help you decide if you wish to become a client or an investor in a financial product managed or advised by us (a) Identity
    (b) Contact
    (c) Profile
    (d) Marketing and Communications
    (a) Necessary for our legitimate interests (to provide information about the investments we advise and their performance, to develop the financial products we sell and grow our business)
    To provide you with information concerning the performance of your investments and to assist you in the decision of whether you wish to increase your investments or invest in any other financial products including
    (a) Sending you investor reports
    (b) Sending you information from the directors, administrator, registrar or transfer agent of funds you are invested in or will be subscribing to
    (a) Identity
    (b) Contact
    (c) Profile
    (d) Marketing and Communications
    (a) Necessary for our legitimate interests (for running our business, and maintaining investor relationships and help our business grow and ensure smooth relationships with any funds you are invested in and their service providers)
    (b) Necessary to comply with a legal obligation (including any regulatory requirements)
    (c) Performance of a contract with you
    To make suggestions and recommendations to you about financial products that may be of interest to you (a) Identity
    (b) Contact
    (c) Technical
    (d) Usage
    (e) Profile
    (f) Marketing and Communications
    Necessary for our legitimate interests (to develop our business strategy, advise on financial products/services and grow our business)
    To perform contracts with third parties as service providers
    To deal with job applications or work experience or employment
    (a) Identity
    (b) Contact
    (c) Financial
    (a) Performance of a contract with you
    (b) Necessary to comply with a legal obligation (including any regulatory requirements)
    (c) Necessary for our legitimate interests (to obtain and verify identity, background and suitability, develop and maintain and grow our business)
    To deal with job applications or work experience or employment (a) Identity
    (b) Contact
    (c) Employment-related history and qualifications
    (d) Financial
    (a) Necessary for our legitimate interests (to obtain and verify identity, background and suitability, develop and maintain our workforce and ensure our specialisms and grow our business)
    (b) Necessary to comply with a legal obligation (including any regulatory requirements)
    (c) Performance of a contract with you
    To perform our portfolio management services (a) Identity
    (b) Contact
    (c) Profile
    (a) Necessary for our legitimate interests (to obtain and verify identity, background and suitability, undertake, develop and maintain and grow our business)
    (b) Necessary to comply with a legal obligation (including any regulatory requirements)
    To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
    (b) Contact
    (c) Technical
    (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
    (b) Necessary to comply with a legal obligation (including any regulatory requirements)
    To deliver relevant website content (and if applicable, advertisements) to you and measure or understand the effectiveness of the information we are providing to you (a) Identity
    (b) Contact
    (c) Profile
    (d) Usage
    (e) Marketing and Communications
    (f) Technical
    Necessary for our legitimate interests (to inform you as to how the investments you may have invested in are performing, to develop them, to grow our business and to inform our marketing strategy)
    To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
    (b) Usage
    Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

    Marketing
    We strive to provide you with choices regarding certain personal data uses, particularly around marketing. We have established the following personal data control mechanisms:

    Promotion from us
    We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you or where you tell us which financial products you are interested in hearing about. This is how we decide which products, services and offers may be relevant for you.

    You will receive marketing communications from us if you have requested information from us or have appointed us to advise you or manage your investments or if you provided us with your details and, in each case, you have not opted out of receiving that marketing.

    Third party marketing
    We will get your express opt-in consent before we share your personal data with any company outside SCIO Capital LLP for marketing purposes.

    Opting out
    You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

    Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a contract between us or other transactions or while SCIO remains appointed as portfolio managers of any funds where you have an interest or are giving consideration or intending to subscribe for such an interest or where we have a legitimate interest in holding that data.

    Cookies
    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Please note that you cannot disable or refuse cookies if you are logged in, otherwise you are able to disable or refuse cookies but still continue to have full access and functionality to our website. For more information about the cookies we use, please see our Cookie Policy.

    Change of purpose
    We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

    If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

    5. Disclosures of your personal data

    We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

    • External third parties as set out in the Glossary.
    • Specific third parties such as service providers to funds we manage or advise e.g. MDO Management Company S.A. and BNP Paribas Securities Services Luxembourg SCA
    • Third parties who are conducting a due diligence on our business as portfolio managers or to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

    6. International transfers

    Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

    Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

    Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

    7. Data security

    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

    8. Data retention

    How long will you use my personal data for?
    We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

    To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For example, we remove your user information and log in details from our website and MailChimp if you cease to be an investor or client of SCIO or no longer wish to subscribe.

    By law we have to keep basic information about individuals we deal with (including Contact, Identity, Financial and Transaction Data) for a minimum of 6 years after they cease being clients or investors or cease to communicate with us in order to comply with legal and compliance obligations and because we have a legitimate interest in retaining the information.

    In some circumstances you can ask us to delete your data: see Request erasure below for further information.

    In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for data security or research or statistical purposes in which case we may use this information indefinitely without further notice to you.

    9. Your legal rights

    Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click here to find out more about these rights:

    • Request access to your personal data.
    • Request correction of your personal data.
    • Request erasure of your personal data.
    • Object to processing of your personal data.
    • Request restriction of processing your personal data.
    • Request transfer of your personal data.
    • Right to withdraw your consent.

    If you wish to exercise any of the rights set out above, please contact us.

    No fee usually required
    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    What we may need from you
    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

    Time limit to respond
    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

    10. Glossary

    Lawful basis

    • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/products and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
    • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
    • Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

    Third parties
    External third parties

    • Service providers acting as controllers or joint processors based in the EEA and US who provide CRM services (e.g. Pipeline), IT and system administration services, online data storage and data processors (e.g. Microsoft for data storage and MailChimp (which is GDPR compliant) to send emails and newsletters, introduction and advisory services, employment screening service providers and criminal record checks (e.g. HireRight).
    • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers and compliance professionals based in the EEA, who provide consultancy, banking, legal, insurance, accounting and compliance services.
    • Service providers acting as controllers or joint processors to funds managed or advised by SCIO, based in the EEA, including directors, lawyers, auditors, insurers, distribution agents, depositaries, administrators, transfer agents, registrars and domiciliation agents.
    • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
    • Regulators and other authorities acting as processors or joint controllers based in the EEA and US who require reporting of processing activities in certain circumstances.

    Your legal rights

    You have the right to:

    • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
    • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
    • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
    • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
    • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
    • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
    • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

    May 2018

0f5e76950b
/wp-admin/options-general.php?page=emc2-popup-disclaimer/emc2pdc-admin.php
ceb35b15c6
980
1
Accept
Decline
http://www.google.co.uk
1

This website is directed only at persons in the United Kingdom and the European Economic Area that qualify as professional clients or eligible counterparties as defined by the Financial Conduct Authority. The information in this website is not intended for the use of and should not be relied on by any person who would qualify as a retail client. If you are uncertain about whether you qualify as a professional client or as an eligible counterparty, you should seek independent advice from your legal and financial advisers.
In the United States, this website is intended only for qualified purchasers as defined in Section 2(a)(51) of the U.S. Investment Company Act of 1940, as amended.
Persons resident in jurisdictions other than the UK or US should consult their professional advisers to determine whether there are any restrictions, any requirements for regulatory, governmental or other consent, or any other formalities to be observed to enable them to invest in our investment products.
The information on this website is provided for your general information only and does not constitute the giving of any investment advice or an offer to sell or the solicitation of an offer to buy any product or service by us and must not be relied upon at any time or in any circumstances by anyone entering this website in connection with any investment decision. The information on this website does not constitute a financial promotion for the purposes of the Financial Services and Markets Act 2000 and rules and guidance issued from time to time by the Financial Conduct Authority. The information and material on this website is not for distribution and does not constitute an offer to sell or the solicitation of any offer to buy any securities or any service in any jurisdiction.
Any decision to purchase interests in any Fund described on this website must be based solely upon the information contained in the prospectus of the relevant Fund and subscriptions will only be received and shares issued on the basis of the current prospectus of the relevant Fund; you are referred to this document if further information is required.
No information provided on this website in relation to any product or service should be construed as investment or other advice to you on the suitability or otherwise of that product or service for any person, such suitability depending on all the circumstances of the person concerned and all persons should consult with their own financial and other appropriate professional advisers as to all matters concerning any potential investment or any interest in any investment.
By clicking the ‘ACCEPT’ button below, entering this website and continuing to use it, you represent and confirm that you are a professional client or eligible counterparty as defined by the Financial Conduct Authority, or in the US are a qualified purchaser as defined in Section 2(a)(51) of the U.S. Investment Company Act of 1940, as amended , or that otherwise there are no restrictions in place that prevent you from accessing this website and/or considering any investment products or services detailed therein, and that you agree to be fully bound by the terms and conditions of this Legal Notice and our full terms and conditions of use of our website which you should read before using this website. Please note that you may be required to provide documentary evidence in support of your identity and categorisation as a professional client or eligible counterparty or qualified purchaser where we are considering making a financial promotion to you or we are considering entering into a contract with you as an investor or you are considering making an investment.

SCIO Capital LLP is authorised and regulated by the Financial Conduct Authority.

References to ‘we’, ‘us’, ‘our’, ‘firm’, ‘SCIO’ or ‘SCIO Capital’ mean SCIO Capital LLP. SCIO®, SCIO Capital® and the SCIO logo® are registered trade-marks of SCIO CAPITAL LLP® in the United Kingdom. All rights reserved.

Accept Decline