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Privacy notice

This notice describes how The European Investment Trust plc (the “Company”, “we”, “us” or “our”), as “data controller”, may collect, use and process your personal information in accordance with applicable data protection legislation. This notice also sets out the rights available to you in connection with the Company’s use of your personal information.

Whose personal information does this privacy notice apply to?

This notice describes the Company’s practices when collecting and processing personal information of individuals who:

  • hold shares in the Company (“shareholders”) or who are connected with, or employed by, a shareholder in the Company such as directors, officers, employees and/or beneficial owners of the investor;
  • have been appointed as a director, officer, employee, agent and/or service provider of the Company or who are connected with, or employed by, an agent or service provider to the Company;
  • visit the Company’s website at www.eitplc.com; or
  • who disclose personal information during the course of requesting information from, or otherwise communicating with, the Company either directly or from any director, officer, employee, agent or service provider of the Company.

What personal information do we collect?

The Company may collect and process the following categories of personal information:

  • Contact details such as name, title, profession, job title, position, address (personal / business), telephone number (personal / business) and email address (personal / business).
  • Identification details such as name, title, sex, date of birth, place of birth, nationality, address (personal / business), telephone number (personal / business), email address (personal / business), national insurance number, tax identification number, passport information, driving license, photograph and signature.
  • Information which you provide to us when requesting information from us in person, via email, via telephone or via the Company’s website.
  • Communications with the Company, and any personal information provided therein, including emails, telephone calls and letters. Please note that for regulatory purposes, the Company and/or its service providers may be required to retain a record of certain communications, particularly email and telephone communications, in their entirety for periods of up to 10 years.
  • To the extent that you access the Company’s website, the Company may collect certain information from you via the website, including: (i) information that you provide by filling in forms on our website such as name, title, profession, job title, position, address, telephone number and email address; (ii) information about how you use our website such as device information (e.g. device brand and model, screen dimensions), unique identification numbers (e.g. IP address and device ID), and session information(e.g. URL, browser type, pages visited, search terms entered, date/time of access); (iii) information captured by the cookies on our website (please refer to the Cookies Policy available via our website for further information).

It is our policy to collect only such personal information from business contacts as is necessary in order to provide our services, to ensure proper administration of our business including our website, or to meet legal, regulatory and compliance requirements.

Please note that if any of the personal information you provide to us does not relate to you (e.g. information about your colleagues or representatives), you should ensure that you have obtained the necessary consent in order to disclose such information.

How do we collect personal information?

Personal information may be collected by the Company directly, or indirectly by service providers acting on behalf of the Company. Such service providers may include Computershare Investor Services plc (the “Registrar”), Edinburgh Partners AIFM Limited (the “AIFM), Edinburgh Partners Limited (the “Investment Manager”), the company secretary or other third party providers appointed by the Company (“Service Providers”).

Personal information is typically collected in the following ways:

  • As part of the information you, or your appointed representative, provide to the Company and/or the Registrar when you become a shareholder in the Company.
  • As part of the information provided to theCompany and/or the Registrar by an entity you are connected with, or employed by, when it is applying to become a shareholder in the Company.
  • As part of the information you, or your appointed representative, provide to the Company and/or its Service Provider(s) when you are appointed to act as director, officer, employee, agent and/or service provider to the Company. 
  • As part of the information provided to the Company and/or its Service Provider(s) by an entity you are connected with, or employed by, when it is appointed to act as agent and/or service provider to the Company. 
  • As part of the information provided to theCompany and/or its Service Provider(s) by third parties (e.g. fraud prevention agencies) when verifying your identity and when carrying out anti money laundering checks. Such information may include details about any criminal convictions and allegations, as well as details of your status as a politically exposed person.
  • During any communications you may have with Company and/or its Service Provider including emails, telephone calls and letters.
  • As part of the information you, or your appointed representative, provide to the Company and/or its Service Provider(s)when you subscribe to email newsletters or other periodic communications, including information you provide when you respond to a survey or marketing communication.
  • As part of the information that you provide and/or which is collected via our website, including information captured by the cookies on our website (please refer to the Cookies Policy available via our website for further information).

Please note that our website may contain links to websites or content operated and maintained by third parties. Please consult the privacy policies of those third parties, which should be available on their respective websites, for more information on how they process your data. We cannot control and accept no liability for how those third parties process your data.

What do we do with your personal information?

The Company, or Service Providers acting on behalf of the Company, may use the personal information collected from you for the purposes listed below:

Shareholders and Prospective Shareholders in the Company:

  • To verify the identity of shareholders in the Company for anti-money laundering purposes and to meet our regulatory obligations in the prevention of fraud, terrorist financing, bribery and corruption, and to ensure that we do not receive investment from persons who may be subject to economic or trade sanctions.
  • To store your details on the shareholder register for the Company and to maintain the register on an ongoing basis.
  • To administer your investment in the Company in accordance with your instructions and to communicate with you in relation to your investment in the Company.
  • To invite you to events hosted by the Company unless you have indicated to us that you do not wish to receive such information.
  • To protect your interests and your data or, where applicable and only to the extent that your interests are not infringed by such use, the interests of the Company, the Registrar, the AIFM, the Investment Manager or other service providers to the Company.
  • To comply with the Company’s legal and regulatory obligations, including to retain certain records and to look into any complaints you may have in connection with your investment in the Company.

Directors, Officers, Employees, Agents and/or Service Providers to the Company:

  • To verify the identity of directors, officers, employees, agents and/or Service Providers to the Company for anti-money laundering purposes and to meet our regulatory obligations in the prevention of fraud, terrorist financing, bribery and corruption, and to ensure that we do not receive services from persons who may be subject to economic or trade sanctions.
  • To store director details on the register of directors for the Company and to maintain the register on an ongoing basis.
  • To obtain services and support from you and to communicate with you in relation to the services you provide to the Company.
  • To arrange for and facilitate payment of salaries, reimbursement for expenses and/or payment of invoices.
  • To invite you to events hosted by the Company unless you have indicated to us that you do not wish to receive such information.
  • To protect your interests and your data or, where applicable and only to the extent that your interests are not infringed by such use, the interests of the Company, theRegistrar, the AIFM, the Investment Manager or other Service Providers to the Company.
  • To comply with the Company’s legal and regulatory obligations, including to retain certain records and to look into any complaints you may have in connection with your investment in the Company.

The Company, or Service Providers acting on behalf of the Company, will only use your personal information for the purposes for which it was collected, unless the Company or the relevant Service Provider reasonably considers that it needs to use it for another reason and that reason is compatible with the original purpose. If the Company, or Service Providers acting on behalf of the Company, need to use your personal information for an unrelated purpose, the Company or the relevant Service Provider will notify you and will explain the legal basis which allows it to do so.

What are our grounds for using your personal information?

The Company, or Service Providers acting on behalf of the Company, may use your personal information pursuant to the following legal bases:

  • To comply with the Company’s or the relevant Service Provider’s legal and regulatory obligations.
  • To perform the Company’s obligations under a contract with you, with an entity you are connected with, or employed by, or with the Service Providers to the Company.
  • To pursue our legitimate business interests where we consider that our interests are not overridden by your interests or rights which require protection of your personal information.

Who do we share your personal information with?

The Company, or Service Providers acting on behalf of the Company, may need to share your personal information with:

  • Entities within the AIFM and Investment Manager’s group of companies, including without limitation, Edinburgh Partners North America Inc. and the Investment Manager’s parent company, Franklin Resources Inc.
  • Financial intermediaries and other professional third parties, such as administrators, custodians, auditors, lawyers and other Service Providers, with whom the Company or a Service Provider has a business relationship.
  • Competent authorities such as tax authorities, courts, regulators and security or police authorities where required or requested by law or where we consider it necessary.

Transfer of personal information outside the European Union (“EU”)

In accordance with the above, the personal information we collect from you may be transferred to, and stored, outside the EU and may also be processed by individuals operating outside the EEA who are employed by the Company or its Service Providers.

Countries outside the EU may have a lower standard of protection for personal information than the standard required by EU data protection laws. If the Company needs to transfer your data outside the EU, it will take steps to ensure your personal information is protected and safeguarded once it leaves the EU. This may include implementation of EU Data Protection Model Clauses approved by the European Commission with the recipient of personal information. More information on how we protect your personal information when it is transferred outside the EU (including a copy of the relevant EU Data Protection Model Clauses) is available upon request to the contact details provided below.

How long do we retain personal information?

The Company, or Service Providers acting on behalf of the Company,  will only retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying the Company’s legal and regulatory obligations.

The Company and its Service Providers are subject to a number of legal and regulatory obligations, in the UK and overseas, which require them to keep records for certain specified periods. Although such periods will differ from country to country, in the majority of instances the Company will keep your personal information for the duration of your relationship with the Company and then for periods of up to 10 years following the end of our relationship, after which time it will be destroyed from its primary location. System back-ups and emailing archiving maybe retained for longer periods.

How do we keep your personal information secure?

The Company is committed to taking all reasonable and appropriate steps to protect the personal information that the Company, or Service Providers on behalf of the Company, hold from misuse, loss, or unauthorised access. The Company seeks to achieve this by having in place a range of contractual standards (relating to, amongst other matters, compliance with applicable data protection legislation and appropriate technical and organisational measures) in agreements with its Service Providers. These include mechanisms to facilitate the exercising of your rights under data protection legislation and measures to deal with any suspected data breach.

What are your rights in connection with your personal information?

You have the following rights, under certain circumstances, in relation to your personal information:

  • Right to access personal information: You have the right to obtain confirmation that your data is being processed and to access to all of the personal information stored by the Company.
  • Right to rectify personal information: You have the right to request that inaccurate or incomplete personal information relating to you is rectified.
  • Right to request that personal information is erased: You have the right to request that personal information is erased if it is no longer needed for its original purpose. Please note that there may be circumstances where you ask us to erase your personal information but we are legally required and/or entitled to retain it.
  • Right to restrict processing: You have the right to request that personal information is processed for only limited purposes or that processing is suspended if you want us to establish the accuracy or reason for processing.
  • Right to data portability: In certain circumstances in relation to personal information which you have provided to us, you are entitled to receive personal information in a structured, commonly used and machine-readable format and/or requesting that we transmit that information to a third party where this is technically feasible.
  • Right to object: Where personal information is processed under the legal basis of public interest or legitimate interests of the controller individuals have the right to object to processing.
  • Right to withdraw consent: In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

You can exercise your rights by contacting the Company at: enquiries@edpam.com

Where the Company receives a request to exercise one of these rights, it shall provide information on the action it takes without undue delay and in any event within one month of receipt of the request. The Company may ask for additional information to verify your identity before carrying out a request. Where requests are manifestly unfounded or excessive in nature, the Company may charge a reasonable fee or to refuse to carry out the request. Where we do not carry out a request, we will inform you without delay and within one month of receipt of the request, providing our reasons for not taking the action requested.

If you are not satisfied with our response to your request, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the supervisory authority for data protection matters in the United Kingdom or, as may be the case, to any other competent supervisory authority of an EU member state.

Changes to this notice

The Company keeps this notice under review and may update it from time to time. Any changes to this notice will be posted on the Company’s website and, where appropriate, notified to you by way of separate communication. We recommend you regularly review the Company’s website to ensure that you are aware of our information practices and any updates to this notice.

Further information

If you have any concerns or require any further information, please do not hesitate to contact enquiries@edpam.com