- our shareholders;
- our beneficial owners;
- our directors;
- staff located at our affiliates and service providers;
- third party supplier contacts; and
- any other natural persons about whom we may process personal data.
- The Company’s website may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that the Company does not accept any responsibility or liability for their policies or processing of your personal data. Please check these policies before you submit any personal data to such third party websites.
Personal data that the Company collects
- The Company only collects the personal data that we determine is required for the purposes set out at Section 4: Purposes for which we use your personal data, below. We may collect:
- Information you provide to the Company ►ersonal data that you provide to the Company, such as when contacting us using the email or physical address(es) listed on our website, including your name, email address, bank account details (where required) and other contact details;
- In relation to shareholders only, information relating to your shareholding ► share register services are outsourced to registrars, which hold the majority of this personal data. We periodically receive reports listing our shareholders and details of these shareholdings;
- KYC and due diligence information ► information obtained by third party screening providers and publicly available information and background screening, where required by law or applicable financial regulations;
- Our correspondence ► if you contact us, we will typically keep a record of that correspondence. This may include telephone calls in relation to management of shareholdings, and you will be informed that any call is being recorded. If you object to this, you can end the call at that point and utilise an alternative method of communication should you prefer;
- Device Information ► such as information about your operating system, browser, software applications, geolocation, security status and other device information in order to improve your experience, to protect against fraud and manage risk;
- Marketing and communications information ► including your preferences for receiving marketing from us and our third parties and your communication preferences; and
- Website and communication usage ► details of your visits to the Company’s website and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.
Purposes for which we use your personal data
- To understand who our shareholders/beneficial owners are and undertake reporting and analysis ► Our corporate records contain information in respect of shareholders/beneficial owners including names and addresses, account designations and the amount of shares held. We share this information with our authorised brokers to undertake reporting analysis.
Lawful bases: legitimate interests (to understand our shareholder demographic and undertake reporting and analysis); legal obligations
- To maintain our share register ► we may process your personal data to set-up, maintain and update the register of our members, to prepare and issue share or stock certificates, to receive and deal with transfers, probates, powers of attorney, changes of address, and all similar documents normally needed to maintain the register, to deal with telephone enquiries for shareholders, to maintain and update dividend and interest payment instructions and account details, to make dividend payments, to deliver Annual Report and Accounts and Interim Reports, to assist with proxy voting and to enable you to use online platforms which enable you to vote by proxy and access and manager your shareholdings.
Lawful bases: legitimate interests (to manage your shareholding) unless we can rely on contract performance; legal obligations
- For administrative purposes ►we may process your personal data to arrange for payment of directors fees, deal with queries, pay dividends, organise and minute all meetings, liaise with directors regarding meetings and board packs, assist with the arrangement of travel, accommodation and directors’ requirements for board and committee meetings, maintain and keep a register of declared interests, advising directors and monitoring directors’ interests and conflicts.
Lawful bases: legitimate interests (to make corporate decisions and ensure that our directors are engaged consulted appropriately); legal obligations
- To comply with legal or regulatory requirements including to conduct KYC, AML and anti-fraud checks► we may process your personal data to comply with our regulatory requirements (for example, to comply with KYC, anti-money laundering or insider dealing requirements) or dialogue with our regulators or to defend or prosecute claims which may include disclosing your personal data to third parties, the court service, fraud agencies and/or regulators or law enforcement agencies. Such compliance requirements may involve background checks including screening against PEP, sanctions and/or anti-money-laundering databases on a periodic basis.
It is possible that special categories of personal data (e.g. political opinions, religious beliefs, ethnicity) and/or data relating to criminal convictions or offences may be received as a result of these background checks where such information has been made public or is relevant to the necessary checks.
Lawful bases: legal obligations; legitimate interests (to cooperate with law enforcement and regulatory authorities). Where special categories of personal data or data relating to criminal convictions or offences is processed, we will rely on substantial public interest (prevention/detection of fraud or crime) or legal claims, as applicable (or very rarely, explicit consent)
- To monitor certain activities ► to monitor queries, complaints and transactions to ensure service quality, compliance with procedures and to combat fraud. As part of this, we may keep a record of communications, including recordings of telephone conversations
Lawful bases: legal obligations; legitimate interests (to ensure that the quality and legality of our services). Where special categories of personal data or data relating to criminal convictions or offences is processed, we will rely on substantial public interest (prevention/detection of fraud or crime) or legal claims, as applicable (or very rarely, explicit consent)
- To inform you of changes ► to notify you about changes to the Company’s services and products;
Lawful bases: legitimate interests (to notify you about changes to the Company’s services)
- To provide you with marketing materials ► to provide you with updates and offers, where you have chosen to receive these. We may also use your information for marketing our own products and services to you by post, email, SMS, and phone and, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out in Section 10: Contact us
Lawful bases: consent, legitimate interest where are not required to rely on consent (to keep you updated with news in relation to our products and services)
- To re-organize or make changes to the Company’s business ► in the event that the Company (i) is subject to negotiations for the sale of the Company’s business or part thereof to a third party, (ii) is sold to a third party or (iii) undergoes a re-organization, we may need to transfer some or all of your personal data to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. The Company may also need to transfer your personal data to that re-organised entity or third party after the sale or re-organisation for them to use for the same purposes as set out in this policy;
Lawful bases: legitimate interests (in order to allow the Company to change its business)
- To communicate effectively with you and conduct the Company’s business ► to conduct the Company’s business, including to respond to your queries, to otherwise communicate with you (and keep a record of that communication, including recordings of telephone conversations relating to your shareholding), or to carry out our obligations arising from any agreements entered into between you and the Company.
Lawful bases: legitimate interests (to enable the Company to perform its obligations and provide its services to you and for the purposes of maintaining service standards) unless we can rely on contract performance; legal obligations.
Sharing your personal data (and transfers outside of the EEA/UK)
- Sharing outside of the Company: personal data may be provided to third parties, including our affiliates, brokers, share registrars, registrars, administrators, fund managers, receiving agents, alternative investment fund managers, secretariat service providers, legal advisors, auditors, financial advisors, portfolio advisors, other advisors, regulatory authorities or other self-regulatory organisations (when required to satisfy the legal or regulatory requirements of governments), regulatory or law enforcement authorities (located anywhere in the world), or to comply with a court order or for the protection of our assets.
- Where the Company transfers personal data from inside the EEA/UK to outside the EEA/UK, the Company may be required to take specific additional measures to safeguard the relevant personal data. Certain countries outside the EEA/UK have been approved by the European Commission/Information Commissioner’s Office as providing essentially equivalent protections to EEA/UK data protection laws and therefore no additional safeguards are required to export personal data to these jurisdictions. In countries which have not had these approvals (see the full list here http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm), the Company will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses, or other legal grounds permitted by applicable legal requirements.
- Please contact us at the email address provided in Section 10: Contact us below if you would like to see a copy of the specific safeguards applied to any export of your personal data.
Retention of your personal data
- The Company’s retention periods for personal data are based on business needs and legal requirements. The Company retains your personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, the Company may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When personal data is no longer needed, the Company either irreversibly anonymises the data (and the Company may further retain and use the anonymised information) or securely destroys the data.
Safeguarding your personal data
- No data transmission over the Internet or website can be guaranteed to be secure from intrusion. The Company uses commercial reasonable physical, electronic and procedural safeguards to protect against unauthorised use, access, modification, destruction, disclosure, loss or theft of your personal data in the Company’s custody or control, in accordance with applicable data protection legislative requirements
- The Company has agreements and controls in place with third party service providers requiring that any information the Company provides to them must be safeguarded and used only for the purpose of providing the service the Company has requested the company to perform.
- All information you provide to the Company is stored on our or our subcontractors’ secure servers and accessed and used subject to the Company’s security policies and standards. You are responsible for complying with any other security procedures of which you have been notified by the Company.
- If you have any questions in relation to the Company’s use of your personal data, you should first contact the Company at the email address provided in Section 10: Contact us Under certain conditions, you may have the right to require the Company to:
- provide you with further details on the use the Company makes of your information;
- provide you with a copy of information that you have provided to the Company;
- update any inaccuracies in the personal data the Company or its service providers hold. In order to assist us with this, please contact the Company at the email address provided in Section 10: Contact us where your details have changed/where you consider your personal data should be updated;
- delete any personal data that the Company no longer has a lawful basis to use;
- transfer your personal data in a structured, commonly used, machine-readable format to an applicable third party in certain circumstances.
You also have the right to:
- where processing is based on consent, to withdraw your consent so that the Company stops that particular processing
- object to any processing based on the legitimate interests ground unless the Company’s reasons for undertaking that processing outweigh any prejudice to your data protection rights
- object to receiving marketing communications from the Company by contacting the Company as per Section 10: Contact us; and
- restrict how the Company uses your information while a complaint is being investigated
- Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and the Company’s interests (e.g. the maintenance of legal privilege). If you exercise any of these rights, the Company will check your entitlement and respond in most cases within a month
- If you are not satisfied with the Company’s use of your personal data or the Company’s response to any exercise of these rights you have the right to complain to the UK’s data protection regulation, the Information Commissioner’s Office. The contact details are below:
Information Commissioner's Office
Telephone: 0303 123 1113
- If you have any questions or concerns about our privacy practices, the privacy of your personal data or you want to change your privacy preferences, please contact our administrator and company secretary in the first instance as follows:
PraxisIFM Fund Services (UK) Limited
85 Queen Victoria Street
London EC4V 4
Contact: Company Secretary
Telephone: 0204 513 9260
- If after contacting the Company you do not feel that the Company has adequately addressed your concerns, you may contact your local data protection regulator identified above.
ANNEX A: Table of Lawful Bases
The main lawful bases for our use of personal information are as follows:
- Consent: where you have consented to our use of your personal data. You may withdraw your consent to the use of your personal data by contacting us as per Section 10: Contact us. If you do so, we may be unable to provide a service that requires the use of such personal data;
- Contract performance: where we are required to collect and handle your personal data in order to provide you with the services that we have contractually agreed to provide to you;
- Legal obligation: where we need to use your personal data to comply with our legal obligations; and
- Legitimate interests: where we have a legitimate interest in using your personal data. We will only rely on this lawful basis if we consider that our interest in using your personal data for the relevant purpose is not outweighed by any interests that you may have, or any prejudice that you may suffer, from the relevant use of your personal data.
The main lawful bases for our use of your special categories of personal data are as follows:
- Legal claims: where your personal data is necessary for us to establish, exercise of defend any legal claims;
- Substantial public interest: where we need to process your personal data for reasons of substantial public interest set out in UK law; and
- Explicit consent: You have given your explicit consent to the processing of those personal data for one or more specified purposes. You may withdraw your consent to the use of your personal data by contacting us as per Section 10: Contact us. If you do so, we may be unable to provide a service that requires the use of such personal data.