Welcome to the Eighteen48 Partners Limited’s privacy policy.

Eighteen48 respects your privacy and is committed to protecting your personal data. This privacy policy identifies how we look after your personal data, your privacy rights and how the law protects you.

1. Important information and who we are

Eighteen48 is made up of different legal entities, and this privacy policy is issued on behalf of the Eighteen48 Group so when we mention Eighteen48, we, us or our in this privacy policy, we are referring to the relevant company in the Eighteen48 Group responsible for processing your data. We will let you know which entity is the controller for your data when you purchase a product or service from us. Eighteen48 Partners Limited is the controller and responsible for this website.

More information on Eighteen48 and related Group companies is provided at www.eighteen48.com.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you may download a pdf version of the policy here: www.eighteen48.com/privacypolicy.

Please refer to the Glossary to understand the meaning of some of the terms used.

Purpose of this privacy policy

This privacy policy aims to give you information on how and when Eighteen48 collects and processes your personal data (including any data you may provide through this website or in other ways – see below), why we use your personal data and how we keep it secure.

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 policy (together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

Our Contact details

Full name of legal entity: Eighteen48 Partners Limited

Email address: privacy@www.eighteen48.com

Postal address: Montpelier House, 106 Brompton Road, London SW3 1JJ

Telephone number: +44 (0)20 7590 1855

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy or our privacy practices, including any requests to exercise your legal rights, please contact our data privacy manager using the details above.

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 policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on the date specified above. Historic versions may be obtained upon request.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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 policy 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 as follows:

• Identity Data includes first name, maiden name, last name, marital status, title, date of birth and gender.
• Contact Data includes home address, billing address, email address and home and mobile telephone numbers.
• Financial Data includes bank account details, and (where relevant) your relevant income, the amount you are looking to invest, and any payments you may wish to make.
• Transaction Data includes details about payments to and from you and other details of products and services you have with us, including those you currently have, which you have currently or previously held.
• 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 and any account(s) with us.
• Profile Data includes your client login information including your username and password, orders or instructions received from you, your feedback and your investment selection(s), preferences and interests, portfolio and account numbers, and other relevant information you may have provided to us, for example where your investment money has come from.

In addition to the above, we will collect the following information from you when required:

• your tax residency and/or nationality, to comply with our legal and regulatory requirements.
• personal data which we obtain from identity verification agencies, for anti-money laundering purposes.
• information about your employment status (such as whether you are employed, retired or receive benefits) and the source of your wealth, for regulatory compliance purposes relevant to specific products and/or services.
• answers to security verification questions, to secure your account.

• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We do not collect, use or share Aggregated Data such as statistical or demographic data for any purpose. We also do not collect, use or share 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).

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 cancel a product or service you have with us. We will notify you if this is the case.

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 corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you meet with our staff and any verbal or written communications with our staff.
• Automated technologies or interactions. As you interact with our website, we will 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 party sources or publicly available sources. Sometimes we collect additional information about you from third parties. Specifically, we will obtain information about you from:
• Contact, Financial and Transaction Data from providers of technical and payment services and agencies (based inside or outside the EU) who we use to monitor and prevent money-laundering.
• Identity and Contact Data from agencies (based inside or outside the EU) that provide us with background checking services.
• Financial, Transaction and Profile Data from third parties who you have authorised and appointed to deal with your investments on your behalf (such as an investment advisor or wealth manager).
• Identity and Contact Data from publicly available sources, such as Companies House and the Electoral Register based inside 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 have obtained your consent to process personal data either contractually or based on a specific request.
• 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 in instances where your interests and fundamental rights do not override these. A legitimate interest is when we have a business or commercial reason to use your information – but our legitimate interest must not unfairly go against what is right and best for you.
• Where we need to comply with a legal obligation

Each of these categories is a ‘legal basis’ that allows us to process your information under data protection law. Click here to find out more information about what this actually means, in terms of how we process your personal data, and the purposes for processing your personal data relevant to each legal basis.

You have the right to withdraw consent to processing your personal data at any time by contacting us.

Marketing by 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, which may include communications via post or email (or other electronic means) containing investment-market related reports, information and insights. This is how we decide which services may be relevant for you (we call this marketing).

You will receive such marketing communications from us if you have requested information from us or used our services previously and you have not opted out of receiving that marketing.

Please note that we will use your personal data to perform any contract, transaction or service we have agreed with you, for example to contact you for approval of investment decisions, or to provide you with reports, information, insights and updates on your existing or prospective investment activities or portfolio, where these are in line with your agreed investment management mandate. This is not classed as marketing. See the ‘Performance of a Contract’ section below for further details.

No third-party marketing

We will not share your personal data with any third party for marketing purposes.

Opting out

You can ask us to stop sending you marketing at any time by following the opt-out links on any marketing message sent to you, or by contacting us at any time.

Where you opt out of receiving marketing, this will not apply to our use your personal data to perform any contract, transaction or service we have agreed with you, in line with your agreed investment management mandate.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 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 which 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 explain the legal basis for this.

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 share your personal data with the parties set out below for the purposes set out above.

• Internal Third Parties as set out in the Glossary section below.
• External Third Parties as set out in the Glossary section below.
• Third parties 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 policy.

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. If you have any questions about the third parties we share your personal information with, please contact us.

6. International transfers

We share your personal data within the Eighteen48 Group. This may involve transferring your data outside of the UK. We will ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”.

Some of our external third parties are based outside of the UK so their processing of your personal data will involve a transfer of data outside of the UK.

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

• We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data . This includes the European Union and countries covered by a European Commission “adequacy decision”. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe and the UK. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where the transfer is subject to a set of binding obligations under which a group of undertakings has committed to process personal data in accordance with the UK GDPR and the UK Binding Corporate Rules which have been approved by the ICO.
• Where the transfer is conditional upon the data importer signing up to a code of conduct approved by the ICO.

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 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 & deletion

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

We will, in relation to our client investment management activities, retain all relevant client records, reports and other information (including certain personal data) for a period of six years, or such other period as required by relevant law (including the UK Financial Conduct Authority Handbook of Rules and Guidance). Further details of this are available in your Investment Management Agreement which you can request from us by contacting us.

Deleting & anonymising your personal data

Our data privacy manager is responsible for the continuing process of identifying personal data that has met its required retention period and for supervising its destruction in line with our data retention periods.

In some circumstances you may ask us to delete your data: see Your Legal Rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for 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 on the links below to find out more about these rights:

• Right to be informed
• Request access to your personal data.
• Request rectification 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 portability of your personal data.
• Right to withdraw 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 could refuse to comply with your request in these circumstances.

What we may need from you

As a security measure, we may 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).

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests, in which case you will be notified and updated.

10. Glossary

LAWFUL BASIS

Consent means we have offered you a real choice and control as well as the right to withdraw such consent. We typically obtain your consent to process your personal data for the purposes of and/or when entering a contractual relationship with you. We will obtain your separate consent for anything that is not covered by the contractual relationship.

Legitimate Interest means processing your data in the interests of pursuing and managing our business interests, including to give you the best service/product 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 may obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Our legitimate interests which are applicable to our processing of your personal information include:

• identification verification, and any anti-fraud, anti-money laundering and such other checks to confirm your identity and to ensure that the investments which we handle for you are done in compliance with our legal obligations (including to the Financial Conduct Authority);
• recording incoming and outgoing calls for training, monitoring, and security purposes, as well as to keep an accurate record of any instructions received from you in relation to your investments;
• administering and managing your account(s) and services relating to that, updating your records and tracing your whereabouts to contact you about your account;
• adhering to guidance and best practice under the regimes of governmental and regulatory bodies such as tax authorities, financial regulators/ombudsmen and non-financial regulators;
• management and audit of our business operations including accounting;
• reviewing and improving the information provided on the Eighteen48 website to ensure is it user friendly and to prevent any potential disruptions or cyber-attacks;
• conducting statistical monitoring and analysis of current attacks on devices and systems to detect malicious data and understand how this may affect your IT system, and for the on-going adaptation of the solutions provided to secure devices and systems against current attacks;
• carrying out searches at identity verification agencies pre-application, at the application stage, and periodically after that;
• determining the target market for our existing and future products and services (e.g. determining whether a service is meeting the needs of investors);
• contacting you when we have updated this privacy policy and consider that it is necessary to advise you about any changes to the way we are processing your personal information.

Performance of a Contract means processing your data where it is necessary for us to perform a contract with you, including fulfilling our obligations under any product or service you have with us (or to take steps at your request before entering into such a contract). This could include:

• fulfilling the terms of any Investment Management Agreement (or any similar contract) we enter into with you;
• communicating with you about your investment(s), product or service (i.e. periodic statements), to verify that your instructions are genuine and to process them accordingly;
• enabling us to process your subscription, switch, conversion or redemption instruction, and to enable payments to be made or, if relevant, currency to be converted for you;
• where applicable, notifying you about changes to your investment(s) (such as a change of name, or amendments to the investment policy of a fund), allowing you to exercise rights in relation to your investment(s) (such as voting rights), or evidencing your ownership of an investment;
• recovering any money amount owed to us;
• investigating and deal with complaints or disputes;
• contacting you when we have updated this privacy policy and consider that it is necessary to advise you about any changes to the way we are processing your personal data;
• transferring your personal data to any third party who replaces an Eighteen48 company as a provider of services to you; and/or
• sharing your personal data with third parties (such as our service provider who assists us administer or process transactions on our behalf) if required for the management of your service.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. This could include:

• verifying your identity and carrying out regulatory checks (such as anti-money laundering and identity verification checks);
• enabling a register of investors to be maintained;
• contacting you with notices about your investments;
• determining the outcome of investor votes (such as the verification and counting of proxy cards);
• detecting, preventing and/or investigating fraud, money laundering and other financial crimes;
• complying with audit requests from our auditor; or the auditor or depositary of the fund you invest into (if we are not able to anonymise/redact information);
• combating and maintaining controls in respect of late trading and market timing practices;
• ensuring you are eligible for a product (such as an ISA);
• verifying the adequacy of your income, net worth or investment experience (e.g. if you request to be categorised as a professional investor) to comply with requests made by you when exercising your legal rights (such as those contained within this privacy policy);
• recording incoming and outgoing calls for regulatory purposes;
• carrying out monitoring of trades and transactions for continued compliance with our regulatory obligations (such as anti-money laundering) and keeping records of the transactions we’ve undertaken.

THIRD PARTIES

Internal Third Parties

Other companies in the Eighteen48 Group who are based in the United Kingdom or overseas.

External Third Parties

Third parties who have a duty to keep your data secure and confidential, where we have a lawful reason for doing so, as explained above, include the following types of organizations:

• Our service providers or service providers of relevant investment funds, or relevant agents and sub-contractors on our or their behalf (such as an investment fund’s transfer agent, registrar, paying agent, representative, facilities agent, auditor, depositary, custodian banks, investment manager, sub-investment manager and global distributor (if relevant)).
• Professional advisers including lawyers, accountants, actuaries, bankers, consultants, auditors and insurers.
• HM Revenue & Customs, and other regulators and other authorities who require reporting of processing activities in certain circumstances.
• UK and overseas regulators and authorities in connection with their duties (such as crime prevention), and/or in connection with our compliance with legal and/or regulatory obligations.
• Market / local exchanges / regulators in certain markets where investments are made, in accordance with local rules and requirements for market transparency.

YOUR LEGAL RIGHTS

You have the right to:

Be informed about the collection and use of your personal data.

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 rectification 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 it being processed (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 (where applicable) we will notify to you.

Object to processing of your personal data where we are relying on a legitimate interest and your situation 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 legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• 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.
• 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 portability 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 prior to the withdrawal of your consent. If you withdraw your consent, we may not be able to provide certain products or services to you, which (where applicable) we will notify to you.