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Privacy Policy – GBIM Clients

GBIM Limited (GBIM) is an investment management company that provides discretionary fund management services. GBIM, Gore Browne and Gore Browne Investment Management are trading styles of GBIM Limited which is authorised and regulated by the Financial Conduct Authority (FCA number 593265) and is a limited company registered in England (07746731). Registered and Head Office at Chequers Court, 37 Brown Street, Salisbury, Wiltshire, SP1 2AS.

GBIM (“we”, “us” or “our”) is committed to protecting and respecting your privacy. This privacy policy sets out how we collect, store and use your personal data when you provide it to us, when you access the GBIM portal site, or submit information via our website or otherwise. It provides you with details about the types of personal data that we collect from you, how we use your personal data and the rights you have to control our use of your personal data.

GBIM is the data controller in respect of your personal data. To contact us please refer to the ‘How to contact us’ section below.

Topics covered:

  • What information do we collect about you?
  • How will we use the information about you?
  • Marketing
  • Disclosure to and use of your information by third parties
  • How long will we store your information?
  • Security
  • Your rights
  • Where we store your information
  • Cookies
  • Changes to this policy
  • How to contact us

What information do we collect about you?

We collect information from you when you open an account with us, but we only collect the information that is necessary to perform our contractual duties and to comply with UK and applicable international regulations. This includes information that identifies you, so your name, address, date of birth, nationality, national insurance number; your bank account details (to make payments to you), and information about your financial/tax situation to ensure we manage your investment portfolio accordingly.

The information we keep is that which you gave to us when becoming a client, the correspondence we exchange with you and any anti money laundering (AML) checks we are required to make. Also, and following the introduction of MIFID II, we are required to record telephone conversations with clients.

How will we use the information about you?

The purposes for which we use your information and the legal basis under data protection law on which we rely to do this are as follows:

  • We will keep your information for the Performance of a contract we have with you, this includes
    – we use the information about you to manage your portfolio of investments according to your risk profile, preferences, financial situation etc
    – To contact you to discuss matters relating to your portfolio
    – To update you on your investments
  • It is necessary for the compliance with a legal obligation; this is in order to comply with AML and anti-terrorist financing regulations.

Marketing

We would like to send you quarterly newsletters and occasionally other articles which we think may be of interest to you and we require your consent to do so. If you have consented to receive the Newsletter and other information and no longer wish to receive it, you may opt out at any time. To contact us please refer to the ‘How to contact us’ section below.

Who will have access to my information?

  • Our GBIM employees
  • Our third-party partners that are required to fulfil our contractual obligations to you; such as our clients’ custodian, our client relationship management company, our accountants/auditors, our IT company and our printers. When we use third party service providers, we only disclose to them the personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our agreement.
  • Credit reference agencies and fraud prevention agencies, this process may leave a ‘Soft footprint’ on your credit record but will not affect your credit rating.
  • If it is a requirement, law enforcement, regulatory and tax authorities.
  • We will not share or sell your information for marketing purposes with any other organisations.

How long will we store your information?

Our policy is to keep your information for five years from the date that your client account is deactivated though this can be extended to seven years on request by our regulator.

Security

The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us and any transmission is at your own risk. Once we have received any data, we will use strict procedures and security features to prevent unauthorised access.

Where we have given (or where you have chosen) a password which enables you to access the files we send to you or the GBIM Portal site, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.

Your rights

Under data protection law, you have rights in respect of the personal data relating to you. You have the right:

  • to be informed about the processing of your personal data (this is what this statement sets out to do);
  • to have your personal data corrected if it is inaccurate and to have incomplete information completed;
  • to object to processing of your personal data;
  • to restrict processing of your personal data in certain circumstances including where you contest the accuracy of it, you have objected to it and we are assessing whether we can stop processing it and still comply with our contractual and legal obligations;
  • to have your personal data erased in certain circumstances including where it is no longer necessary for our purposes, you withdraw your consent or you object to the processing and we have no overriding contractual or legal reasons to continue using it;
  • to withdraw your consent to our processing of your personal data where we have relied on your consent;
  • to request access to your personal data and information about how we process it;
  • to move, copy or transfer your personal data in certain circumstances and where feasible; and
  • rights relating to automated decision making, including profiling.

The way we process your information and the legal basis on which we rely to process it will affect the extent to which these rights apply to you. If you would like to discuss or exercise any of these rights, please contact us using the details provided below.

You have the right to lodge a complaint with the Information Commissioner’s Office where your information has or is being used in a way that you believe does not comply with data protection laws. We encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.

Where we store your information

All information you provide to us is stored securely in our offices or on our secure servers which are located within the European Economic Area (EEA). Our custodian bank does have servers in the US, and your information might be stored there, this does however fall under the EU-US Privacy Shield Framework, for more information please go to www.privacyshield.gov

If at any time we transfer your information to, or store it in, countries located outside of the EEA (other than the US), we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. This is because some countries outside of the EEA do not have adequate data protection laws equivalent to those in the EEA.

Cookies

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. We may use this information to track visitor use of the website and to compile statistical reports on website activity. For further information visit www.aboutcookies.org or www.allaboutcookies.org. You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

Changes to This Policy

We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website site and/or by contacting you by mail/email. If we plan to use your personal data for a new purpose, we will update our privacy policy and communicate the changes to you before we start any new processing.

If you do not agree with any aspect of the updated policy you must immediately notify us.

This privacy policy was last updated on 14/05/2018.

How to Contact Us

Please contact us if you have any questions about our privacy policy or information we hold about you by:

  • Contacting your investment manager
  • Emailing us at gdpr@gbim.co.uk
  • Writing to us at: The Data Protection Officer, GBIM Ltd, Chequers Court, 37 Brown Street, Salisbury, SP1 2AS