Before you access the First Sentier Investors website, we would like you to read & understand some important information about the site, what data we collect and how we use it. This information is set out in the terms and conditions below:
- Important Information
- Privacy Notice
- Cookie Policy
Scroll down to view the relevant policy.
1. Important Information
If you are not a Professional Client or an Eligible Counterparty and are based in the UK please return to www.fssaim.com and select Private Investor.
It is important that you read this page. The use of www.fssaim.com (this “Website”) is subject to the following terms and conditions (the “Terms”). After you have read and understood these Terms, you may click “I Agree” to confirm that you agree to the Terms which create a binding legal agreement between us. If you do not agree to these Terms, please refrain from using this Website.
IMPORTANT INFORMATION ABOUT ACCESS TO THIS WEBSITE
This Website and the information on it is communicated by First Sentier Investors (Ireland) Limited (“First Sentier Investors”), which is authorised and regulated by the Central Bank of Ireland. It is not directed at or made available to Retail Clients. This Website uses cookies as described in paragraph 16 of these Terms and by agreeing to these Terms you consent to the use of cookies as described in that paragraph.
This Website (and the information on it) is directed only at persons who are Professional Clients or Eligible Counterparties for the purposes of the Markets in Financial Instruments Directive (“MiFID”) or as otherwise defined under applicable local regulations and at whom this Website (and any information on it) may lawfully be directed in any relevant jurisdiction. Access to this Website is not open to persons resident in, or citizens of any territory where, to allow such access would require any registration, filing, application for any licence or approval or other steps to be taken by First Sentier Investors in order to comply with local laws or other regulatory requirements in such overseas territory. Please contact First Sentier Investors if you require any further information on your status.
Following a UK departure from the European Union, First Sentier Investors ICVC (“OEIC”) has ceased to qualify as a UCITS scheme and is instead an Alternative Investment Fund (“AIF”) for European Union purposes under the terms of the Alternative Investment Fund Managers Directive (2011/61/EU). Accordingly, no marketing activities relating to the OEIC are being carried-out by First Sentier Investors in the European Union (or the additional EEA states) and the OEIC is not available for distribution in those jurisdictions. This website does not constitute an offer or invitation or investment recommendation to distribute or purchase shares in the OEIC in the European Union (or the additional EEA states).
1. About this Website: This Website is owned, maintained, operated and communicated by First Sentier Investors (Ireland) Limited which is authorised and regulated by the Central Bank of Ireland (the “CBI”). First Sentier Investor’s registered office is at 70 Sir John Rogerson’s Quay, Dublin 2, Ireland number 629188 (CBI registration number C182306).. The information on this Website constitutes a financial promotion and an invitation or inducement to engage in investment activity and/or a marketing communication.
This Website contains information about investment funds which are offered by First Sentier Investors (the “Funds”) and which are registered, or have otherwise been notified, for public distribution and marketing in certain jurisdictions in the European Union / EEA. Please note that the fact of such registration does not mean that any regulator has determined that such Funds are suitable for all or any investors. The Funds referred to on this Website may not be suitable investments for you and you should therefore seek professional investment advice before making a decision to invest in any of the Funds.
A prospectus and Key Investor Information Document (“KIID”) for each of the Funds is available on this Website. Contact details of the facilities where such documents are available are also set out on the web-page for the relevant Fund.
2. Selling Restrictions: The distribution of the information on this Website may be restricted by law in certain countries. You have selected Spain as your country of residence. This Website, and the information on it, are not addressed to any person resident in the territory of any country or jurisdiction where such distribution would be contrary to local law or regulation. By choosing to view or make use of this Website you do so on the basis that you have informed yourself of any regulatory or other consequences of your doing so.
First Sentier Investors and its affiliates disclaim all responsibility if you access or download any information from this Website in breach of any law or regulation in the country of which you are a citizen or in which you are residing or domiciled. If your country of residence or domicile changes, you must access this Website selecting your new country of residence. Please note, however, that this may impact your ability to access information about certain Funds.
3. No Advice: The information on this Website is provided for information only and does not constitute, and should not be construed as, investment advice or a recommendation to buy, sell or otherwise transact in any investment including the Funds. The information on this Website is provided solely on the basis that you will make your own investment decisions and First Sentier Investors has not taken any account of your particular investment objectives or financial situation in preparing the information on this Website. In addition, nothing in this Website shall, or is intended to, constitute financial, legal, accounting or tax advice. We strongly recommend that you seek professional investment advice before making any investment decision.
First Sentier Investors neither provides investment advice to, nor receives and transmits orders from, investors in the Funds.
4. Price and Performance Information: All prices provided on this Website are indicative only. Such prices or values may not reflect actual prices or values that would be available in the market at the time provided or at the time you may decide to purchase or sell an interest in a particular Fund. First Sentier Investors accepts no responsibility for updating such price information.
Past performance is not a reliable indicator of future performance. The value of investments and the income from them can go down as well as up and investors may not get back the amount originally invested and may lose all of their investment. Exchange rate changes may cause the value of overseas investments to rise or fall. To the extent that any information on this Website refers to a particular tax treatment, such treatment depends on the individual circumstances of the investor and may be subject to change in the future.
5. Risk Warnings: Any investment involves substantial risks. Further information about the types of risks associated with investment in the Funds referred to on this Website can be found here. The offering documents for each Fund also contain risk warnings which are specific to the relevant Fund and which you should consider carefully before taking any decision to invest.
6. Offering Documents: The terms of any investment in a Fund are governed by the documents establishing such terms. In the event of any inconsistency between the information on this Website and the terms specified in, or established pursuant to, the documents establishing the terms of issue or contract, the terms so specified or determined shall prevail. An application for interests in any of the Funds should only be made having fully and carefully read the relevant prospectus, the latest financial reports and other offering documents for the relevant Fund which are available on this Website and upon request from the fund representative in your jurisdiction.
7. Information on this Website: First Sentier Investors has taken reasonable care to ensure that the information contained on this Website is accurate, current, complete, fit for its intended purpose and compliant with relevant legislation and regulations and, where applicable, the laws of the country of your residence as at the date of issue. However, errors or omissions may occur due to circumstances beyond First Sentier Investors’ control and no warranty is given, or representation made, regarding the accuracy, validity or completeness of the information on this Website and no liability is accepted by such persons for the accuracy or completeness of such information. You must conduct your own due diligence and investigations rather than relying on any of the information in this Website. Any person who acts upon, or changes his or her investment position in reliance on, the information contained on this Website does so entirely at his or her own risk.
Information posted on this Website is current only as at the date it is first posted and may no longer be true or complete when viewed by you. First Sentier Investors cannot guarantee that content will be accurate, complete and current at all times. To the extent that any information on this Website relates to a third party, such information has been provided by that third party and is the sole responsibility of such third party and First Sentier Investors accepts no liability for such information. All content on the Website is subject to modification from time to time without notice. Please contact First Sentier Investors for further information regarding the validity of any information contained on this Website.
To the extent that this Website contains any expression of opinion or forecast, such opinion or forecast is based on sources believed by First Sentier Investors to be reliable, but is not guaranteed or warranted as to its current validity, accuracy or completeness. Opinions expressed represent the opinions of First Sentier Investors at the date of publication only, reflecting prevailing market conditions and certain assumptions (which may not prove to be valid), are subject to change and should not be relied on by users of the Website.
Certain content (the “Restricted Content”) on this Website including, but not limited to, webcasts shall be made available only on the granting of permission by First Sentier Investors or a third party appointed by First Sentier Investors. First Sentier Investors reserves the right, in its absolute discretion, not to grant access to such Restricted Content. Where you are granted access to such Restricted Content, such access is granted for your personal use only. You must treat this Restricted Content as confidential and you must not disclose it to any third party or allow any third party to access such Restricted Content. First Sentier Investors may revoke access to the Restricted Content in its absolute discretion at any time without notice.
8. Material Interests: First Sentier Investors, its affiliates and its or their directors, officers, employees or agents may have holdings in the Funds and/or underlying investments of the Funds and may otherwise be interested in transactions in those Funds. Further details about the policies that First Sentier Investors has adopted in order to avoid or to manage such conflicts in a way that ensures fair treatment for First Sentier Investors’ clients are available from First Sentier Investors on request.
9. Linked Websites: Links to websites operated by third parties are provided for information only and do not constitute any form of advice, endorsement or recommendation of such websites or the material on them. First Sentier Investors accepts no responsibility for information contained on any other sites which can be accessed by hypertext link from this Website or for these sites not being available at all times. First Sentier Investors has not reviewed, and will not review or update, such websites or information and any use that you make of such websites and information is at your own risk. Please note that when you click on any external site hypertext link you will leave this Website.
10. Liability: No warranty is given that the contents of this Website are compatible with all computer systems or browsers or that this Website shall be available on an uninterrupted basis. First Sentier Investors does not accept any liability for any damages or losses arising from changes or alterations made to this Website by unauthorised third parties.
The internet is not a completely reliable transmission medium and neither First Sentier Investors nor any of its affiliates accept any liability for any data transmission errors such as data loss or damage or alteration of any kind or for the security or confidentiality of information transmitted across the internet to or from First Sentier Investors or any of its affiliates. Any such transmission of information is entirely at your own risk and any material downloaded from this Website is downloaded at your own risk.
The information on this Website is provided “as is”. To the extent permitted by law, First Sentier Investors, its affiliates and its and their directors, officers, employees and agents expressly exclude all conditions, warranties, representations and other terms which might otherwise be implied by statute, common law or the law of equity. First Sentier Investors and its affiliates will only be liable to you in respect of any direct losses arising from your use of, or inability to use, this Website in the event of First Sentier Investors’ gross negligence, wilful default or fraud. In no event will First Sentier Investors or any of its affiliates be liable to any person for any indirect, special or consequential damages arising out of any use of, or inability to use, this Website or the information contained on it or on any other hyper-linked site including, without limitation, any lost profits, business interruption, loss of programs or data on your equipment or otherwise, even if First Sentier Investors is expressly advised of the possibility or likelihood of such damages. This does not affect First Sentier Investors’ liability for any loss or damage which cannot be excluded or limited under applicable law.
Nothing in these Terms is intended to exclude or restrict any duty or liability that First Sentier Investors has to its clients under applicable local regulatory rules or which may not be excluded or restricted as a matter of applicable law.
11. Access: First Sentier Investors reserves the right to suspend or withdraw access to any page(s) included on this Website without notice at any time and accepts no liability if, for any reason, these pages are unavailable at any time or for any period.
12. Compliance with Law and Regulation: When using this Website you must comply with all applicable local, national and international laws including those related to data privacy, international communications and exportation of technical or personal data. It may be illegal to download the information contained on this Website in certain countries and First Sentier Investors, its affiliates and its and their directors, officers, employees and agents disclaim all responsibility if you download any information from this Website in breach of any law or regulation of the country in which you reside.
13. Intellectual Property:
(a) Unless otherwise specified, First Sentier Investors is the owner or the licensee of all intellectual property rights in and to this Website, its content and the information, imagery and data published on it including but not limited to copyright and trade mark rights (whether registered or unregistered). Those works are protected by copyright laws and treaties around the world. All such rights, save as expressly granted, are reserved.
(b) Notwithstanding paragraph (a) above, no warranty or indemnity is given that the use of the Website, or any information or material taken or downloaded from the Website will not infringe the intellectual property rights of any third party.
(c) Reproduction in any form of any part of the content, information, imagery or data from, or underlying, this Website, save for in strict compliance with these Terms, is prohibited without the prior written consent of First Sentier Investors. All such intellectual property rights shall continue to be held by First Sentier Investors or its licensors and no rights of any kind in such rights shall pass to you.
(d) The information held on this Website is for your own personal use only. You may print off or download copies of, or extracts from, pages from this Website for your personal reference but you must not modify those copies or extracts in any way. First Sentier Investors (and any identified contributors), as the authors of material on this Website, must always be acknowledged.
(e) Notwithstanding paragraph (d) above, to the extent that you are a financial advisor, you may use the information available on this Website and provide copies of documents available on the Website to make recommendations to your clients, however such information is not intended for direct use by members of the public.
(f) Any unauthorised downloading, re-transmission or other copying or modification of any of the contents of the Website may be in breach of statutory or common law rights which could be the subject of legal action. First Sentier Investors disclaims all liability which may result from any unauthorised reproduction or use of the information on the Website.
(g) All trade marks, service marks, company names or logos are the property of their respective holders. The display of any trade names or trade marks on the Website does not imply that any licence has been granted to any third party in respect of the same. Any use by you of these marks, names and/or logos may constitute an infringement of the holders’ rights.
14. The Internet: Please note that there is no guarantee that any e-mail sent by you will be received by us, or that the contents of any such e-mail will remain private during internet transmission. Any information is sent at your own personal risk.
15. Data Protection: Please see our Privacy Notice for information relating to how First Sentier Investors and other companies associated with it protect your personal data. In agreeing to these Terms you agree to the terms of our Privacy Notice.
16. Cookies: Cookies are small data files that are sent to and stored on your computer, smartphone or other device used to access the internet, whenever you visit a website. We use cookies to enable and improve certain functions on our website and gain feedback on how our website is used. If you choose to switch certain cookies off, it will affect how our website works.
Cookies are useful because they allow a website to recognise the device you are using. As the First Sentier Investors group are based in various jurisdictions and operate different websites for each regional business, we use your IP address to identify your location, and use cookies to store general information such as the region where you are based, the language the site is being viewed in (for example English, Chinese) and the type of client you are. This helps us to tailor our website to better suit your requirements. The Cookies we use here are ‘session’ cookies and will be removed every time you leave our website.
When you browse this website, you do so on the basis of these Terms and Conditions, a Cookie may set if you have accepted them. This can mean that you don’t have to re-accept them on every visit. This type of cookie is ‘persistent’ as they remember your preferences. Every time we amend our Terms and Conditions, or on an annual basis, a new Cookie will be set and you will be asked to re-accept our Terms and Conditions.
We use analytics cookies to collect information on website activity (such as the number of users who visit our website, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site and, when entering our website from another website, the address of that web site). This information on its own does not identify an individual but it does provide us with statistics that can be used to analyse and improve our website. These Cookies are ‘session’ cookies.
The browsers of most computers, smartphones and other web–enabled devices are usually set up to accept cookies. If your browser preferences allow it, you can configure your browser to accept all cookies, reject all cookies, or notify you when cookies are set. Each browser is different, so check the "Help" menu of your browser to learn about how to change your cookie preferences.
However, please remember that cookies are often used to enable and improve certain functions on our website. If you choose to switch certain cookies off, it will affect how our website works and certain functionality may not work.
More information about cookies can be found on allaboutcookies.org
17. Amendment: First Sentier Investors may delete or make changes to these Terms and to the information contained on this Website at any time. Where we make any changes to these Terms, you will be required to accept such changes in order to continue to use the Website. If you do not accept such revised Terms, you may no longer be able to access this Website.
If any provision of these Terms is found by any court or authority of competent jurisdiction to be illegal, void or invalid under the laws of any jurisdiction, the legality, validity or enforceability of the remainder of these Terms in that jurisdiction shall not be affected and the legality, validity and enforceability of the whole of these Terms in any other jurisdiction shall not be affected.
18. Third Parties: First Sentier Investors’ affiliates shall have the benefit of the rights conferred on them by these Terms but otherwise no person who is not a party to these Terms may enforce its terms.
19. Applicable Law: These Terms and any non-contractual obligations arising from or connected with them shall be governed by, and these Terms shall be construed in accordance with, the laws of Ireland.
20. Jurisdiction: You agree that the Irish courts shall have exclusive jurisdiction in relation to any legal action or proceedings arising out of or in connection with these Terms (whether arising out of or in connection with contractual or non-contractual obligations) (“Proceedings”) and waive any objection to Proceedings in such courts on the grounds of venue or on the grounds that Proceedings have been brought in an inappropriate forum. You further agree that this paragraph operates for the benefit of First Sentier Investors and accordingly First Sentier Investors shall be entitled to take Proceedings in any other court or courts having jurisdiction.
21. Contact Us: If you have any enquiries in relation to this Website or the information on it, please contact First Sentier Investors at enquiries@firstsentier.com
By clicking “I Agree” you:
(1) represent, warrant and undertake to us that you are resident in the country selected when entering this Website;
(2) confirm that you have read and understood the Terms and agree to abide by them on every occasion that you access this Website;
(3) confirm that you are accessing this Website in compliance with the laws and regulations of your jurisdiction; and
(4) confirm you have read and understood our Privacy Notice.
Please click the "I have read and agree to the above information" button below if you have read and understood this page and agree to abide by its contents, otherwise click "Cancel" to leave the website.
2. PRIVACY NOTICE
First Sentier Investors
Background
This Notice gives information on how the First Sentier Investors group of companies collect, use and protect the personal data held about investors, clients, intermediaries and other business contacts.
This Notice describes how we will fulfil our obligations under applicable data protection laws.
Information about us
References in this Notice to First Sentier Investors will include the following companies as well as the EU and UK based group company investment funds that they manage (as applicable):
First Sentier Investors (UK) Funds Limited*
First Sentier Investors (UK) IM Limited*
First Sentier Investors (UK) Services Limited
First Sentier Investors UK Holdings Limited
First Sentier Investors International IM Limited*
First Sentier Investors (Ireland) Limited**
(together “we”, “us” or “our”)
*Authorised and regulated by the Financial Conduct Authority of the United Kingdom
**Authorised by the Central Bank of Ireland
Information we may collect
First Sentier Investors collects from time to time, personal data on investors, clients, intermediaries and other business contacts from a number of sources, including from: investor application forms; other First Sentier Investors forms (including website forms); client investment management agreements; correspondence, conversations with clients, advisers, intermediaries; business cards; third party service providers to our funds (for example, transfer agents, administrators, distributors, custodians, paying agents); client advisers; other third parties; and from public sources. This information may be collected directly from investors, clients, intermediaries and business contacts, or indirectly from third parties, as follows:
From you
We may collect from you and process the following personal data, depending on the nature of our business relationship with you:
- Your name; address (including proof of name and address); photo identification; contact details both personal and work (for example, your email and phone numbers); hobbies and interests; job title and company; nationality; citizenship; tax residency; date of birth; passport details; national insurance number and other tax details; adviser details; investment details; banking details; signed contracts with you; business cards, contact sheets and biographies; financial dealings; family connections; details of your company’s directors, secretaries, authorised signatories and identification documents; details of any complaints made; data received from due diligence activities (such as anti-money laundering, politically exposed persons and sanctions checks); responses to surveys and competitions; fraud enquiries (for example, information from police reports); images captured by CCTV cameras on our premises; recordings of telephone conversations and electronic communications with our staff.
- By the use of cookies on this site in accordance with our Cookies Policy set out below.
From third parties
We may collect personal data about you from third parties, depending on the nature of our business relationship with you, in particular:
- Third party service providers to our funds (for example, transfer agents, registrars, administrators, distributors, custodians and paying agents) – information received includes personal details of investors obtained from fund application forms such as: name; address; contact details; nationality; national insurance number; date of birth; tax residency; adviser details; investment details; bank account details.
- Your advisers (including independent financial advisers) – information received may include your name, address, gender, date of birth; bank details.
- Our vendors such as Experian and World-Check – information received includes the results of “Know Your Client”, anti-money laundering, politically exposed persons and sanctions checks.
- Publically available sources such as MandateWire and LinkedIn – information available includes contact details of institutional investors (MandateWire) and details of job title, company, former employers and roles, and connections (LinkedIn).
How we will use the information we collect
The information we collect and use will depend on the nature of our business relationship with you, as follows:
- In relation to prospective investors and clients, we may process personal data for identification purposes (prior to becoming an investor in our funds or a client of ours under an investment management agreement), for the purposes of anti-money laundering, counter terrorist financing, suitability and appropriateness assessments, “Know Your Client” and credit-worthiness checks, and for any other applicable legal or regulatory reasons. Failure to provide relevant information will mean that we will not be able to on-board a potential investor or client.
- In relation to investors in our funds, we may process information collected for the purpose of account administration and other general business purposes (for example, for processing subscriptions and investments; maintaining the share register of investors, carrying out investor instructions; handling any complaints and enquiries; sending investor communications, including financial reports, valuations, corporate actions). In addition, in order to comply with regulatory obligations, we may collect and disclose certain information about our investors and certain related persons and their investments to HM Revenue & Customs and/or other relevant tax authorities overseas.
- In relation to our investment management clients, we may process personal data for the purpose of managing and administering clients’ accounts, including providing valuations and periodic reports and informing clients of relevant information as required by the investment management agreement.
- We may from time to time process personal data of investors and clients to comply with legal and regulatory requirements impacting our business. In particular, we may need in the context of our business: to obtain legal advice on legal and regulatory requirements; to report to relevant regulators; to comply with market opening and registration requirements in the conduct of our business.
- In relation to intermediaries who introduce investors into our funds (such as distributors, platforms and independent financial advisers), we may process personal data to conduct market research, gauge product sales or product performance or assess the creditworthiness of intermediaries. In addition, we may process the personal data of investors introduced to our funds, as outlined above.
- In relation to our general business contacts (including consultants and intermediaries who act for our mutual clients), we may process personal data for general business purposes such as: for public relations and corporate communications purposes; providing thought leadership articles; networking/relationship building; conducting market research and gathering industry statistics; evaluating products and services; and assisting with any queries.
- Monitoring purposes: we may process personal data to analyse the performance of IT systems, monitor usage of resources and systems and to improve products, services and usability of our technology platform, including telephone calls and electronic communications with our staff which may be recorded for the purposes of retaining a record of communications, in the interests of security, for training and compliance monitoring purposes and/or to comply with legal or regulatory obligations.
- Where you have provided your consent, we may process your personal data for the purposes of informing you (for example, by telephone, mail and email) about other products and services available from the First Sentier Investors group of companies and of marketing campaigns and event invitations.
We are entitled to use your personal data in these ways because:
- We have legal and regulatory obligations that we have to discharge;
- We may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
- The use of your personal data as described is necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates);
- The use of your personal data is necessary for the performance of a contract with you;
- You have provided your consent to us processing your personal data (other than for marketing purposes); or
- You have provided your consent to us processing your personal data for the purposes of informing you (for example, by telephone, mail or email) about other products and services available from the First Sentier Investors group of companies and of marketing campaigns and event invitations.
Disclosure of your information
- We may disclose your personal data to any member of the First Sentier Investors group, which means our affiliates, for internal business and administrative purposes (including to administer our products and services and for prudential and risk management purposes) and, where you have given your consent, to provide you with information on related products and services. We may also disclose personal data relating to our clients to members of our group to whom we sub-delegate our services (for example, trade order execution and portfolio management).
- We may disclose your personal data to third parties that are specifically engaged by us to provide services to us, in which case we will require those parties to keep that information confidential and secure and to use it solely for the purpose of providing the specified services to us. The following is a list of the types of third parties who process your personal data on our behalf:
- third party service providers to our funds (for example, transfer agents, administrators, distributors, custodians, paying agents and researchers). These third party service providers may also disclose and transfer your personal data to their affiliates or other third party contractors;
- credit reference agencies, debt collection agencies and other companies for use in credit decisions, for fraud prevention, to pursue debtors and for the verification of identity;
- document execution vendors in relation to the execution of contracts with our clients;
- insurance brokers;
- professional advisers (for example, accountants/tax advisors and legal advisors).
- If you use a financial adviser (as indicated on your investor application form), then details of your investments and valuations may also be provided to such financial adviser.
- We may disclose to relevant tax authorities, regulators, government departments or competent authorities of the UK or of other countries, any personal data (including tax status, identity or residency or other personal and payment information, documents or self-certifications) in order to comply with a court order or to meet legal and regulatory requirements arising in the conduct of our business. Such disclosure may be made directly to such regulators or competent authorities or made indirectly to our advisers or providers who will make such filings or disclosures on our behalf.
Transfers outside the EEA
We may transfer your personal data to our overseas affiliates (including outside the EEA) and/or allow the information to be accessed by our affiliates and their employees outside the EEA as well as within in. It may also be processed by personnel operating outside the EEA who work for us or for one of our third party service providers.
Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA or that the transfer is otherwise compliant with data protection laws. This can be done in a number of ways, for example:
- the country that we send the data to might be approved by the European Commission;
- the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data;
- where data protection laws permit us to transfer your personal data outside the EEA.
You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a sample copy of the model contractual clauses) by contacting infoUK@firstsentier.com
How long will we store your data?
Personal data held by us will be kept confidential. How long we hold your personal data for will vary and will be determined by various criteria, including:
- the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
- legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.
Your rights in relation to your data
If you wish to contact us for any of the reasons below, please e-mail us at infoUK@firstsentier.com
- You have a right to access the information which we hold about you. If you wish to make an application to access or obtain this information, please contact us. In some circumstances, you have the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit that data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us.
- We take reasonable steps to ensure that the personal data we collect, use or disclose is accurate, complete and up to date. Please contact us if any of the details you have provided change. Please also contact us if you believe that the information we have about you is not accurate, complete or up to date.
- If you wish us to erase or restrict using your data, please contact us. We may need to discuss with you the basis of your request as there may be circumstances where we are legally entitled to continue processing your personal data/refuse your request.
- If you have previously provided your consent to our use of your data (other than for marketing purposes) and you wish to withdraw such consent, please contact us. We may need to discuss with you whether our use of your data needs to continue for lawful purposes (i.e. because we have another legitimate reason (other than your consent) for doing so).
- If you have previously consented to being sent information about other products and services available from the First Sentier Investors group of companies, you may withdraw such consent by contacting us.
- If you have any complaints in relation to the way we have used your information, please contact us in the first instance. If you are based in the UK you also have the right to lodge a complaint with the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF (Tel: 0303 123 1113) or, if you are based in the EU or EEA, the Irish Data Protection Commission at 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland (Tel: +353 578 684 800) if you think that any of your rights have been infringed by us.
Other Products and Services
If you would like to receive further information from us about other products or services offered by First Sentier Investors group, please ensure you tick the relevant box on the appropriate application form or contact us by e-mailing us at infoUK@firstsentier.com
Links to other web sites
Our web site may contain links to non-First Sentier Investors web sites. While such links are provided for your convenience, you should be aware that the information handling practices of the linked web sites might not be the same as ours. You should review any privacy policies on those linked websites. We are not responsible for any linked websites.
Recording of telephone conversations and electronic communications
Please note that we are required to record telephone conversations (we will do so without a warning) and to keep copies of electronic communications. We are required to keep copies of these recordings and electronic communications for a period of five years (or up to seven years at the request of a regulator). Copies may be provided to you upon request by contacting infoUK@firstsentier.com
Changes to our Privacy Notice
This Notice was updated in September 2021. We reserve the right to change this Notice at any time. We will ensure that any changes to this Notice are added to the Notice available on our website on their effective date.
3. Cookies Policy
Cookies are small data files that are sent to and stored on your computer, smartphone or other device used to access the internet, whenever you visit a website. We use cookies to enable and improve certain functions on our website and gain feedback on how our website is used. If you choose to switch certain cookies off, it will affect how our website works.
Cookies are useful because they allow a website to recognise the device you are using. As the First Sentier Investors group are based in various jurisdictions and operate different websites for each regional business, we use your IP address to identify your location, and use cookies to store general information such as the region where you are based, the language the site is being viewed in (for example English, Chinese) and the type of client you are. This helps us to tailor our website to better suit your requirements. The Cookies we use here are ‘session’ cookies and will be removed every time you leave our website.
When you browse this website, you do so on the basis of these Terms and Conditions, a Cookie may set if you have accepted them. This can mean that you don’t have to re-accept them on every visit. This type of cookie is ‘persistent’ as they remember your preferences. Every time we amend our Terms and Conditions, or on an annual basis, a new Cookie will be set and you will be asked to re-accept our Terms and Conditions.
We use analytics cookies to collect information on website activity (such as the number of users who visit our website, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site and, when entering our website from another website, the address of that web site). This information on its own does not identify an individual but it does provide us with statistics that can be used to analyse and improve our website. Visit Google’s site for an overview of privacy at Google and information on how to opt out of the Google Analytics cookie. These Cookies are ‘session’ cookies.
We use marketing automation cookies placed by Pardot and Salesforce. Pardot tracks visitor and prospect activities on our website and landing pages by setting cookies on your browsers. Cookies are set to remember preferences (like form field values) when you return to our site following a previous visit. Pardot also sets a cookie for logged-in users to maintain the session and remember table filters.
Pardot sets first-party cookies for tracking purposes, to allow us to improve our content, and sets third-party cookies for redundancy. Using first-party and third-party cookies together is standard in the marketing automation industry. Pardot cookies don’t store personally identifying information, only a unique identifier. Pardot sets first-party cookies on tracker subdomains and Pardot domains.
We use remarketing cookies to allow us to match external advertising messages with the pages that you have visited on our website, with the intention of providing you follow-up information. You can opt-out of this service by visiting the Network Advertising Initiative opt-out page.
The browsers of most computers, smartphones and other web-enabled devices are usually set up to accept cookies. If your browser preferences allow it, you can configure your browser to accept all cookies, reject all cookies, or notify you when cookies are set. Each browser is different, so check the "Help" menu of your browser to learn about how to change your cookie preferences.
However, please remember that cookies are often used to enable and improve certain functions on our website. If you choose to switch certain cookies off, it will affect how our website works and certain functionality may not work. More information about cookies can be found on allaboutcookies.org
