RUTLAND PARTNERS LLP

PRIVACY POLICY

Rutland Partners is committed to protecting and respecting your privacy.

This Privacy Notice together with our Terms of Use and any other documents referred to in it sets out how Rutland Partners collects, uses, maintains and discloses Personal Data, including any information provided through our website(s) (the “Website”).

Your privacy is of the utmost importance to us. Please read this Privacy Notice carefully to understand our views and practices regarding your personal data and how we will treat it.

Whenever you provide personal information, we are legally obliged to use it in accordance with the laws concerning the protection of personal information.

Who we are

RUTLAND PARTNERS LLP is registered in England and Wales with company number OC305965 whose registered office address is Thomas House, 84 Eccleston Square, London, SW1V 1PX (“Rutland Partners”).

For the purposes of the Data Protection Act 1998, the General Data Protection Regulations and any other applicable data protection and privacy laws and regulations (“Data Protection Legislation”), Rutland Partners will be the ‘data controller’ for all personal information that we determine the means and purpose of processing. We are registered with the Information Commissioners Office under registration number ZA270350.

By “Personal Data” we refer to information collected or held by Rutland Partners, that identifies and relates to you as an individual.

Information we may collect

We may collect personal information about you when you request our services, including:

• your name;
• postal address;
• date of birth
• financial information, which may include bank details, NI number, UTR and financial history;
• information regarding the services you request;
• information collected from a personal utility bill or requested ID documents;
• supplementary information you provide us about yourself when contacting us;
• email address; and
• telephone numbers (including mobile).

We may also collect technical information about you when you visit the Website. This information may include the Internet protocol (IP) address used to connect your computer to the Internet, your browser type and version, time zone setting, operating system and platform, browser plug-in types and version, the full URL clickstream to, through and from the Website, page response times, download errors, length of visits to certain pages, page interaction (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.

The collected information is used to provide an overview of how people are accessing and using the Website. It is not used for any additional purpose, such as to profile those who access the Website.

We may also receive details about you from third parties who have provided us with your information under appropriate legal grounds for sharing. We will always inform you of how we received your information when we contact you.

If you fail to provide us with Personal Information

You always reserve the right to withhold your Personal Information but this may affect how we provide our services to you.

Where we need to collect personal data by law, or under the terms of an agreement 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. In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.

What do we do with the information we collect?

We will use your personal information for a number of purposes including:

• To initiate and process the investment services you request;
• To ensure our records are complete and accurate;
• To comply with our legal and regulatory obligations;
• To provide the specific services agreed by you;
• To undertake performance analysis and management of the business;
• To give you information that you request from us and to improve our services;
• To notify you about changes to our services;
• To allow us to operate the Website efficiently;
• Any relevant troubleshooting, testing or statistical analysis as appropriate; and
• To keep the Website secure.

Where we have your permission to do so, we may also use the information collected to:

• provide you with information about our services that we offer via promotional communications; and
• keep you up to date with features on the Website.

However, you can opt-out of any of these data uses at any time by emailing privacy@rutlandpartners.com.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

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 requirements.

Legal basis of processing

We will only process your information for as long as we have a relevant legal basis to do so. This is usually in order to provide you with the contractual services you have requested from Rutland Partners or if you have provided us with adequate consent to process your information for other purposes.

If we choose to process your information under the legal basis of legitimate interests, we will always inform you of our legitimate business interest and your right to object.

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 and that reason 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 at privacy@rutlandpartners.com.

Protecting your information

We are committed to ensuring that your information is secure and we have procedures in place to try and prevent any unauthorised access or disclosures and to safeguard and keep secure the information that we collect online.

All the Personal Data collected by us and stored electronically is held on a secure server in the EEA only. Where required, this information is encrypted for additional security. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to Personal Data only for those employees who require it to fulfil their job responsibilities.

Rutland Partners holds a Cyber Essentials certification as part of our ongoing commitment to ensure adequate cyber security.

However, you should be aware that providing information over the internet can never be guaranteed as being completely safe and if you choose to send such information to us via the internet, you do so at your own risk.

Transfer of data outside of the EEA

We shall not transfer any personal data to any country outside of the EEA unless we ensure that such personal data is subject to an adequate level of protection and appropriate legal safeguards in accordance with Data Protection Legislation.

Sharing your information with others

Please be assured that we will not share your information for any other reason unless we are required by law or permitted to do so under this Privacy Notice. The main circumstances in which we will be permitted or required to disclose this by law will be by court order, to government bodies and law enforcement agencies. However, sometimes we may share your information with third parties in the following ways:

• we may use carefully selected sub-processors to help us collect, store or manage your information. This will always be managed under the terms of a written data processing agreement;
• analytics and search engine providers that assist us in the improvement and optimisation of the Website; and
• if Rutland Partners is acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

We process your personal information for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your personal information in this way, the relevant seller or buyer of our business may not be able to provide services to you.

Access to your Personal Data

You have rights in relation to any Personal Data that we hold about you. If you wish to access your Personal Data you may make a formal subject access request by contacting Rutland Partners.

The information you request must relate to you or another person for whom you have authority to act on their behalf. Rutland Partners will require a confirmation of your ID prior to providing any information about the data we hold. If you are unable to provide sufficient information to prove your ID, Rutland Partners reserves the right to refuse your request for access to Personal Data. The rights you have in relation to the Personal Data we hold regarding you are:

• the right to rectify any inaccuracies in the information we hold;
• the right to erasure of information in specific circumstances;
• the right to request transfer of your information to another controller; and
• the right to object to processing in certain circumstances.

If you have provided us with consent to process your information, you always reserve the right to withdraw this consent via the method detailed in the paragraph below. We are committed to ensuring that your wishes are respected and upon notification that you wish to withdraw your consent, Rutland Partners will immediately cease processing the information in question.

Please send your request to Rutland Partners by emailing at privacy@rutlandpartners.com. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to this Privacy Notice

We may change this Privacy Notice at any time to ensure it always accurately reflects the way we collect, use and safeguard your Personal Data.

Please check this notice from time to time to ensure you are aware of any updates we may have made to our Personal Data handling practices. The date of the changes will be listed in the ‘Last updated’ section below. We will endeavour to notify all of our current clients of any updates to this notice via email and we will post the relevant announcement on our website homepage.

We recommend that you print a copy of this page for your reference.

Cookies

This Website uses cookies to help us recognise different users of the Website and to provide users of the Website with a good experience when using it. Please see our Cookies Policy below for further information.

How can you make a complaint?

Please note that if you are not satisfied with the processing of your personal data as set out in this Privacy Notice, please contact us at privacy@rutlandpartners.com.

You have the right to issue a complaint directly with the Information Commissioners Office, the data protection supervisory authority for England and Wales (https://ico.org.uk/concerns/).

Contacting us

Please contact us at privacy@rutlandpartners.com if you have any questions, comments or requests regarding this Privacy Notice.

Last updated: 17 March 2022

COOKIES POLICY

Our website www.rutlandpartners.com (the “Website”) uses cookies to distinguish you from other users of the Website. This helps us to provide you with a good experience when you browse the Website and also allows us to improve the Website.

If you do not consent to the cookies used on the Website, you must disable them or refrain from using the Website.

What is a Cookie?

A cookie is a small file of text and numbers which is created by the Website. When you visit the Website, the cookie is attached to your computer or other device but does not access your hard drive on your computer. If you revisit our Website, the cookie will be recognised by the Website.

Cookies are widely used to do things such as identifying the type of device you are using (PC or a phone for instance) to access websites, store items in the shop basket and help you navigate pages more easily. They can also help you translate web pages, log into the Website or remember your region or country preferences. Cookies can also be used to help us find out how people use the Website and the number of visitors to it.

Cookies are not harmful to your computer and do not pose a security or virus risk to your computer, nor do they store any personal identifiable information about you. If you would like to know about what cookies are, or how to control or delete them, then you may choose to visit www.aboutcookies.org for more detailed guidance.

Cookies Which We Use

There are several types of cookies which we may use from time to time:

Necessary cookies: These are necessary for the Website to function. If you do not allow these cookies, the Website will not operate for you, for example being able to add an item to the Website shop basket.

Performance cookies: These cookies allow us to recognise visitors to our Website and to see how they use it. We also use these cookies to help us improve the way in which the Website works, for example, making it easy for people to find what they are looking for.

Functionality cookies: These are used to remember you when you revisit our Website, and enable us to personalise content for you, welcome you by name or to remember your preference such as your language choice or region.

Targeting cookies: These cookies will record your visit to the Website, pages you visited and any links that you followed. Generally, this information is used to make the Website and any advertising relevant to your interests, but it may also be information which we share with a third party.

The cookie specifications for this Website are as follows.

Cookies Used

We use cookies to collect information about how visitors use and access the Website. This information is used to compile reports to help us improve the site performance and your user experience.

Cookie declaration

This is a full list of the Cookie used on this website.

Cookies are not used to:

• Collect any personally identifiable information.
• Collect any sensitive information.
• Pass data to advertising or affiliate networks.
• Pass personally identifiable data to any third parties.
• Pay any sales commissions.

How Can You Manage Cookies?

Most browsers automatically accept cookies, but you can usually disable cookies by adjusting your browser settings. Please note that if you do turn cookies off, this may limit the service that we can provide to you and may affect your experience of the Website.

If you have any queries concerning your personal information or any questions on our use of cookie data, please contact us at contact@rutlandpartners.com.

Last Updated: 4 April 2022