Privacy Policy

This privacy statement applies to the asset and fund management services provided to UK customers of Trading Platforms UK, as well as the optional management services supplied by Trading Platforms UK and its affiliates.

This Privacy Policy is also valid to Trading Platforms UK's investment trusts and funds, unless the documents relating to your investment in a specific investment trust or fund state otherwise.

Trading Platforms UK and its affiliates are committed to protecting any personal information shared with them. You may rest confident that personal information will only be gathered and used as needed, appropriate, and legal to provide you with the agreed product or service, in accordance with relevant privacy & data protection rules.

Our Privacy Policy explains what personal information you provide and how we use it. It also explains who we can share your personal information with, why, and how you may opt-out of certain activities.

We update our Privacy Policy on a regular basis. We may have to modify this Privacy Policy from time to time in order to comply with new laws or comply with court orders, for example. If major modifications are made to where your personal information is handled, we will let you know via e-mail.

How to contact us

Please use our 'Contact Us' page if you have any queries about our Privacy Policy or the information we collect or use regarding you.

Information we collect and use

We collect and use information about you, including:

• Information about yourself, such as your name, birth date, and contact information
• Information connected to your product or service, like your bank account details
• Information about your contact with us, such as phone calls, meetings, letters, and emails
• Information that's automatically collected using cookies when visiting our website

Sensitive personal information, such as health-related data will not be collected and used by us. When we collect and utilise sensitive personal information, it will only be done so when it is necessary to provide the product or service you have requested or to fulfil our legal obligations, and where you have given your consent to do so.

Where we collect your information

Personal information may be collected directly from you or acquired from a variety of sources, including:

• Application forms for products or services
• Emails or letters
• Phone conversations
• Meetings with us
• Sponsored competitions
• Research surveys
• Event registrations
• Online services, like social media, websites, and client portals

Personal information about you may also be collected from commercial or publicly available sources, including business directories and other places to check or improve the data we have, like your address or (such as your phone number), or to give better contact information if we are cannot contact you directly.

The reason we collect and use your information

We are committed to protecting your privacy. We will collect and use only information that is personal to you when it is required, fair, and legal to do so. We will gather and utilise your data only if we can fulfil one of the lawful processing criteria set out in the data protection regulations. This will be the case where:

• It's needed to provide the goods or service you requested; for example, if you wish to invest in one of our funds or products, which may include your name, address, birth date, and bank account details
• Because it's critical for us to fulfil our legal or regulatory obligations, such as sending you Annual Statements, notifying you about changes to the Terms and Conditions and detecting and preventing fraud
• It's in our best interests to provide you with the correct information and assistance so you are aware of your options that can optimise your product or investment.
• We may use your contact information to send you marketing messages and new products and services as a result of our legitimate business interests, such as communicating with you about relevant news regarding the goods and services we offer.
• We will always conduct an analysis to ensure that this use of your personal information is not excessive or more intrusive than it needs to be unless the processing is in our legitimate interests.
• You have given us your consent to use your information in this manner, as indicated by the following sentence. For example, if we collect and use sensitive personal information or for certain sorts of direct marketing

Automated decisions are made from time to time based on personal information we hold or the data we may collect and use from others about you. These automated decisions can have an impact on the products, services, or features we provide now or in the future. We make automated choices as follows:

• Tailoring products and services: for example, placing you in groups with similar clients to help us decide which goods and services we may provide to meet your requirements
• Designing and enhancing our online services to assist you to get the most out of your investing experience

It may be that we will not be able to provide you with some of our goods or services if you do not want us to collect and use your personal information in these ways.

Who we share your information with and why

We may share your information with individuals, groups, or organisations outside of our organization for the following

reasons:

• We may collaborate with partners who help us in delivering the products or services you've agreed upon.
• For the purpose of performing a credit check and ID verification, credit and identity check firms are used.
• We have selected third parties to assist us in the delivery of the items and services we provide to you and other customers. For example, a research, consultancy, or technology firm that assists us in enhancing our service to you
• Companies who help us connect with you, for instance, an internet service provider
• Our regulators in the UK
• The agencies that we provide information with (or where they ask for it) in the detection and prevention of crime

We will only use your personal information as described below in accordance with our obligations to keep your data safe and secure.

Where your information is processed

The majority of your data is processed in the United Kingdom or the European Economic Area (EEA). Some of your data, on the other hand, maybe handled by us or third-party partners located outside of the UK and EEA. We take extra measures to safeguard your data, such as storing it on servers within the European Economic Area (EEA) or outside of the United Kingdom and the European Union (EU/EEA).

How we protect your information

We take information security and compliance very seriously, and we try to follow the rules at all times. Personal information will be protected in accordance with our data protection laws in any case where it is gathered, recorded or utilized. Our information security controls are in place to safeguard your data from accidental, negligent, or intentional acts. Our security measures follow industry rules and best practices while also providing a secure control environment that manages risks to the confidentiality, integrity, and availability of your information - whether it is handled by us or a third party on our behalf. We also take your data security seriously. Storing or moving information over the Internet is a sensitive and confidential activity, so our staff must undergo annual training on this. We use both internal and external audits as well as third-party experts to conduct regular, independent assurance and benchmarking testing across our organisation to ensure that our security control environment is effective.

How long we keep your information

We will keep your personal information and copies of records we make (e.g., conversations with you) while you are a [potential] customer or client of ours to provide you with the service or product promised, as well as to satisfy our legal and regulatory obligations. Despite this, even if you are no longer associated with us, we are required to maintain data for various legal and regulatory purposes. The duration of time will differ, but we continually examine our retention periods to ensure they are in accordance with all legislation and rules.

Your rights

You have several rights under data protection legislation that may be exercised in certain situations. These are:

Right to be informed

You have the right to receive clear and simple information on what personal data we collect, why we collect it, and with whom we share it - this is covered in our Privacy Policy and privacy notifications.

Right to restrict processing

You can request that we stop or suppress the processing of your personal information if there are specific reasons. This allows us to continue to store your information - but just for the purpose of not using it in the future for those reasons you have restricted.

Right of access

You have the right to know what information we collect about you and how it will be used. You may request a copy of your personal data by submitting a data subject access request. Use our Contact Us if you wish to enquire more about submitting a data subject access request.

Right to data portability

For your own reasons, you can request a copy of your personal information for use on other services. In some situations, you may move, copy, or transmit the personal information we have with another firm in a safe and secure manner. For example, you were transferring your assets to an additional discretionary investment manager or ISA manager.

Right to request that your personal information be rectified

You may demand that incorrect or missing personal information be updated if you believe it is accurate and complete.

Right to request erasure

If there is no compelling reason for Trading Platforms UK to retain your data, you may request it to be removed or deleted.

Right to object

You have the right to object to us processing your personal information if it is based on our legitimate interests, for direct marketing, or for research and statistics.

Right to not be subject to automated decision making including profiling

You have the right to ask Trading Platforms UK to:

• Give you information about how your personal data is being handled.
• Consider the possibility of human intervention or challenge a decision where processing is entirely automated
• Examine our automated decision making and profiling systems on a regular basis to ensure that they are functioning as intended.