EFGAM Privacy Policy

Website Privacy Notification

1.    Introduction

This Website Privacy Notification applies to all physical persons (“you”) who have access to this website (“Website”). In this Website Privacy Notification “we” refers to EFG Asset Management (UK) Limited (Park House, 116 Park Street, London W1K 6AP, Tel. +44 207 491 9111) (“EFGAM”), who is the controller of your personal data. The EU Representative for EFGAM is EFG Bank (Luxembourg) S.A. (https://lu.efgbank.com/).

This Website does not seek to collect personal data from individuals under the age of 18. Individuals under the age of 18 should receive permission from their parent or legal guardian before providing any personal data to us.

2.    Types of personal data collected and processed

The types of personal data we collect and process depends, among other factors, on how you are using this Website. If you are only using this Website for information purposes, i.e. you do not otherwise transmit data to us, EFGAM will only gather the personal data that is forwarded to its servers by your browser. In particular, EFGAM will gather the access data that it requires for technical reasons to be able to display this Website and warrant the stability and security of the same. This access data includes the IP address, date and time of your visit, access status/HTTP status code, the referred URL (previously visited page), browser type and version, operating system.

In addition, we will also receive your personal data if you reach out to us using the contact form on this Website. Personal data in this context includes e.g. name, address, e-mail, telephone number, date and time of your request and content of your request.

3.    Sources of personal data

We collect your personal data:

  • Directly from you; and
  • Third parties provide about you. If you transmit personal data about third parties (e.g. your spouse, relatives etc.), you are responsible for complying with the applicable data protection provisions. This may require obtaining the consent of these third parties for the transmission of this data.

Moreover, EFGAM collects your personal data automatically, through relevant systems used in connection with your website consultation (e.g. location data, cookies, log data). For instance, EFGAM may collect your personal data from the device through which you access this Website. Finally, EFGAM uses tracking technology to collect data about you. Please refer to the Cookie Policy for more information on how EFGAM uses cookies and other similar tracking technologies. 

4.    How we use personal data

The situations in which we may process your personal data are listed below:

  • To process your request, if you contact us using the contact form of this Website;
  • To establish a basis for future information on the products and services offered by us;
  • To comply with any applicable laws and regulations;
  • To comply with the request or requirement of any court of any relevant jurisdiction or any relevant authority; and
  • For use in connection with any legal proceedings or regulatory action (including prospective legal proceedings/ regulatory action) and for obtaining legal advice or for establishing, exercising or defending legal rights.

The situations in which EFGAM may process your personal data are listed below:

  • To provide you with access to this Website;
  • To administer technically and develop this Website; and
  • To carry out statistical and other analysis regarding the use of this Website.
5.    Recipients of your personal data

We may disclose personal data in the situations described below:

  • To third parties who provide services to us (e.g. IT companies, telecommunication providers);
  • To our affiliates, only to the extent necessary to process your request, if you contact us using the contact form of this Website;
  • To any court of any relevant jurisdiction or any relevant authority;
  • To public authorities, regulators or governmental bodies or other third parties, when required by law or regulation; or
  • Otherwise if you consent to such disclosure.
6.    Legal basis for using your personal data 

We will only use your personal data when the law allows us to. Most commonly and depending on the situation in which we will use your personal data, we will use your personal data in the following circumstances:

  • Where you have given your consent (e.g. in the form of the clear affirmative action of sending us a request by using the contact form of this Website);
  • Where we need to comply with a legal obligation; 
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (e.g. ensuring compliance with our policies and procedures); and
  • Where necessary for the establishment, exercise and defence of legal claims.
7.    Overseas transfers

We may transfer the personal data we collect about you to countries other than the country of our incorporation or the country in which the data was originally collected. Other destination countries may not have the same laws on personal data as the country in which you initially provided the data.

When we transfer your personal data to other countries, we will protect that data as described in this Website Privacy Notification and in accordance with applicable law. If necessary, we require the recipients referred to in section 5 above to comply with appropriate safeguards designed to protect personal data. 

8.    Will your personal data be used for automated decision-making? 

As a rule, we do not use fully automated decision-making (i.e. a purely automated process that would produces legal effects concerning you or significantly affecting you) in the context of your access to this Website or of your use of a form to contact us. If such processes are used in isolated cases, you will be informed separately, to the extent this is required by law. 

9.    Do you have an obligation to provide personal data? 

In the context of this Website, you will need to provide the personal data that is required for its use for technical or IT security reasons. If you do not provide this data, you will not be able to use this Website.

In the context of contacting us by form, you are only required to provide the personal data without which your inquiry cannot be processed by us.

10.    Your rights in connection with personal data

Under certain circumstances and subject to applicable law, you have the right to:

  • 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.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
  • 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 exercised your right to object to processing (see below).
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. 
  • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Where personal data is processed by automated means and:
    • where we process your personal data on the basis of your consent; or
    • where such processing is necessary for entering into or performing our obligations under a contract with you, 
  • request the transfer of your personal data to you or to another party (also known as “data portability”).
  • Where we process your personal data on the basis of your consent, you may withdraw that consent at any time. If you do not give your consent or withdraw your consent this may affect our ability to provide you with services. Please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
  • In certain circumstances, request not to be subject to automated decision-making, including profiling.

Certain of these rights are not absolute under the applicable legislation (as sometimes there may be overriding interests that require the processing to continue, for example); nonetheless we will consider your request and respond to you. 

Finally, you have the right to lodge a complaint with the supervisory authority in the jurisdiction where you live or work, or in the place where you think an issue in relation to your personal data has arisen.

11.    Retention of personal data

We will retain personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory, reporting or internal policy requirements. To determine the appropriate retention period for personal data, we consider the applicable legal requirements, as well as the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized 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, as well as the time periods, during which such personal data may need to be retained as evidence in an actual or potential judicial context.

12.    Processing of personal data for distributing EFGAM material

If you ask to be added to any of our distribution lists for any material, we will use your data for that purpose. You may withdraw your consent at any time by clicking on an “unsubscribe” link which is offered at the bottom of every email we send or by contacting us, as per section 13 below.

13.    How to contact us 

If you have a query regarding the processing of your personal data or you would like to exercise any of your rights in connection with your personal data or receive a copy of the safeguards designed to protect personal data in the case of transfer of your personal data outside the EEA or obtain further information on the retention periods of personal data, please contact [email protected].

14.    Changes to this Website Privacy Notification

We may revise this Website Privacy Notification from time to time. The most current version of this Notification will govern our processing of your personal data and will always be at this Website. By continuing to access and use this Website you agree to be bound by the Website Privacy Notification currently in place at the time of each visit.