Privacy Policy

Website Privacy Policy

Who are we?

Seilern Investment Management Limited (“SIM”), Seilern International AG (“SIAG”) and Seilern Investment Funds plc (“SIF”, and collectively with SIF and SIAG, “Seilern”, “we”, “us” or “our”) are committed to maintaining, protecting and respecting your privacy. You can visit our website without telling us who you are or revealing any information about yourself. However, if you do give us any personal information about yourself or others, we promise to treat it securely, fairly, and lawfully. This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website and if you opt-in to receive our newsletters.

The data controller

The data controller of the personal data you submit to this site is Seilern. We are responsible for, and control the processing of, your personal information.  Further information can be obtained by contacting us. (See the “How to Contact Us” section below.)

The Data Subject

What our policy covers

This Privacy Policy (the “Privacy Policy”) covers without limitation, the home page, splash page and all other pages under the domain name https://seilernfund.wpengine.com (“our Site”) and all content contained on those pages. This Privacy Policy (together with our Terms of Use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Information We May Collect From You

Information you give us

You may give us information about you by filling in forms on our Site or forms that we have given to you to fill in or by corresponding with us via phone, email, facsimile or otherwise including providing information to us for marketing reasons such as subscribing for publications or for access to certain advertising materials. This includes information you provide when you subscribe to a service and when you report an issue with our Site. The information you give us may include:

• Your name;
• Your email address;
• Your phone number;
• Your date of birth;
• Your client number or unique investor identification number;
• Your gender;
• Your financial information;
• The information about your investment strategies and objectives; and
• Any further personal information you provide to us: such as through subscription documents and other onboarding documents (that may include tax ID numbers or other government-issued identification numbers, to the extent permitted by applicable law), and other forms and documents you send us in connection with a product or application for a product.

Information we collect about you

Each time you visit our Site we may automatically collect the following information:

• Technical information including the internet protocol (“IP”) address used to connect your computer to the internet, your log-in information, browser type, and version, browser plug-in types and versions, time zone setting, operating system, and platform; and
• Information about your visit, including the Uniform Resource Locators (“URL”) clickstream to, through, and from our Site (including date and time); items you searched for; page response times; download errors, length of time spent on pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page and any phone number used to call us.

Information we receive from other sources

We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment, and delivery services, advertising networks, analytics providers, and search information providers. We receive personal data from these third parties from time to time. We may combine this information with the information you give to us and the information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Monitoring and recording communications

We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention, and compliance with our obligations under applicable legislation.

Personal information about other individuals

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

• Give consent on his/her behalf to the processing of his/her personal data;
• Receive on his/her behalf any data protection notices; and
• Give consent to the processing of his/her personal data which may include all of the information listed above.

Cookies

Our Site uses cookies to distinguish you from other users of our Site and to make the Site work more efficiently. A “cookie” is a small file of letters and numbers that a website can store on the browser or hard drive of your computer. Some cookies are deleted when you close down your browser. These are known as “session cookies”. Others remain on your device until they expire, or you delete them from your cache. These are known as “persistent cookies” and enable us to remember things about you as a returning visitor.

For further information about how to control and disable cookies in your browser please visit: www.aboutcookies.org.uk.

Alternatively, you can search the internet for other independent information on cookies. Cookies may be required to allow you to access and participate in certain areas of our Site. The cookies we store on your computer do not contain any personally identifiable information. There are different types of cookies used for different purposes. The cookies our Site uses are listed below under the cookie categories recommended by the International Chamber of Commerce.

Strictly necessary cookies

These are cookies that are required for the operation of our Site. They include, for example, cookies that may enable you to log into secure areas of our Site or to fulfil an action requested by you when you are logged on. Without these cookies, we are unable to provide some products or services that you might request. Other strictly necessary cookies keep our Site secure. Even if you say no to cookies on this Site, we will continue to use these essential cookies.

Performance or analytical cookies

These cookies allow us to improve our Site by recognising and counting the number of visitors to our Site and to see how visitors move around our Site while they are using it. These analytics will help us improve the way our Site works, for example by letting us know how we need to adapt our Site to ensure users can easily find what they are looking for. If you disable these cookies, you will still be able to use most of our online services, but some might not work as you expect if you do not allow us to store and access cookies on your device.

Cookies we use 

Website: https://seilernfund.wpengine.com/

Function	Cookie Name(s)	Further information
Keeping an anonymous record of how visitors use the website	__utma __utmb __utmc __utmz	The Google Analytics software is described at: http://www.google.co.uk/intl/en/analytics/privacyoverview.html To opt out of being tracked by Google Analytics across all websites, visit: http://tools.google.com/dlpage/gaoptout
Remembering Google Analytics choice	gainc	Determines whether the user wants Google Analytics cookie to run.
Allowing the server to identify whether the browser is using Javascript	has_js	Identifies whether a browser has Javascript enabled to display Javascript elements or go to non-Javascript .
Allowing the server to maintain a session for the duration of a user’s visit to the Seilern Invest website	PHPSESSID	This cookie is essential for functions such as forms that depend on visiting pages or taking actions in a particular sequence. It will be deleted when you close your browser, or after a period of inactivity. More information on sessions is available at: www.php.net/

Managing and blocking cookies

If you want to remove any cookies already set, you can do so from your browser. You can find out how to do this by going to the help menu in your browser or by visiting www.aboutcookies.org.uk or by searching the internet for other independent information on cookies. You can also block cookies from your browser. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site.

How we use your information

We use information which you have given to us and we have collected and hold about you in the following ways:

• To carry out our obligations arising from any contracts entered into between you and Seilern and to provide you with the information, products and services that you request from us;
• to communicate with you (including the mailing, in physical or electronic format, of periodical reports, notices or other communications that are necessary for the functioning of our relationship);
• To comply with our legal and regulatory obligations such as to carry out identity and anti-money laundering checks (where applicable);
• To provide you with information about other products and services that we offer that are similar to those that you have already purchased or enquired about;
• To facilitate our internal administrative process and to keep a record of the services you have subscribed to
• To provide you, or permit selected third parties to provide you with information about products or services we feel may interest you;
• To notify you about changes to our service;
• To improve our Site to ensure that content from our Site is presented in the most effective manner for you and for your computer or device;
• To administer our Site and for internal operations including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• To allow you to participate in interactive features of our service, when you choose to do so;
• As part of our efforts to keep our Site safe and secure; and
• To measure or understand the effectiveness of marketing communications, advertising, and or financial promotions we serve to you and others, and to deliver relevant marketing communications, advertising, and or financial promotions to you.
• for any other purpose which you have specifically consented to when providing the information such as through a subscription form or other contractual document.

If you fail to provide personal data where it is required under the law or contract

Where we need to collect personal data by law, or under the terms of a contract 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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, cease our business relationship and/or discontinue any communication, but we will notify you if this is the case at the time.

Marketing 

We would like to send you information by post, email, telephone, or text message (“SMS”) about our products and services which may be of interest to you. We will only ask whether you would like us to send you marketing communications when you tick the relevant boxes when you signed up with us or filled out a form on our Site.

If you have consented to such receive marketing communications from us, you can opt out at any time.  See the “Your Rights” section below for further information.

Disclosure of your information

We may share your personal information with:

• Our agents and service providers (including custodians);
• Your agents and representatives and any other person or entity with your prior consent to do so;
• Our business partners in accordance with the “Marketing and opting out” section above;
• Suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• Analytics and search engine providers that assist us in the improvement and optimisation of our Site;
• If we are required to do so by applicable law and regulation or by any governmental, tax, regulatory body or law enforcement agency If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, where requested by regulatory agencies, or in order to enforce or apply our Terms of Use and other agreements or to protect the rights, property or safety of Seilern. This includes exchanging information with other companies and organisations for the purposes of fraud protection.;
• Financial institutions and other similar organisations that we deal with in the course of the services we offer;
• Agents, consultants and advisers. These can be specialist companies who advise us on ways to develop and improve our services and products,
• Tax authorities, regulators and other authorities acting as processors or joint controllers based in Ireland who require reporting of processing activities in certain circumstances.
• Service providers acting as processors based in Switzerland, the UK, and the EEA who provide Customer Relationship Management (“CRM”) and/or cloud computing data storage solutions.   and
• Auditors, accountants, legal counsel or contractors or other advisers auditing, assisting with or advising on any of our business purposes, in any jurisdiction where we operate.

When we share your information with third parties they will process your information either as a data controller or as our data processor and this will depend on the purpose of our sharing the personal data. We will only share your personal data in compliance with the applicable data protection legislation.

A list of our selected third parties with whom we may share your information is available by contacting us.

Where we store your personal data

All information you provide to us is stored on our secure servers located in the UK, with backup outsourced to our IT provider. Data may also be stored in Switzerland and the EEA. Data backup is to cloud and encrypted in flight and at rest. Seilern does not transfer your personal data outside of the UK, the EEA and Switzerland.

Security

• What we do

We will use technical and organisational measures to safeguard your personal data, for example:

• We store your personal data on secure servers;
• We limit access to your personal data to those individuals who have a legitimate need to know, and
• Payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology).

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet.

If you have any particular concerns about your information, please contact us (see “How to Contact Us” section below).

• What you can do

If you want detailed information on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonnline.org. Get Safe Online is supported by HM Government and leading businesses.

How long we store your personal data for

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, accounting, or reporting requirements. Such information may be retained after our client relationship has ceased, and for client identification purposes in accordance with our data retention procedures. You may ask us for further information on these.

To determine the appropriate retention period for personal data, we consider the amount, nature, 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. By law, we have to keep basic information about our customers (including Contact, Identity) for six years after they cease being customers for tax purposes.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. Such anonymised personal data may include aggregate data, this is where we aggregate usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregate data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Other websites

Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Your rights

You have:

• The right to ask us to stop contacting you with direct marketing

Even if you have accepted the processing of your personal data for marketing communication purposes (by ticking the relevant box), you have the right to ask us to stop processing your personal data for such purposes.

Let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone).

You can exercise this right at any time by contacting us at [email protected]

• The right to request a copy of your information

You can request a copy of your information which we hold (this is known as a “Subject Access Request” or “SAR”).

If you would like a copy of some or all of your information, please contact us at [email protected]; and let us know the specific information you want a copy of, including any account or reference numbers, if you have them.

Any subject access request may be subject to a reasonable fee to cover the cost of providing you with details of the information we hold about you.

• The right to correct any mistakes in your information

You can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please contact us at [email protected]; and let us know the specific information that is incorrect and the specific information you want it replaced with.

• The right to request we cease processing your information

You may request that we cease processing your personal data.  If you make such a request, we shall retain only the amount of personal data pertaining to you that is necessary to ensure that no further processing of your personal data takes place.

• The right to lodge a complaint

You have the right to make a complaint at any time:

• In the EEA: Datenschutzstelle Liechtenstein’s supervisory authority for data protection issues (https://www.datenschutzstelle.li/ ), Städtle 38 Postfach 684, FL-9490 Vaduz, Liechtenstein
• In the UK: Information Commissioners Office, https://ico.org.uk/,

When exercising a right we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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.

We would, however, appreciate the chance to deal with your concerns before you approach the relevant data protection authority, so please contact us in the first instance.

• The right to request deletion of your information

You can ask us to erase all your personal data (also known as the “right to be forgotten”) in the following circumstances:

• It is no longer necessary for Seilern to hold that Personal Data with respect to the purpose for which it was originally collected or processed;
• You wish to withdraw your consent to us holding and processing your personal data;
• You object to us holding and processing your personal data (and there is no overriding legitimate interest to allow us to continue doing so);
• The personal data has been processed unlawfully; or
• The personal data needs to be erased in order for us to comply with a particular legal obligation.

Unless we have reasonable grounds to refuse to erase your personal data, all requests for erasure shall be complied with.

Changes to our Privacy Policy

We may change this Privacy Policy from time to time. Any changes to our Privacy Policy in the future will be posted on our Site and where appropriate notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.

How to contact us

If you have any questions about this Privacy Policy or the information we hold about you please send an email to [email protected].

If you are in the UK:  You can write to us at the Data Protection Officer, Seilern Investment Management Limited, Burdett House, 15-16 Buckingham Street, London, WC2N 6DU; or call us on +44 (0) 20 7494 1996.

If you are in the EEA: You can write to us at our registered office:  Seilern International AG, Austrasse 9, Vaduz 9490, Liechtenstein.