Privacy notice
This notice was updated in March 2024 following changes to the Artemis Cookie Policy and international data transfers.
The following privacy notice (the “notice”) is issued by Artemis Investment Management LLP and any holding company or subsidiary company (including but not limited to Artemis Fund Managers Limited) as defined in section 1159 of the Companies Act 2006, referred to in this notice as "we", "our", "us" or "Artemis".
Please note that a separate privacy notice is issued by Artemis Funds (Lux) - view the Artemis Funds (Lux) privacy notice; by Artemis UK Future Leaders plc - view the Artemis UK Future Leaders plc privacy notice;and by Murray Income Trust PLC - view the Murray Income Trust PLC privacy notice.
We act as data controller in respect of the processing of the information we gather about you.
In this notice, “personal data” includes any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Artemis or its representatives or service providers. We collect and use personal data and where applicable this may include information related to your spouse/partner, directors, partners and owners (your “representatives”).
Certain personal data is considered particularly sensitive and is subject to stricter rules regarding its processing. These categories of personal data are referred to as “special category data” and include any personal data relating to the racial or ethnic origin of the data subject; their political opinions; their religious (or similar) beliefs; their physical or mental health condition; details of criminal offences or criminal convictions (including the commission or alleged commission of any offence, any proceedings for any offence committed or alleged to have been committed and the disposal of such proceedings or the sentence of any court in such proceedings) and genetic and biometric data.
This notice applies to any personal data we receive from you, create or obtain from other sources and explains how it will be used by us. It is important that you take the time to read and understand this notice so that you understand how we will use your personal data and your rights in relation to your personal data.
If you fail to provide certain information when requested, we may not be able to perform any contract we may have with you, or we may be unable to deal with you.
If you have any questions regarding our use of personal data or this notice, including any requests to exercise your legal rights, you can contact our Privacy Officer using the details in the “Contact us” section below.
Personal data that we collect from you
We will collect and use the following personal data about you and your representatives:
Information you give us
- This is information about you (and your financial adviser/representative or beneficial owner which may include a child for whom you have parental responsibility, if applicable,) that you (and/or your financial adviser/representative, if applicable) give us by filling in forms or by corresponding with us by phone, e-mail, electronic messaging, voice and/or videoconferencing or otherwise. The information you give us may include your name, address, e-mail address and phone number, financial and debit card information, credit history, identification records.
Information we collect or generate about you and your representatives
- We sometimes record telephone conversations, electronic messaging, voice and/or video conferencing and monitor email communications to resolve complaints, improve our service and in order to comply with our legal and regulatory requirements. We generate data to improve our service, to manage, administer and take decisions about your account, and to help us market our products. The information we capture in this way may include your name, address, e-mail address and phone number, financial and debit card information, credit history and identification records.
Information we receive from other sources
- Verifying your identity – we will use information provided by third parties (e.g. fraud prevention agencies) when verifying your identity and when carrying out anti money laundering checks. Such information may include some details about any criminal convictions and any allegations regarding criminal activity that relate to you, as well as details of your status as a politically exposed person. It may also include your nationality and identification records (e.g. passport information).
- Cookies - when you visit the Artemis website, cookies are used to collect information about the services that you use, and how you use them. These are used to monitor and improve our services, and may be used to help us market our products to you. For more information on the cookies used by Artemis please see our Cookie Policy on our website.
- Intermediaries – we may receive information from dealers, brokers and introducers for the purposes of entering in to and administering your agreement. This may include your name, address, e-mail address and phone number, financial and debit card information, credit history and identification records.
- Public databases – we may obtain information about you from public databases.
For the avoidance of doubt, in the case of institutional investors, personal data includes personal data of individuals linked to such institution.
When you are no longer our client, we continue to process your information as described in this notice, subject to our record retention policies and applicable law.
Purposes for which we process your personal data and the legal grounds for this
We may process your personal data in line with one of the following legal bases:
In order to perform our obligations under our contract with you, such as:
- managing your investments and administering your account(s);
- verifying your information, including your identity as part of our client onboarding process;
- to communicate with you in order to provide you with services or information about Artemis and our products and services; and
- to make payments or distributions.
Where we have obtained your consent, such as:
- to send promotional information about our products and services via the methods you specify (to the extent such consent is required by law); and
- to allow events and webinars to be delivered.
To comply with our legal and regulatory obligations, such as:
- to fulfil our legal, regulatory, and compliance obligations, including identity verification, know your client (KYC), terrorist financing, anti-money laundering, and sanctions checks;
- to respond to governmental (including tax authorities) and regulator inquiries or examinations, court orders and legal investigations; and
- to establish, exercise or defend our legal rights and / or for the purpose of (or in connection with) legal proceedings.
The use of your personal data is necessary for our legitimate business interests, such as:
- allowing us to effectively and efficiently manage and administer the operation of our business;
- maintaining compliance with internal policies and procedures;
- marketing our products and services (where consent is not required);
- for ongoing review and improvement of the information on the Artemis Website, including analysing the data of visitors to our site and capturing metrics about the journey of users, and preventing any potential disruptions or cyber-attacks;
- enforcing the terms and conditions of any agreement we have with you; and
- the recovery of outstanding debts from you.
We will only use personal data for the purposes for which we collected it or as otherwise described in this notice.
Transfer of personal data outside the UK and European Economic Area ("EEA")
On 28 June 2021, the EU Commission announced that it had ruled that the UK’s data protection regime is adequate under the EU’s General Data Protection Regulation. The UK government has also adopted adequacy regulations in relation to the EU/EEA regime. This means that most data can continue to flow between the UK and the EU/EEA without the need for additional safeguards. The UK has also adopted adequacy regulations in relation to Switzerland, meaning that the Swiss data protection framework has been assessed as providing ‘adequate’ protection to the rights and freedoms of UK individuals in respect of their personal data. The majority of the information you provide to us will be transferred to and stored on secure servers in the United Kingdom or the European Economic Area. However, from time to time, personal data may be transferred to, stored in, or accessed from a destination outside the EEA. It may also be processed by authorised staff operating outside of the EEA who work for one of our suppliers.
Where we transfer your personal data outside the UK and 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 UK and EEA. This can be done in a number of ways, for instance:
- Adequacy Decisions - the country that we send the data to might be approved by the UK as providing ‘adequate’ protection for people’s rights and freedoms in respect of their personal data;
- UK International Data Transfer Agreement (IDTA) or Addendum to EU Standard Contractual Clauses (SCCs); SCCs can be used which the sender and the receiver of the personal data can both sign up to. These clauses comprise a number of specific contractual obligations designed to provide legal protection to individuals when their personal data is transferred to ‘third countries’;
- The recipient of the data might be a signatory to binding corporate rules;
- Other safeguards, which may include:
- Approved codes of conduct;
- Approved certification mechanisms; and
- Legally binding and enforcement instruments between public authorities or bodies.
In other circumstances the law may permit us to transfer your personal data internationally. In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.
You can obtain more details of the protection given to your personal data when it is transferred internationally by contacting us in accordance with the “Contact us” section below.
How long we keep your personal data
How long we hold your personal data for will vary. We will only retain 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.
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 unauthorized use or disclosure of your personal data;
- the purposes for which we process personal data; and
- whether we can achieve those purposes through other means, and the applicable legal requirements.
Your rights
You have a number of rights in relation to the personal data that we hold about you. These rights include:
- the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
- the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so;
- in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those 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;
- the right to request that we rectify your personal data if it is inaccurate or incomplete;
- the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
- the right to request that we restrict our processing of your personal data in certain circumstances. Please note that there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request;
- the right to object to our processing of your personal data where we process your personal data in line with our legitimate business interests. Please note that there may be circumstances where you object to our processing of your personal data but we are legally entitled to refuse that request;
- the right to object to any automated decision making (including profiling) which we conduct based on your personal data, which significantly affects you. Please note that there may be circumstances where you object to us conducting automated decision making but we are legally entitled to refuse that request;
- the right to object to the processing of your personal data in certain circumstances; and
- the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.
You can exercise your rights by contacting us using the details set out in the “Contact us” section below.
You can find out more information about your rights by contacting the data protection regulator, the Information Commissioner, or by searching its website.
Changes to our privacy notice
We keep our privacy notice under regular review. Any changes we make in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy notice.
Contact us
We are registered in the UK and our registered address is at Cassini House, 57 St. James's Street, London, SW1A 1LD.
Please contact us if you have any questions about our privacy notice or personal data we hold about you:
- Write to us at our address
Artemis Investment Management LLP, Cassini House, 57 St. James's Street, London, SW1A 1LD
- By telephone on
020 7399 6000
- By email to
[email protected]
Within our group, we also have Artemis entities based in Germany and Switzerland. If you are based outside the UK and would prefer to contact our German or Swiss entities in connection with your data privacy rights, please write to:
- AI Management (Europe) GmbH
Maximilianstraße 13, 80539 Munich, Germany
- Artemis Investment Services (Switzerland) GmbH
Talacker 41, 8001 Zurich, Switzerland
You can also contact these entities by email at [email protected].
