Privacy
Privacy notice
This notice was updated on 20 May 2020 to include reference to additional types of personal data (electronic messaging and voice and/or video conferencing) and our use of personal data for marketing purposes.
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.
For the purposes of data protection law, we are a data controller in respect of your personal data. We collect and use your personal data and where applicable this may include information related to your spouse/partner, directors, partners and owners (your “representatives”). Artemis is responsible for ensuring that it uses your personal data in compliance with data protection law.
Our Privacy Officer can be contacted using the details in the “Contact us” section below.
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.
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 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).
- 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.
How we use your personal data
Your personal data may be used by us in the following ways:
Background checks
- to verify your identity as part of our client onboarding process;
- in order to detect and prevent fraud and money laundering;
- in order to identify politically exposed persons.
Products and services
- in order to manage and administer your accounts and holdings;
- in order to provide you with information, products or services you may request from us;
- where you have provided your consent to do so (to the extent such consent is required by law), to send promotional information about our products and services via the methods you specify (i.e. email, post etc).
Reasons we might process your personal data
We will process your personal data in line with one of the following legal bases:
- in order to perform our obligations under our contract with you;
- to comply with our legal and regulatory obligations;
- to establish, exercise or defend our legal rights and / or for the purpose of (or in connection with) legal proceedings;
- for the prevention of fraud; and
- the use of your personal data as described is necessary for our legitimate business interests such as:
- enforcing the terms and conditions of any agreement we have with you;
- the recovery of outstanding debts existing under an agreement with you;
- to send promotional information about our products and services via the methods you specify (where you have provided consent to do so).
Sharing your personal data
We may disclose your personal data within Artemis and to third party service providers in the circumstances described below:
- to ensure the delivery of products or services to you;
- to ensure the safety and security of our data; and
- for internal research and statistical analysis purposes.
We will take steps to ensure that the personal data is accessed only by personnel that have a need to do so for the purposes described in this notice.
We may also share your personal data outside of Artemis:
- in order to enforce or apply the terms of use and other agreements you have with us;
- with an insurer or insurers for administration, claims handling and fraud prevention (which could include passing it to other insurers);
- with any broker or introducer of an agreement with us;
- with tracing and repossession agents;
- if we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes;
- if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer; and
- with third party agents for the purposes of providing services to us.
These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice.
We may also share your personal data outside of Artemis to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation (including disclosures made to credit agencies and Companies House), and to establish, exercise or defend our legal rights.
Transfer of personal data outside the European Economic Area
The information you provide to us will be transferred to and stored on our secure servers in the European Economic Area (“EEA”). However, from time to time, your personal data may be transferred to, stored in, or accessed from a destination outside the EEA. It may also be processed by staff operating outside of the EEA who work for a company in Artemis or for one of our suppliers.
Where we transfer your personal data outside the 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 EEA. This can be done in a number of ways, for instance:
- the recipient of the data might be a signatory to binding corporate rules;
- the country that we send the data to might be approved by the European Commission or a relevant data protection authority;
- the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data
In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA. 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 outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data or binding corporate rules) 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. The retention period will be determined by various criteria including:
- the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
- legal obligations – laws or regulation may set a minimum period for which we have to store your personal data.
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 for direct marketing purposes; 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 at https://ico.org.uk/ (opens in a new window).
Changes to our privacy policy
We keep our privacy policy under regular review. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
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 policy 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 an Artemis entity based in Germany. If you are based outside the UK and would prefer to contact our German entity in connection with your data privacy rights, please write to AI Management (Europe) GmbH, Maximilianstraße 13, 80539 Munich, Germany or e-mail [email protected].
Identity theft and fraud
What is identity theft and fraud?
Identity fraud is where someone impersonates you without your knowledge or consent, or uses your personal information to obtain money, goods or services. More information on the types and incidences of identity fraud is available from the FCA website (opens in a new window), which contains tips on how to protect yourself, what to do if it happens to you and contact details of organisations that can help.
How does identity theft and fraud occur?
It can occur when someone fraudulently represents a legitimate company - either online or by telephone - and tricks you into divulging personal information. A common method is phishing, the act of sending an e-mail that fraudulently represents a legitimate company and lures you into revealing personal and financial information that could then be used for identity theft. In addition, these fraudulent e-mails may contain trojans or viruses. A trojan is a computer programme that may seem innocent but has been designed to damage your computer or send confidential information over the internet to another computer. A virus is a computer programme that runs on your computer without your knowledge. If you are in any doubt about whether an e-mail is genuine do not open it or click on any links it contains.
How can I spot a scam or phishing e-mail?
Initially phishing e-mails look genuinely like those from financial services companies. They may have an official looking logo and information taken from legitimate websites. However, there are things you should look out for.
- Artemis, or its associates, will never contact you by telephone or e-mail asking you to verify your account details. You should not respond to any e-mail asking you to verify your account number or sign-on details, or seeking similar confirmations, which purports to be from Artemis.
- Beware of links in e-mails. Always check financial websites carefully to make sure the web address is correct and is not spelt slightly differently.
- Genuine e-mails from Artemis may contain links. However, we will not send any e-mail with links to the online sign-in page.
What should I do if I have received a suspicious e-mail?
- Forward the suspicious e-mail to [email protected]
- Delete the e-mail.
- Do not respond to or access any links contained within the e-mail.