Privacy

Information about you that we collect and use includes:

• Where you are investing on your own behalf, information about who you are in order to verify your identity and comply with Anti-Money Laundering Regulations e.g. your name, date of birth, national identifier/tax numbers, passport details, contact details, occupation, and source of wealth
• Where you are investing on behalf of a company, or representing a company, information about you, the company, and your relationship
• Information connected to the product or service you have with us e.g. bank account details, email address
• Information about your contact with us e.g. meetings, phone calls, emails / letters
• Information that is automatically collected via cookies when you visit one of our websites or access our online tools, e.g. username, your activity on our website. Some information will only be collected where you have turned on the relevant cookies in our preference centre
• Information if you visit one of our offices e.g. visual images collected via closed circuit television (CCTV)
• Information classified as special category [‘sensitive’ personal information] e.g. relating to your health or gender. This information will only be collected and used where it’s required to provide the product or service you have with us, or to comply with our legal obligations, and where we have also obtained your explicit consent to process this information

We will collect your personal information directly from you, and from a variety of sources, including:

• An application form for a product or service with us
• Phone conversations with us
• Emails or letters you send to us
• Meetings with us
• Registering for one of our events
• Participating in research surveys to help us understand you better and improve our products and services
• Our online services such as websites, and through our social media (if you engage with our marketing campaigns)
• Entering competitions e.g. to win tickets to a sporting event which we sponsor
• External third parties who support us in verifying your identity and relationships with our corporate clients

We may also collect personal information about you from places such as business directories and other commercially or publicly available sources e.g. to check or improve the information we hold (like your address) or to obtain updated contact information if we are unable to contact you directly.

We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only if we are able to satisfy one of the lawful processing conditions set out in the data protection laws. This will be the case where:

• It’s necessary to provide the product or service you have with us e.g. when you, or the company you represent, invest in one of our funds or products, we will require some personal information from you which may include your name, address, date of birth, and bank account details
• It’s necessary for us to meet our legal or regulatory obligations e.g. to send you important information including any changes to a product’s legal Terms and Conditions, to do appropriate money laundering checks, or for the detection and prevention of fraud
• You have given us your permission [consent] to use your information e.g., if we are collecting and using your sensitive personal information, or for certain types of direct marketing
• It’s in our legitimate interests to process your information to better understand you and your needs so we can:
  
• Send you postal communications from time to time to make you aware of other relevant products and services available from us
• Deliver appropriate information and guidance so you are aware of the options that may help you get the best outcome from your product or investment
• Conduct research and collate management information to understand how clients have interacted with us, which products and services they have already purchased or invested in, and to help us send more relevant communications based on our analysis of clients’ preferences and needs. This may also include analysing customer complaints for the purposes of improving services and processes
• Compensate you as appropriate due to service, process or regulatory failures
• Show you targeted ads for our products and services through social media channels

Where the processing is in our legitimate interests, we will always conduct an assessment to ensure that this use of your personal information is not excessive or unnecessary or otherwise more intrusive than it needs to be. If you wish to object to this processing, please contact us (see Contact Us section).

We sometimes use systems to make automated decisions based on personal information we have - or are allowed to collect and use from others – about you. These automated decisions can affect the services or features we offer you now or in the future.

If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with some of our products or services.

We will be required to share your information with selected 3^rd parties and other subsidiaries of abrdn plc for the reasons outlined in ‘Why we collect and use your information’.

We will share your information with:

• Other subsidiaries of abrdn plc who support us in the provision of the products or services agreed with you, or the company you represent
• Various technology companies, software suppliers, or companies who can help us in our contact with you, for examples an internet service provider
• Credit and identity check agencies for ID verification and credit reference checks
• Third parties we have chosen to support us in the delivery of the products and services we offer to you and other customers. For example, research, consultancy, custodians, or technology companies who help us improve our services to you
• Our regulators; including Financial Service and Data Protection Supervisory Authorities  
• Law enforcement and other appointed agencies who support us (or where they request the information) in the prevention and detection of crime; and
• Local tax authorities for the purposes of tax relief (where relevant), tax reporting, or the prevention and detection of tax fraud
• Social media companies such as Facebook or LinkedIn, so that they can display messages to you and others about our products and services, or to make sure you are not sent information which is not relevant to you personally (for example, if you already have the abrdn product we want to advertise).
• Third parties in the negotiations of a sale, restructure or re-organisation of all or part of abrdn plc e.g. professional advisers or prospective purchasers
• Third parties, where relevant, for the purposes of responding to complaints, including the payment of any compensation.

Please note that where we share your personal data with our selected third parties, they may require to retain some data in line with their own regulatory obligations e.g. custodians or fund managers.

The majority of your information is processed in the UK or European Economic Area (EEA).

However, some of your information may be processed by us, or the third parties we work with, in locations outside of the UK or the EEA, including the countries such as the United States, Hong Kong, Singapore, the Philippines and India.

Where your information is being processed outside of the UK or the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK or EEA Data Protection Laws e.g. we will put in place legal agreements with third parties and abrdn affiliates with ongoing oversight to ensure they meet these obligations.

We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.

Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information whether it is being processed by us or a third party acting on our behalf.

Our colleagues also protect sensitive or confidential information when storing or transmitting information electronically and must undertake annual training on this.

We also use internal and external audit and specialist third party consultants to conduct regular, independent assurance and benchmarking exercises across our business to ascertain the effectiveness of our security control environment and our security strategy.

To provide you with the service or product agreed, and to fulfil our legal and regulatory obligations, we will keep your personal information and copies of records we create (e.g. calls with us) while you are a [prospective] client or investor.

Even when you no longer have a relationship with us, we are required to keep information for different legal and regulatory reasons. The length of time will vary and we regularly review our retention periods to make sure they comply with all laws and regulations.

You have a number of rights under data protection laws which may be exercised in certain circumstances.

These are:

Right to be informed

You have a right to receive clear and easy to understand information on what personal information we hold, why, and who we share it with – we do this in our Privacy Notice on our websites and within, for example, product application forms and terms and conditions.

Right of access

You have a right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request (‘DSAR’) by contacting the Data Protection Officer for abrdn [see Contact Us section]

Right to request that your personal information be rectified

If your personal information is inaccurate or incomplete, you can request that it is corrected.

Right to request erasure of your personal information

You can ask for your information to be deleted or removed if there is not a compelling reason for abrdn to continue to have it.

Right to restrict processing of your personal information

You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don’t use it in the future for those reasons you have restricted.

Right to data portability

You can ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way. For example, if you were moving your investments/assets to another company.

Right to object to processing of your personal information

You can object to us processing your personal information where: it is based on our legitimate interests; for direct marketing (including profiling); and if we were using it for research and statistics.

Right to not be subject to automated decision making including profiling

You have the right to ask us to:

• Give you information about its processing of your personal information
• Request human intervention or challenge a decision where processing is done solely by automated processes
• Carry out regular checks to make sure that our automated decision making and profiling processes are working as they should. 

If you would like to exercise any of these rights please contact the Data Protection Officer [see the How to Contact us section].

We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our Privacy Notice, please let us know immediately and we will do our utmost to make things right.

While we hope that we can resolve any complaints for you, you do have the option complain to your local data protection authority. This is available to you whether or not you have exhausted our complaints procedure.

The UK data protection authority’s details are:

The Information Commissioner’s Office
Phone helpline (UK): 0303 123 1113
Phone helpline (outside UK): +44 1625 545 700
Email: casework@ico.org.uk
Website: https://ico.org.uk/concerns

For EU markets, you can find details of your Supervisory Authority on the

European Data Protection Board website.

For any other regional details, please contact the Data Protection Officer.