Ardea Investment Management (UK) Limited Privacy Policy

This policy (together with the terms of use and any other documents referred to in it) sets out the basis on which any personal data Ardea Investment Management (UK) Limited (‘Ardea IM UK’) collects from you, or that you provide to Ardea IM UK, will be processed by. Please read the following carefully to understand Ardea IM UK’s practices regarding your personal data and how Ardea IM UK treats it. Ardea IM UK is a member of the Ardea Investment Management Pty Limited group (Ardea IM Group), which is based in Australia.

For the purposes of the General Data Protection Regulation (EU) 2016/679 (the ‘GDPR’), the data controller is the Ardea IM UK entity.

1. Information Ardea IM UK may collect and process about you

Ardea IM UK may collect personal data about you, directly (where you are asked to provide the data), indirectly or implicitly when you communicate with Ardea IM UK in person, in writing, by e-mail or other electronic means, by SMS, by fax, when you use this website or by telephone. Ardea IM UK may also collect personal data that you choose to make public, including via social media, or through third party providers and may create personal data about you, such as records of your interactions with us and third parties. Ardea IM UK will, however, only use this personal data in accordance with the purposes set forth in this privacy policy and is committed to protecting and respecting your privacy.

However, Ardea IM UK uses personal data it ensures that the usage complies with law and the law allows and/or requires it to use personal data for a variety of reasons. These include where Ardea IM UK:

  • has obtained your consent.
  • has legal and regulatory obligations that it must discharge (including recording of telephone calls).
  • needs to do so in order to establish, exercise or defend its legal rights or for the purpose of legal proceedings.
  • is fulfilling contractual obligations.
  • is using your personal data for the legitimate business interests of Ardea IM UK and the Ardea IM group, such as:
    • allowing it to manage and administer the operation of its business effectively and efficiently.
    • maintaining compliance with its internal policies and procedures.
    • monitoring the use of its copyrighted materials.
    • enabling quick and easy access to information on Ardea IM UK and Ardea IM group products and the investment opportunities offered by each; and
    • offering optimal, up-to-date security solutions for mobile devices and IT systems; and
    • obtaining further knowledge of current threats to network security to update its security solutions.

Ardea IM UK will take steps to ensure that your personal data is accessed only by employees of Ardea IM UK and the Ardea IM group that have a need to do so for the purposes described in this Privacy Policy. For more details please see paragraph 6 below.

2. Sensitive data

Ardea IM UK does not seek to collect sensitive personal data (such as data revealing political opinions, religious beliefs or data concerning health or sex life). If Ardea IM UK does seek to collect such data, your explicit prior consent will be sought.

3. International transfers and storage of personal data

The Ardea IM Group is an investment management business and its partners with members of the Challenger Limited group. Those members of the Challenger Limited group provide the Ardea IM Group with various services. Our customers and operations are spread around the world. As a result, the data that Ardea IM UK collects from you may be transferred to, and stored at, destinations inside or outside the United Kingdom and/or the European Economic Area (“EEA”). It may also be processed by staff operating inside or outside the UK and/or EEA who work for Ardea IM UK, the Ardea IM Group or the Challenger Limited group, or for one of its agents. Such staff may be engaged in, amongst other things, the provision of support services.

Where Ardea IM UK transfers your personal data to another country outside the UK and/or the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of the EEA, for example, this may be done in one of the following ways:

  • the country that Ardea IM UK sends the data to might be approved by the United Kingdom or the European Commission as offering an adequate level of protection for personal data.
  • the recipient might have signed up to a contract based on “model contractual clauses” approved by the United Kingdom or the European Commission, obliging them to protect your personal data.
  • where the recipient is in the US, if it is a certified member of the EU-US Privacy Shield scheme; or
  • in other circumstances the law may permit Ardea IM UK to otherwise transfer your personal data outside the UK or Europe.

You can obtain more details of the protection given to your personal data when it is transferred outside the UK or Europe (including a copy of the standard data protection clauses which Ardea IM UK have entered into with recipients of your personal data) by contacting us as described in paragraph 11 below.

Unfortunately, the transmission of information via the internet is not completely secure. Although Ardea IM UK will do its best to protect your personal data, Ardea IM UK cannot guarantee the security of your data transmitted to its website; any transmission is at your own risk.

4. Purposes of processing

Ardea IM UK uses information held about you in the following ways:

  • to provide you with discretionary investment management services and products, investment advice or information including but not limited to newsletters about products or services that you request from Ardea IM UK or products or services offered by Ardea IM UK, the Ardea IM Group and/or its associated entities or entities with which Ardea IM UK has a commercial relationship which Ardea IM UK feels may interest you, where you have consented to be contacted for such purposes (or in the other circumstances described in this paragraph 4);
  • to administer the services and products we provide to you.
  • compliance with legal obligations (e.g. comply with diversity disclosures or anti- money laundering and anti-terrorism financing purposes).
  • compliance with contractual obligations; or
  • to notify you about changes to your investment, as well as other products or services.

If there is any change to your personal data which you have submitted to Ardea IM UK, please contact Ardea IM UK at the address in paragraph 11 so that it may ensure its records of your personal data are accurate and, where necessary, kept up to date. Personal data shall not be retained for longer than is necessary for the purpose for which it is held.

5. Disclosure of your information

Ardea IM UK may disclose your personal information to the following categories of third parties and for the following purposes:

  • with our business partners including but not limited to the Challenger group. For example, this could include our partners from whom you or your company or your organisation invested in the Ardea IM product(s). Personal data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation.
  • with third party agents, contractors, or data suppliers for the purposes of providing services to Ardea IM UK (for example, Ardea IM UK’s professional advisors, marketing agents and its IT and communications providers etc.) or to you. These third parties will be subject to appropriate data protection obligations and they will only use your personal data as described in this Privacy Policy.
  • if substantially all of Ardea IM UK’s assets or business are acquired by a third party, in which case personal data held by it may be one of the transferred assets; or
  • if Ardea IM UK is under a duty to disclose or share your personal data in order to comply with any legal obligation (whether in your jurisdiction or elsewhere) or in order to enforce or apply the terms of use and other agreements, or to protect the rights and property of Ardea IM UK.

6. How long Ardea IM UK keeps your personal data

How long Ardea IM UK will hold your personal data for will vary and will be determined by the following criteria:

  • the purpose for which Ardea IM UK is using it – Ardea IM UK will need to keep the data for as long as is necessary for that purpose; and
  • legal obligations – laws or regulations may set a minimum period for which Ardea IM UK has to keep your personal data.

7. Your rights

In all the above cases in which Ardea IM UK collects, uses, or stores your personal data, you may have the following rights, and, in most cases, you can exercise them free of charge. These rights include:

  • the right to obtain information regarding the processing of your personal data and access to the personal data which Ardea IM UK holds about you.
  • the right to withdraw your consent to the processing of your personal data at any time. Please note, however, that Ardea IM UK may still be entitled to process your personal data if it has another legitimate reason for doing so. For example, it may need to retain personal data to comply with a legal obligation.
  • in some circumstances, the right to receive some personal data in a structured, commonly used, and machine-readable format and/or request that Ardea IM UK transmits 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 directly to Ardea IM UK.
  • the right to request that Ardea IM UK rectifies your personal data if it is inaccurate or incomplete.
  • the right to request that Ardea IM UK erases or puts beyond reasonable use your personal data in certain circumstances. Please note that there may be circumstances where you ask Ardea IM UK to erase or put beyond reasonable use your personal data, but it is legally entitled to retain it.
  • the right to object to, or request that Ardea IM UK restricts, its processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask Ardea IM UK to restrict, its processing of your personal data but it is legally entitled to refuse that request; and
  • the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by Ardea IM UK.

You can exercise your rights by contacting Ardea IM UK at the address given below.

8. Cookies

Cookies are pieces of information that are transferred to your computer when you visit a website so that sites can record usage and, in some cases, provide you with tailored content or targeted advertising. Most web browsers are set to accept cookies. You can choose to disallow cookies by changing settings on your web browser. However, if you reject all cookies you may not be able to use some areas of our websites. Ardea IM UK is unable to identify you using cookies in the Ardea IM website. The goods or services available on the Australian sections of the website are only available to Australian residents.

Clear gifs (also known as web beacons) are used in combination with cookies to help us understand how visitors interact with our website. A clear gif is typically a transparent graphic image (usually 1-pixel x 1 pixel) that is placed on a site. The use of a clear gif allows us to measure the actions of the visitor opening the page that contains the clear gif.

Website analytics

Ardea IM UK may use third party web analytics providers to collect information on how people use our website and to help us know what our customers find interesting and useful in our website. Our web analytics providers use “cookies” to collect information. For more information on our web analytics providers, please visit Omniture and Google Analytics sites.

Online advertising

Ardea IM UK uses several advertising companies for our online advertising. These advertising companies may use cookies to collect information such as browser type, date and time of your visit, your interactions with banner advertisements and if you have visited our website through an online advertisement. Visit Sizmek’s website to view their privacy policy for more information on advertising cookies and how to opt out of Sizmek’s targeted advertising from the use of these cookies.

Ardea IM UK uses Google AdWords Remarketing to trigger advertisements across the Internet. AdWords remarketing will display advertising based on what parts of our website have been visited by placing a cookie on your machine. This cookie does not identify you as an individual. Google AdWords Remarketing allows us to tailor our marketing to better suit your online activity and display ads that are relevant to you. Visit Google’s Ads Preferences Manager for more information on the Google AdWords Remarketing cookie and how to opt out from the use of these cookies.

9. Amendments

Ardea IM UK reserves the right to modify sections of this privacy policy at any time.

10. How to contact Ardea IM UK

If you have any questions or concerns about this privacy policy, Ardea IM UK’s data processing activities, or you wish to access or update the information held about you, you may contact Ardea IM UK at:

L1, 1 Gresham St, London, EC2V 7BX, United Kingdom

Telephone: +44 (0) 207 832 0900.

or via e-mail at info@ardea.com.au

We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from our Compliance Officer, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, Ardea IM UK’s Compliance Officer will provide you with the contact information for that regulator.