Privacy Policy

1. IMPORTANT INFORMATION AND WHO WE ARE

1.1 Purpose of this privacy notice

(a) This privacy notice aims to give you information about how Amati Global Investors Limited and Amati AIM VCT PLC collect and process personal data.

(b) It is important that you read this privacy notice carefully so that you are fully aware of how and why we are using your data. 

 

1.2 Who we are and who this notice applies to

(a) Amati Global Investors Limited is a company registered in Scotland under company number SC199908 and have our registered office at 8 Coates Crescent, Edinburgh EH3 7AL.  

We are registered as a controller with the UK Information Commissioner's Office (ICO) under registration number Z591809X.  

We are the controller of and we are responsible for the personal data of:

  • Current and past investors with portfolios managed on a discretionary basis by Amati Global Investors Limited, as investment manager of the Amati AIM IHT Portfolio Service.
  • Independent financial advisers and other financial intermediary business contacts.
  • Business contacts with whom we have a contractual relationship.
  • Company contacts who provide investment research information.
  • Visitors of the www.amatiglobal.com website.
  • Individuals who apply for jobs with us.
  • Individuals who visit our premises.


We are the processor of the personal data of:

  • Current and past investors in TB Amati UK Smaller Companies Fund.
  • Current and past investors in Amati AIM VCT and past investors in Amati VCT plc.
  • Current and past investors in TB Amati Strategic Metals Fund.


(b)
Amati AIM VCT PLC is a company registered in England and Wales under company number 04138683 and have our registered office at 27-28 Eastcastle Street, London W1W 8DH.  

We are registered as a controller with the ICO under registration number ZA522471.  

We are the controller of and we are responsible for the personal data of: 

  • Current and past investors in Amati AIM VCT plc and past investors in Amati VCT plc (dissolved on 9 October 2019).


(c)
References in this notice to "we", "us" and "our" refer to Amati Global Investors Limited and Amati AIM VCT PLC.

 

1.3 Contact details

If you have any questions about this privacy notice or our privacy practices, please contact us at:

Data Protection Officer
Amati Global Investors Limited
8 Coates Crescent
Edinburgh EH3 7AL

Email: dpo@amatiglobal.com 
Telephone: 0131 503 9100

 

1.4 Your right to complain

You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

1.5 Changes to the privacy notice and your duty to inform us of changes

(a) We keep our privacy notice under regular review. 

(b) It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

1.6 Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

2 THE DATA WE COLLECT ABOUT YOU

2.1 Data Categories

(a) Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

(b) We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: 

(i) Identity Data includes first name, last name and title, date of birth, age, gender, and information used to verify your identity, such as copies of passports, driving licences, bank or building society statements, utility bills or tax bills and national insurance numbers.

(ii) Contact Data includes email address, postal address and telephone numbers, including the professional contact details of our business contacts and representatives of our suppliers.

(iii) Financial Data includes bank account details, platform account details, ownership of securities, valuations of investments, dividend preferences, investment details and details of shareholdings, risk and investment preferences, and information received from financial advisers.

(iv) Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.  

(v) Usage Data includes information about how you use our website, products and services.  

(vi) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. When you receive email communications (e.g. newsletters and other updates about our products and services), our service provider who sends out emails on our behalf may:

(A) collect information from your device and applications used to view emails, including your IP address, device attributes (for example: hardware model, operating system, web browser version), connection information (for example, name of your mobile operator or ISP, language and time zone and mobile phone number) and device information (for example, Wi-Fi information); and

(B) collect information from page tags (also known as web beacons) about email engagement, such as when you receive our emails, if and when you open our emails, how long you spend reading our emails and whether or not you click a link contained in our emails.  This information is collected and recorded on an anonymous basis and used by us to analyse our engagement with our contacts. 

More information about how our bulk email service provider uses personal data is available here.

(vii) Recruitment Data includes any personal data you may give to us as part of a recruitment process, including your Identity Data, Contact Data, your CV and your responses to application form questions or assessment questions.  For some roles we may also be required to run a credit check and / or a Disclosure Scotland check against you, however you will be informed if this applies to you.  This may involve the collection and use of information about criminal convictions and offences. 

(viii) CCTV Data includes images recorded by the CCTV systems at our premises, which may capture you if you visit our premises.

(c) We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Except in the context of Recruitment Data as noted above, we do not collect any information about criminal convictions and offences.

 

2.2 If you fail to provide personal data

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 services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

3.  HOW WE USE YOUR PERSONAL DATA

3.1 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

3.2 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

Purpose/Activity Type of data Lawful basis for processing including legitimate interest
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  • Identity
  • Contact
  • Technical
  • Usage

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

To deliver relevant website content to you and measure or understand the effectiveness of the advertising we serve to you
  • Identity
  • Contact
  • Usage
  • Marketing and Communications
  • Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To monitor use of our website and to use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  • Technical
  • Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To respond to requests made via social media or email
  • Identity
  • Contact

Necessary for our legitimate interests (to respond to enquiries from potential investors and other interested parties)

Necessary to perform our contract with you (where we are communicating with an investor in connection with the delivery of products and services to that investor)

To respond to enquiries made by telephone or mail
  • Identity
  • Contact
  • Audio and video call recordings

Necessary for our legitimate interests (to respond to enquiries from potential investors and other interested parties)

Necessary to perform our contract with you (where we are communicating with an investor in connection with the delivery of products and services to that investor)

Necessary to comply with legal obligations (to record calls under the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations)

To send investors regulatory or legal notices
  • Contact
  • Marketing and Communications Data

Necessary for our legitimate interests (to keep interested parties up to date regarding the performance of our funds and investments)

Necessary to perform our contract with you (where we have committed to providing regular information and updates regarding the performance of your investments)

Necessary to comply with legal obligations (where we are required by law to regularly report certain information to investors)

To verify the identity of investors
  • Identity
  • Financial

Necessary for our legitimate interests (to reduce the risk of fraud)

Necessary to perform our contract with you (where we are obligated to provide you with products or services which are subject to regulatory requirements)

Necessary to comply with legal obligations (including under the Money Laundering Regulations)

To process investments in our financial products
  • Identity
  • Contact
  • Financial

Necessary to perform our contract with you (under which we may be obligated to process investments)

To enter into and perform contracts with our service providers
  • Contact
Necessary for our legitimate interests (where we have engaged a third party service provider, we require to be in contact with representatives of that service provider in order to receive the full benefit of their services)
To consider and evaluate companies that we are considering investing in
  • Identity
  • Financial

Necessary for our legitimate interests (to undertake appropriate due diligence of any company or asset which we may decide to invest in)

To send regular updates or newsletters to interested parties
  • Contact
  • Marketing and Communications
Necessary for our legitimate interests (to promote our products and services to interested parties who have not declined or opted out to receiving communications from us)
To recruit members of staff to fulfil vacant positions
  • Identity Data
  • Contact Data
  • Recruitment Data

Necessary for us to take required steps before potentially entering into an employment contract with you

Necessary for our legitimate interests (to keep a record of applications in the event of a claim)

To ensure the safety and security of our premises
  • CCTV

Necessary for our legitimate interests (for the prevention and detection or crime, and to help ensure the safety and security of our premises)

 

3.3 Opting out

(a) You can ask us to stop sending you marketing messages at any time by contacting us at any time, or (where the communication is an email) you can click the "unsubscribe" link contained in the email.

(b) Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

 

3.4 Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

 

3.5 Change of purpose

(a) We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

(b) If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

(c) Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

4. DISCLOSURES OF YOUR PERSONAL DATA

4.1 We may share your personal data with the categories of third parties set out below: 

(a) Service Providers acting as processors who provide IT and system administration services.

(b) Professional advisers acting as processors or controllers including solicitors, auditors, bankers, financial advisers and insurers.  This includes Amati AIM VCT's receiving agent and registrar, and James Brearley who is the administrator and custodian of our AIM IHT portfolio.

(c) Financial Conduct Authority, HM Revenue & Customers, regulators and other authorities acting as processors or controllers.

(d) Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

4.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

4.3 If you are applying for a position with us, we may require to undertake a credit check against you as part of our recruitment process.  This involves us sharing some of your personal data with uCheck, who are our credit reference agency for these purposes.  You can find out more information about how they use your personal data here

 

5. INTERNATIONAL TRANSFERS

5.1 Whenever we transfer your personal data out of the UK, we ensure it is done so in accordance with the relevant data protection legislation.

5.2 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

6. DATA SECURITY

6.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

6.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

7.  DATA RETENTION

7.1 How long will you use my personal data for?

(a) We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

(b) In some circumstances we will 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. 

 

8. YOUR LEGAL RIGHTS

8.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data:

(a) The right to access personal data we hold about you: You can contact us to request a copy of the data we hold about you, as well as why we process that data, who has access to it, and where we got it. 

(b) The right to correct and update the personal data we hold about you: If the data we hold about you is out of date, incomplete or incorrect, please let us know and we will ensure that it is updated.

(c) The right to have your personal data erased: In some circumstances if you no longer wish us to process your data, you can request that we erase it. When we receive your request, we will confirm whether the data has been deleted, or tell you the reason why it cannot be deleted. 

(d) The right to object to processing of your personal data: You have the right to request that we stop processing your data. Upon receiving the request, we will contact you to tell you if we are able to comply or if we have lawful grounds to continue, for example if the data is required to allow us to provide you with services, to process investments or to comply with legal or regulatory obligations. If data is no longer processed, we may continue to hold your data to comply with your other rights. 

(e) The right to data portability: You have the right to request that we transfer your data to another controller. Once we have received your request, we will comply where it is feasible to do so. 

(f) The right to complain: As noted above, you can make a complaint to us by contacting us or to the ICO (the UK data protection supervisory authority) at https://ico.org.uk/.  

8.2 If you wish to exercise any of the rights set out above, please contact us at the details set out above.

 

8.3 What we may need from you

When you exercise your data subject right to access your data, we may need to request specific information from you to help us confirm your identity. 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.