Privacy notice

This Privacy Notice explains how Stonehage Fleming Investment Management Limited (“the Company”), as investment manager and distributor of the Stonehage Fleming Equity Management fund range, collects, uses and discloses your personal data.

This Privacy Notice concerns the processing of personal data for business to business marketing and your rights in relation to the personal data it holds for this purpose.

In this Privacy Notice, “us”, “we” and “our” refers to the Company.

Stonehage Fleming Investment Management Limited is the data controller of your personal data and is subject to the Data Protection Act 2018 and United Kingdom General Data Protection Regulation.

The contact details of our Data Protection Officer, Mr Cesare Milani, are:

By email - ukdataprotectionofficer@stonehagefleming.com

By telephone - +44 207 087 0136

By post - 6 St James's Square, London, SW1Y 4JU, United Kingdom

We may amend this Privacy Notice from time to time to reflect any changes in the way that we process your personal data. This Privacy Notice supersedes any previous version of it, as determined by the date at the end of this document.

You have the following rights:

  • To obtain access to, and copies of, the personal data that we hold about you;
  • To require that we cease processing your personal data if the processing is causing you damage or distress;
  • To require us not to send you marketing communications;
  • To require us to erase your personal data;
  • To require us to restrict our data processing activities;
  • To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;
  • To require us to correct the personal data we hold about you if it is incorrect.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

You can find out more about your rights under data protection legislation at www.ico.org.uk

If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact our Data Protection Officer.

If you are not satisfied with how we are processing your personal data, you can make a complaint to the Information Commissioner ( www.ico.org.uk ).

Your personal data was provided to us by a data services provider.

We may collect the following categories of personal data about you:

  • Your first name, middle name and surname;
  • Details about your firm, including the FCA Reference Number (FRN);
  • Your company physical, postal and email address (where publicly available);
  • Your regulatory status, years with your firm and previous work experience as listed on the FCA website.

We may process your personal data because we would like to inform you about the Stonehage Fleming equity management products and it is in our legitimate business interest to do so.

In this respect, we may share your personal data with the marketing service provider we use.

We will retain your personal information for as long as necessary and permitted for legal, regulatory, and legitimate business purposes. After this period, your personal data will be deleted and / or destroyed.

Version dated: 4 October 2022