Privacy Policy

How we use your personal information

At Guinness Asset Management Ltd, we are committed to safeguarding and preserving the privacy of our customers.

This Privacy Policy explains how we look after your personal information that you provide us with and the choices you give us about what marketing you want us to send you, as well as explaining your privacy rights.

We update this policy from time to time, so please do review it regularly.

Our Privacy Promise to you

We promise:

To keep your data safe and secure.
Not to sell your data
To only get in touch with you in the ways that you wish and to give you ways to manage and review your marketing choices at any time.
To make sure that you are in control of your information. If you have any questions, would like to change your preferences or opt out of communications, please call +44 (0) 20 7222 5703 or email us at info@guinnessgi.com.

Who we are

Guinness Asset Management Limited (registered company number 04647882) offers a range of specialist, quality funds that focus on compelling investment areas and ideas for long-term investors. We also offer Enterprise Investment Services (EIS services) and Estate Planning Services. We are authorised and regulated by the Financial Conduct Authority.
Registered address: 18 Smith Square, London SW1P 3HZ
Tel: +44 (0) 20 7222 5703 Email: info@guinnessgi.com Web: guinnessgi.com

Reasons for collecting personal data and how the law protects you

The Law on Data Protection derives from various pieces of legislation. These include the Data Protection Act 2018 and the General Data Protection Regulation (the ‘GDPR’), which came into force in May 2018. The GDPR states that personal data (information relating to a person that can be individually identified) can only be processed if there is a legal ground to do so. Activities like collecting, storing and using personal information would fall into the GDPR’s definition of processing. The GDPR provides six lawful bases (reasons) under which personal information can be processed (used) in a way that is lawful. For the processing to be permitted by law (lawful), at least one of the lawful bases must apply.

The lawful bases that are most relevant to Guinness Asset Management Limited’s use of your personal information are:

Consent
Legitimate Interest
Contract
Legal Obligation

How the law applies to Guinness Asset Management’s use of personal information

We will only process (use) your personal information if we have:

asked you and have a record of your express consent for us to do so;
a ‘legitimate Interest’ to do so. A legitimate interest is when we have a business or commercial reason to use your information. If we rely on our legitimate interest, we will tell you what that is. Our use will be fair and balanced and never unduly have an impact on your rights;
a contract with you that we can only fulfil by using your personal information;
a legal obligation to use or disclose information about you, e.g. we are required by law to keep records of certain business activities for a minimum period of five years.

We will not unduly prioritise our interests over your interests as an individual. We will always balance our interests with your rights. We will only use personal information in a way and for a purpose that you would reasonably expect in accordance with this Policy.

We will not sell your personal information to other organisations for them to use in their own marketing activities.

Please see below a list of the ways in which we may use your personal information, the lawful bases we rely on to do so and our legitimate interests (where applicable):

What we use your personal information for	Our lawful bases	Our legitimate interests
To manage our relationship with you. To enhance, modify or otherwise improve our services/communications for the benefit of our customers. To develop and carry out marketing activities. To better understand how people interact with our website. To provide postal and email communications which we think will be of interest to you. To determine the effectiveness of promotional campaigns and advertising.	Your consent. Fulfilling contracts. Our legitimate interests. Our legal duty.	Ensuring our records are kept up to date, determining which of our products and services may be of interest to you and telling you about them. Developing products and services and determining related charges. Defining customers for new products or services. Fulfilling our legal and contractual duties in an efficient manner.
To develop and manage our products and services.	Fulfilling contracts. Our legitimate interests. Our legal duty.	Developing products and services, and determining related charges. Defining customers for new products or services. Fulfilling our legal and contractual duties in an efficient manner.
To deliver our products and services. To manage fees and charges. To manage and provide investment products and services.	Fulfilling contracts. Our legitimate interests. Our legal duty.	Fulfilling our legal and contractual duties in an efficient manner. Complying with relevant legislation.
To detect, investigate, report, and seek to prevent financial crime. To manage risk. To comply with relevant legislation. To handle complaints.	Fulfilling contracts. Our legitimate interests. Our legal duty.	Ensuring that we fulfil our legal duties with regard to how we deal with financial crime and undertaking any improvements we need to make in this area. Complying with relevant legislation. Fulfilling our legal and contractual duties in an efficient manner.
To manage our business in a prudent and efficient manner. This includes managing our financial capacity, business capability, planning ahead for new developments and communications.	Our legitimate interests. Our legal duty.	Complying with relevant legislation. Fulfilling our legal and contractual duties in an efficient manner.
To exercise our rights set out in agreements or contracts.	Fulfilling contracts.

Categories of Personal Information

We use different kinds of personal information (depending on the customer type) and categorise them as shown in the table below:

Type of personal information	Description
Financial information	Financial situation and history collected for investors in the EIS services as part of the Suitability assessment.
Contact information	Where you live and how we can to contact you.
Socio-Demographic information	Details about investment experience, employment and source of income is collected as part of the Suitability assessment for investment in the EIS services
Investment information	Details about investments made and redeemed.
Contractual information	Details about products or services provided to you and other relevant details that form part of a contract.
Geographical location information	Data we get about your geographical location, which may come from your mobile phone or the address where you connect a computer to the Internet.
Technical information	Details on the devices and technology you use.
Communication information	What we learn about you from correspondence via letters and email and any other communications.
Public Records and other openly available information	Details about you that are in public records, such as Companies House, and information about you that is openly available on the Internet
Document information for identity purposes	Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport or drivers licence.
Information about consent	Any permissions, consents or preferences that you give. This includes things like how you want us to contact you and the type of information you are interested in receiving.
National Identifier	A number or code given to you by a government to identify who you are, such as a National Insurance Number.

How we collect personal information

We may collect personal information about you from the following sources:

Data provided by you:

When you invest in our products and services.
When you speak to us on the phone.
When you use our website.
In emails and letters.
If you take part in our promotions.

Data we collect when you use our services. This may include:

Payment and transaction data.
Data to understand how you interact with our website. This is collected from the devices you use to connect to the website.

Data from third parties we work with, such as:

Companies that you introduce us to.
Financial advisers and Investment platforms.
Public information sources such as Companies House.
Agents working on our behalf.
Government and law enforcement agencies.

Who we share your personal information with

We may share your personal information with other companies in the Guinness Group and the following organisations:

Our management companies
Third parties, selected by us, with respect to certain activities
Agents and advisers we use to help run our services
HM Revenue & Customs, regulators and other authorities
UK Financial Services Compensation Scheme
Any party linked with you
Companies that we have an agreement to co-operate with
Companies that you introduce us to
Companies that we introduce you to
Companies that introduce you to us
Financial Advisors and Investment platforms
Companies you ask us to share your data with.

If our structure changes in the future, we may also share your personal information with other parties:

In the case of a sale, merger, acquisition or transfer of business, we may share your data with other parties, provided that they agree to keep your data safe and secure.
If the structure of our business changes, other parties may use your data in the same way as set out in this Privacy Policy.

Sending data outside the UK

In operating our website it may become necessary to transfer data that we collect from you to locations outside of the UK for processing and storing.

If we need to transfer information outside the UK, we will make sure that it is protected in the same way as if it was being used in the UK. We will use one of the following safeguards:

Transfer it to a country with privacy laws that give the same protection as the UK.
Put in place a contract with the recipient that means they must protect it to the same standards as the UK.
Transfer it to organisations that are part of the Data Privacy Framework.

If you do not want to give us personal information

We may need to collect your personal information under the terms of a contract we have with you or by law.

If you do not give us this personal information, it may result in a delay or prevent us from meeting our obligations. It could mean that we cancel a product or service you have with us.

We will make clear any data collection that is optional at the time we collect it.

Marketing

From time to time, we may use your personal information for marketing purposes to tell you about relevant products and services.

The personal information we have for you is comprised of information provided by you and information we collect when you use our services or from third parties we work with (e.g. Financial Advisors).

We will only send you marketing messages using your personal information if we have either your consent or a ‘legitimate interest’ (a business or commercial reason to use your information). We will not unfairly go against your interests, rights and freedoms.

You can ask us to stop sending you marketing messages at any time by contacting us. If you do so, you will still receive important non-marketing information about your existing products and services.

We are keen to ensure that you receive information that is relevant and of interest to you. From time to time, we may therefore ask you to confirm or update your preferences. We will also ask you to do this if there are changes in the law or the structure of our business. You can update your preferences at any time by contacting us.

How long we keep your personal information

We will not keep personal information for longer than is necessary for the purposes for which it is being processed (used). We will keep your personal information for as long as we have a business relationship with you. After the business relationship ends, we may keep your information for up to 10 years for one of the following reasons:

To respond to any questions or complaints.

To show that we treated you fairly.
To maintain records as required by the rules that apply to us.
To comply with a legal obligation

We may keep your data for longer than 10 years if we cannot delete it for technical or legal reasons.

How to access your personal information

You have the right to access the personal information we hold for you. You can do this by:

Writing to us at our registered address: 18 Smith Square, London SW1P 3HZ
Calling us: +44 (0) 20 7222 5703
Contacting us via email: info@guinnessgi.com

What to do if you believe the personal information we hold for you is incorrect or incomplete

You have the right to have inaccurate personal data rectified or completed if it is incomplete. If you believe that the information we have about you is incorrect or incomplete and want us to rectify it, please contact us. We will then use our best endeavours to check the accuracy of the information and correct it.

What to do if you want us to stop, delete or restrict how we use your personal information

You have the right to object to our use of your personal information. This is known as the ‘right to object’. You also have the right to ask us to have your personal data deleted if there is no need for us to keep it. This is known as the ‘right to erasure’, or the ‘right to be forgotten’.

Note that there may be legal or other legitimate reasons why we need to keep or use your data.

In some circumstances, you have the right to ask us to restrict the processing of your personal information. This is an alternative to asking us to erase your data. In such cases, we would only use the data for specific purposes, such as legal claims or to exercise legal rights, and we would not use or share your information in other ways while it remains restricted.

You can ask us to restrict the use of your personal information if:

You do not believe that it is accurate and we are verifying it.
It has been used unlawfully, but you do not want us to erase it.
We no longer need it, but you want us to keep it for use in legal claims.
You have already objected to our use of your data but you are waiting for us to tell you if we are allowed to keep on using it.

If you are concerned about how we use your data and you want to object to our use of your personal information, or ask us to delete it or restrict how we use it, please contact us.

How to withdraw your consent

You have the right to withdraw your consent at any time. Please contact us if you wish to do so.

If you withdraw your consent, we may not be able to provide certain products or services to you. We will let you know if this is the case.

How to complain

You have a right to lodge a complaint if you are not happy with how we have used your personal information. If you want to make a complaint, you can do so by:

Writing to us at our registered address: 18 Smith Square, London SW1P 3HZ
Calling us: +44 (0) 20 7222 5703
Contacting us via email: info@guinnessgi.com

You also have the right to complain to the Information Commissioner’s Office. https://ico.org.uk/

Making it easier for you to re-use the personal information we hold for you

You have the right to get your personal information from us in a format that can be easily re-used for your own purposes across different services. You can also ask us to pass on your personal information in this format directly to other organisations if it is technically possible to do so. Note that our processing systems may not always be technically compatible with those of other organisations.

Telephone calls

Telephone calls will be recorded and monitored in order to improve our service and to comply with regulatory requirements.

Cookies

To find out more about how we use cookies, please see our Cookie Policy.

Last updated January 2024