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Fisher Investments Europe Limited
Privacy & Cookie Policy

January 2017

General

This privacy policy sets out how Fisher Investments Europe Limited, including its branches, complies with European Union data protection requirements. Fisher Investments Europe Limited and its branches conduct business under different trading names in different countries, including Fisher Investments Belgium, Fisher Investments España, Fisher Investments Europe, Fisher Investments France, Fisher Investments Italia, Fisher Investments Nederland, Fisher Investments Norden, and Fisher Investments UK (collectively referred to in this policy as “Fisher Investments Europe”). For more information about Fisher Investments Europe’s branch names and registrations, please see the Regulatory Information section at the bottom of the applicable Fisher Investments Europe website.

Fisher Investments Europe is committed to privacy, and will only use information by which individuals can be identified (“Personal Data”) in accordance with this policy. This policy applies to all of Fisher Investments Europe’s websites and interactions. Fisher Investments Europe is registered under the UK Data Protection Act 1998, and has given all appropriate notifications to the applicable data protection authorities.

What Personal Data Fisher Investments Europe Collects

Fisher Investments Europe may collect the following Personal Data of current and prospective clients and their representatives, employees and job candidates, individuals who agree to participate in market research, and website users (collectively referred to in this policy as “Individuals”):

  • Fisher Investments Europe collects the name, address, telephone and fax numbers and email address of Individuals who request Fisher Investments Europe informational materials, Individuals seeking employment or engagement with Fisher Investments Europe, and Individuals interested in Fisher Investments Europe’s services.
  • Fisher Investments Europe may place ads on publishers' websites or within email content, either directly through the publisher or via a third party. As a result of Individuals interacting with the advertising content, ad server companies may collect information about Individuals such as domain type, IP address, clickstream data. This information is not identifiable by Individuals’ Personal Data other than their IP address.
  • Fisher Investments Europe’s websites use cookies and other online tracking technologies that collect information about internet browsing habits and history (collectively referred to in this policy as “cookies”). For more information, please see the cookie policy below.
  • Fisher Investments Europe may collect other Personal Data provided by Individuals only with their consent, including: birth date and birth place; gender; education; occupation; employment history and information; information about activities, memberships, licences, certifications or awards; benefits information; marital status; citizenship; visa information; identification numbers; financial situation; account numbers; personal interests; income; family information; banking details; compensation and payroll information; leave of absence information; dependents or beneficiaries (including name, address, email and phone); emergency contacts; background check information; and health information.
  • In dealing with service providers and vendors, Fisher Investments Europe obtains information about the business contact, including name, title, name, address, telephone and fax numbers and email address.

Fisher Investments Europe’s Use and Sharing of Personal Data Collected

Fisher Investments Europe may use collected Personal Data for the following purposes:

  • To offer or provide investment management services, including financial and suitability analysis;
  • Verification of identity;
  • Recruiting and evaluation of employment candidates;
  • Monitoring and management of personnel, including processing payroll and providing benefit programmes;
  • Monitoring and management of agents and other service providers, including processing payments;
  • Internal recordkeeping;
  • Internal controls;
  • Internal training;
  • To improve products and services;
  • Marketing optimisation, including, market research, analysing and improving marketing campaigns and profiling internet users;
  • With Individuals’ consent, for marketing purposes, including direct marketing, follow up by email, phone or mail with Individuals who requested informational materials to provide further information and send promotional email or mail about Fisher Investments Europe’s investment management services or other information Individuals may find interesting.

Fisher Investments Europe will not sell or lease Individuals’ Personal Data to third parties.

For the purposes listed above, Fisher Investments Europe may share Personal Data collected with:

  • Fisher Investments, in accordance with written agreements in the form of the European Commission Standard Contractual Clauses (“Model Clauses”) governing the transfer of personal data to countries whose national laws do not provide an adequate level of data protection. The European Commission has determined that the Model Clauses offer sufficient safeguards for the protection of individuals’ privacy and fundamental rights and freedoms, including the ability to exercise those rights.
  • Fisher Investments Europe-authorised vendors, agents and representatives, including direct marketing agents. Some data processors may be based outside of the European Economic Area in a country that the European Commission has not determined offers an adequate level of data protection. Where this is the case, data processors will be contractually committed to process information in accordance with the provisions of European data protection legislation, and the transfer will be made in accordance with written agreements in the form of the Model Clauses.
  • Regulators, law enforcement, as otherwise required by law, or where Individuals have provided permission.

Individuals’ Marketing Choices

When Individuals request informational materials from Fisher Investments Europe, they are offered the opportunity to consent and agree that Fisher Investments Europe may use and share their Personal Data for the purposes set out above in this policy. In accordance with applicable data protection laws (in France, the the law « informatique et libertés » of 6 January 1978, amended in 2004), such Individuals who provide Personal Data may contact Fisher Investments Europe at any time to say they do not want their Personal Data to be used for direct marketing purposes. Individuals may do so by writing to or emailing:

Head of Compliance
Fisher Investments Europe Limited
2nd Floor
6-10 Whitfield Street
London
W1T 2RE
United Kingdom
privacy@fisherinvestments.co.uk

When doing so, please ensure that full name and address is provided in exactly the form in which it was originally provided to Fisher Investments Europe to avoid any possible confusion with a different Individual.

Individuals may unsubscribe from direct email marketing via Fisher Investments Europe’s online form at http://www.fisherinvestments.co.uk/weballey/FiUnsubscribeForm.aspx.

Individuals’ Rights to Update, Correct or Request Personal Data

In accordance with applicable data protection laws (in France, the the law « informatique et libertés » of 6 January 1978, amended in 2004), Individuals may request details of Personal Data that Fisher Investments Europe holds about them, and exercise their privacy rights as provided for by law, by writing to or emailing the below address. In the UK, a fee of £10 will be payable for data access requests.

If Individuals believe that any information Fisher Investments Europe holds on them is incorrect or incomplete, please write to or email the below address as soon as possible. Fisher Investments Europe will promptly correct any information which was found to be incorrect.

In each case, please ensure that the full name and address are provided in exactly the form in which they were originally provided to Fisher Investments Europe to avoid any possible confusion with a different Individual.

Head of Compliance
Fisher Investments Europe Limited
2nd Floor
6-10 Whitfield Street
London
W1T 2RE
United Kingdom
privacy@fisherinvestments.co.uk

 

Security

Fisher Investments Europe is committed to ensuring that Personal Data is secure. In order to prevent unauthorised access or disclosure, Fisher Investments Europe has put in place suitable physical, electronic and managerial procedures to safeguard and secure Personal Data collected. Fisher Investments Europe uses encryption when collecting or transferring sensitive data. 

Cookies

A cookie is a small text file with an identification tag that is created and downloaded to a user’s computer (or other device) when accessing websites that use cookies. Cookies allow a website to, among other things, store and retrieve information about a user’s online activity, browsing habits of a user or user’s computer (or other device) and, depending on the information they contain and the way a user uses a computer (or other device), may be used to recognise the user.

Cookies can be categorised by who places them:

  • First-party cookies: These cookies are downloaded to a user’s computer (or other device) from a computer or domain managed by the publisher of the website whose service the user is requesting.
  • Third-party cookies: These cookies are downloaded to a user’s computer (or other device) from a server or domain that is not managed by the publisher of the website, but by another entity that may be seeking data obtained through cookies.

Cookies can also be categorised by their duration:

  • Session cookies: These cookies are designed to collect and store data while the user accesses a website. They are often used to store information for the duration of a visit to the website (e.g. what account user is logged into). Once a user leaves the website, the session cookie is deleted.
  • Persistent cookies: These cookies store data on the user’s computer (or other device) for the duration period set within the cookie’s file, which is determined by the entity controlling the cookie and can range from a few minutes to several years, or until the user manually deletes them. Fisher Investments Europe has configured its persistent cookies to expire within 13 months.

Lastly, cookies can be categorised by the function they serve. Fisher Investments Europe uses the following types of first- and third-party cookies:

1. Functionality Cookies

Fisher Investments Europe uses functionality cookies to keep track of whether or not a user has consented to have other types of cookies placed on their computer (or other device) and, if the user has consented, to note when consent was obtained. Functionality cookies do not collect any Personal Data. Enabling functionality cookies may be necessary to access the full content of website material.

2. Personalisation Cookies

Personalisation cookies allow the website to remember information that changes the page’s appearance or behaviour, such as, for example, the language selected for viewing the page.

Fisher Investments Europe uses the third party personalisation cookie services provided by the companies below and these companies may have access to information collected by the cookies.

 

3. Analytics Cookies

Analytics cookies analyse how users browse the Fisher Investments Europe websites and enable Fisher Investments Europe to measure the number of visitors to the website, as well as to measure and analyse how users interact with the website. This information is used to improve Fisher Investments Europe’s websites and the products or services offered.

Fisher Investments Europe uses the third party analytics cookie services provided by the companies below, and these companies may have access to information collected by the cookies.

 

4. Behavioural Cookies

Fisher Investments Europe serves advertisements on various websites using third-party companies. If a user visits a Fisher Investments Europe website or clicks on one of Fisher Investments Europe’s advertisements, behavioural cookies will be placed on the user’s computer (or other device). Behavioural cookies allow Fisher Investments Europe to manage and optimise its digital marketing (e.g. banner ads, pages offering informational brochures, email campaigns, etc.). Behavioural cookies may be used to build a user profile to provide users with content more relevant to their interests. They adapt advertising and the content users see on other websites based on their browsing habits, including how users navigate the Fisher Investments Europe websites and other websites that the user may visit, as well as how users interact with internet advertising.

Fisher Investments Europe uses the third party behavioural cookie services provided by the companies below, and these companies may have access to information collected by the cookies.

 

How to Manage Cookies

A user can manage cookie preferences for the Fisher Investments Europe websites by using Fisher Investments Europe’s online cookie preference tool at  .

Some browsers have a “Do Not Track” setting that allows users to send a signal to the websites they visit that the user does not wish to be tracked. Fisher Investments Europe websites may not respond to these signals.

Changes to Privacy & Cookie Policy

From time to time, Fisher Investments Europe may use Personal Data for new, unanticipated uses not previously disclosed in this policy. If its practices regarding Personal Data change at some time in the future, Fisher Investments Europe will post the policy changes to http://www.fisherinvestment.co.uk/legal/uksecurity.aspx to notify Individuals of these changes and provide the ability to "opt out" or unsubscribe from these new uses. If Individuals are concerned about how Personal Data is used, they should check such webpage periodically.