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    Insight Investment privacy notice
    Effective from January 2023

    This privacy notice applies to Insight Investment Management Limited and its affiliates (collectively referred to as "Insight", "we", "us"). Insight is a wholly-owned subsidiary of The Bank of New York Mellon Corporation (BNY Mellon.)

    You can find out more about BNY Mellon entities at https://www.bnymellon.com/emea/en/about-us/locations.html or by contacting us using the information in the contact us section.

    This privacy notice explains how Insight collects, uses and shares personal information in the course of our business activities, including:

    This notice does not apply to personal information processed in respect of prospective, current or former employees of Insight. Our employee privacy notice is available here.

    We may amend this notice from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check these pages for the latest version of this notice. If we make significant changes to this privacy notice, we will seek to inform you by notice on our website or email ("Notice of Change").

     

    Sale of Personal Data

    Insight does not sell personal data. Personal data is only transferred or used in accordance with the terms of this notice.

     

    What Personal Information We Collect and When and Why We Use It

    In this section you can find out more about:

    • the types of personal information we collect
    • the legal basis for processing personal information
    • how we use personal information
    • when we collect personal information
    • additional information on the use of artificial intelligence and machine learning

    Insight Data Subjects

    Insight collects personal information and will act as the data controller of this information if you:

    • are a client or represent one of our clients or our prospective clients
    • are associated with an Insight client while we undertake Know Your Customer (KYC) due diligence
    • work or correspond with us from a regulator, vendor or service provider
    • register with or use one of our website or online services
    • visit an Insight office or register to attend an event that Insight sponsors
    • attend an event where the sponsor shares attendance information with exhibitors
    • are associated with a financial arrangement which is promoted to Insight or its clients

    Personal Information We Collect

    Personal Information we collect will fall within one of the following categories:

    • Your name and how to contact you - Basic contact information about you, including your signature.
    • Identification data including unique descriptors - Government issued identifiers, other unique identifiers such as date of birth, and personal descriptors including account details that identify you.
    • Relationship Information - Details about your work or profession, nationality, education and family status.
    • Technical information - Details about your devices and technology that you use to access our services, including IP address.
    • Location - Data we receive about where you are.
    • Communications and CCTV - Information we capture through your communications with us, e.g. voice recordings of telephone conversations, emails and instant messaging, and CCTV images if you visit our offices.
    • Publicly available data - Details about you that are in public records and information about you that is openly available on the internet.
    • Sensitive categories of data - Laws and other regulations treat some types of personal information, including personal information relating to health or criminal convictions and offences, as special and affords them additional protections. We will only collect and use these types of data if the law allows us to do so.

    The legal basis for processing your personal information

    We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This is explained in more detail in the section below which sets out the purposes for which we collect personal information. For each purpose, we indicate that we will have one or more of the following reasons for using your personal information:

    • our use of your personal information is in our legitimate interests as a commercial organisation.
    • our use of your personal information is necessary to comply with a legal or regulatory obligation that we have, for example where we are required to report to tax authorities;
    • our use of your personal information is necessary to fulfil a contract we have with you or to take steps to enter into a contract with you, for example when you ask us to provide you with a product or service;
    • our use of your personal information is required for regulatory reasons that are in the public interest, for example to prevent and detect financial crime;
    • you have provided your consent to us using the personal information, for example if you have agreed to receive communications about an Insight event;

    Insight collects personal information to build, manage and understand relationships with corporations: institutional customers and prospects, and vendors and suppliers. The personal information required to do this comes from employees, consultants, trustees and other people associated with the corporations and the market for institutional investment services. These activities, and the legal basis for the associated personal data processing are described in more detail below.

    Insight provides investment services to corporations through and to natural people whose information must be processed to deliver the service. Personal information of officers, trustees and others is required to identify and research persons relevant to the “know your customer” process required by regulators. This activity takes place on the legal basis of Insight’s compliance with enactment in the form of law and financial regulation.

    The specific requirements (reporting, instructions, authentication and others) of customer service require contact and other information for a wide range of people associated with the customer and other organisations including their consultants, intermediaries, fiduciaries, auditors, regulators and suppliers. This takes place on the basis of our legitimate interest in the delivery of the contracted service in a way which is transparent and timely fulfilling all requirements of the customer and their stakeholders.

    To defend Insight and our customers and stakeholders, Insight may need to process personal data to prevent or detect crime. This activity may take place on the basis of our compliance with an enactment, or our legitimate interest in protecting our customers and protecting our reputation.

    If you are participating in an Insight event you may be asked to consent for our processing of information to provide elements of the event such as a specific menu choice. Where you have provided your consent for voluntary provision of personal data, you have the right to withdraw your consent at any time. You can do so by making a request to the team that collected your personal information, by clicking ‘opt out’ or ‘unsubscribe’ on direct marketing communications, or by contacting us.

    Our relationships with vendors are carried out through contacts with team members at the vendor and their agents. Our use of the personal data required to maintain these contacts takes place on the basis of our legitimate interest

    Where we rely on our legitimate interests, we will do so on the basis that the activity:

    • is necessary for us to meet our business or commercial objectives and to provide services to our clients and cannot be achieved without reliance on our legitimate interests;
    • is proportionate and would not cause unjustified harm;
    • is aligned to, or would not conflict with, your reasonable expectations;
    • does not undermine your individual rights, interests or freedoms; and
    • on balance, does not outweigh your privacy rights.

    The balance between our legitimate interests and the rights of those involved in customer service has to consider the large sums of money being managed, the views of regulators, and the interests of members and pensioners not directly party to the relationship.

    We consider that the information we provide in the form of direct marketing is worthwhile and interesting. Anyone can opt out or tailor use of their contact information for this this processing via the unsubscribe link in any marketing email.

     

    Sharing Personal Information Within Insight and BNY Mellon, With Third Parties, With Our Regulators

    In this section you can find out more about how we share personal information:

    • within Insight and our corporate parent BNY Mellon
    • with third parties that help us provide our products and services
    • our regulators

    We share your information in the manner and for the purposes described below:

    • within Insight and BNY Mellon, where such disclosure is necessary to provide you with our services or to manage our business;
    • with third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These include IT service providers who help manage our IT and back-office systems;
    • with agencies and organizations working to prevent fraud in financial services;
    • with our regulators;
    • to comply with applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies;
    • we may share in aggregate, statistical form, non-personal information regarding the visitors to our website, traffic patterns, and website usage with our business partners, affiliates or advertisers;
    • BNY Mellon may, in the future, sell or otherwise transfer some or all of its assets to a third party. Your personal information, technical information about your device or browser and/or other anonymous information we obtain from you via the websites may be disclosed to any potential or actual third party purchasers of such assets and/or may be among those assets transferred.

     

    Using Cookies and Other Technologies

    In this section you can find out more about:

    • types of cookies used on our websites
    • third party advertisers
    • third party sites
    • control your cookie settings

    Types of Cookies Used on Our Websites

    We use cookies, web beacons and similar technologies ("Cookies") to track information provided to us by your browser and by our software application when you use our websites. A cookie is a small piece of information that a website stores on the web browser on your device and can later retrieve. "Session" cookies are temporary and will expire at the end of a browser session; that is, when you leave a website. Session cookies allow a website to recognize you and carry information as you navigate between pages during a single browser session and allow you to use the website most efficiently. "Persistent” cookies, in contrast, remain in the cookie file of your browser even after you leave a website and after the browser is closed. They enable a website to recognize you upon your return, remember your preferences and provide tailored services to you. A cookie will not contain information that will enable us to contact you via telephone, e-mail, or other means.

    We, and third party service providers acting on our behalf, use session and persistent cookies to:

    • remember preferences that you submit as well as those generated from your usage data and your responses to polls and surveys on our websites;
    • measure your use of our websites in an effort to improve its quality and enhance your overall experience, including tracking page views, time and date of website access, and other usage data, and identifying your operating system and browser type (but not other information about your computer or the programs on it) and your general geographic location; and
    • allow you to share certain information on our websites via social media bookmarking buttons, email or on social networking sites.

    The third party service providers mentioned above use any personal information they collect on our behalf solely for the purpose of providing the contracted service to us. They have also agreed to confidentiality restrictions.

    We may use aggregated usage data to track trends and analyse patterns on our websites. If you register to enter an area of our websites, the website will recognize who you are and collect all information that you submit (including subscription to emails, etc.). Information collected about you from this website may be associated with other identifying information that we have about you.

    Third Party Advertisers

    We may use third party advertising companies to serve ads on our behalf on other websites across the Internet. To measure and track the effectiveness of such ads, these companies typically use cookies; so a cookie may be set in the cookie file of your browser when you click on one of our ads or visit a webpage associated with our ad campaigns. These companies may also use and measure information about your visits to our Site as part of this same process. The information provided to us by these companies about you will be de-identified.

    Third Party Websites

    Our websites contain links to third party sites (including social media bookmarking buttons that enable you to share certain content to our websites). Although some of the entities controlling these websites are under contract with us, not all of them are, so we advise you to familiarise yourself with the individual privacy and cookie notice and other terms for each linked website prior to submitting your personal information. We are not responsible for and do not have control over their terms of use or privacy notices, have not reviewed them and we do not accept any liability with respect to the content of these websites or how they use cookies and handle your personal information. This privacy notice does not apply to your use of a third party website.

    Control Your Cookie Settings

    Most browsers are initially set to accept cookies. However, you have the ability to change your browser settings. It may also be possible to configure your browser settings to enable acceptance of specific cookies or to notify you each time a new cookie is about to be stored on your device enabling you to decide whether to accept or reject the cookie. You can also disable cookies by configuring your browser setting to reject cookies. Please refer to the help section of your browser for instructions on disabling cookies. For more information about cookies, how they work, why they are so useful and how to disable them, you can visit http://www.allaboutcookies.org/.

    If you do not wish to accept cookies from our website, please either disable them or refrain from using our website. If cookies are disabled, it may mean that you experience reduced functionality or will be prevented from using all or part of our website.

    For information about the cookies used on a specific application, please refer to that application’s cookie notice. For more information about how bnymellon.com collects information using cookies and tracking technologies you can read the Cookie Notice on the Insight website.

     

    Transferring Personal Information Globally

    In this section you can find out more about:

    • how we operate as a global business and transfer data internationally
    • the arrangements we have in place to protect your personal information if we transfer it overseas

    Insight operates on a global basis. Accordingly, your personal information may be processed in countries that are subject to different standards of data protection, including the United States and India. Insight takes appropriate steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests, and that transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. To this end:

    • transfers within Insight and BNY Mellon are covered by an agreement entered into by members of BNY Mellon (an intra-group agreement) which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within BNY Mellon;
    • where we transfer your personal information outside BNY Mellon, or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your personal information; or
    • where we receive requests for information from law enforcement or regulators, we carefully validate these requests before personal information is disclosed.

    You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.

     

    How We Protect and Store Your Information

    Security

    Insight has implemented and maintains a comprehensive information security security management system (ISMS) which is certified compliant with the relevant international standard, ISO 27001. The standard requires written policies and procedures designed to protect the confidentiality and integrity of personal information. The ISMS contains administrative, technical and physical safeguards, appropriate to the type of information concerned, designed to: (i) maintain the security and confidentiality of such information; (ii) protect against any anticipated threats or hazards to the security or integrity of such information; (iii) protect against unauthorized access to or use of such information that could result in substantial harm, and (iv) ensure appropriate disposal of such information. The security of your personal information also depends in part on the security of the devices you use to communicate with us, the security you use to protect user IDs and passwords, and the security provided by your internet service providers.

    Storing and Retaining your personal information

    BNY Mellon will retain your personal information:

    • for as long as required for the purposes for which it was collected, as explained in this notice
    • where we are required to do so in accordance with legal, regulatory, tax, accounting, or necessary technical requirements
    • for longer periods of time in specific circumstances so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe that it may be required in defence of a legal claim.

    In these circumstances your personal information will be subject to a corporate retention plan which incorporates the factors above. For more information on the retention of your personal information, you can contact us.

     

    Legal Rights Available to Help Manage Your Privacy

    Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information. Please note that depending on your location your rights may vary.

    Your may have rights:

    • to access personal information
    • to rectify / erase personal information
    • to restrict the processing of your personal information
    • to transfer your personal information
    • to object to the processing of personal information
    • to object to how we use your personal information for direct marketing purposes
    • to obtain a copy of personal information safeguards used for transfers outside your jurisdiction
    • to lodge a complaint with your local supervisory authority

    We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We may charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive

    You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will use reasonable efforts to honour your request promptly or inform you if we require further information in order to fulfil your request.

    We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

    Right to Access Personal Information

    You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of: (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.

    Right to Rectify or Erase Personal Information

    You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it.

    You can also request that we erase your personal information in limited circumstances where:

    • it is no longer needed for the purposes for which it was collected; or
    • you have withdrawn your consent (where the data processing was based on consent); or
    • following a successful right to object (see right to object); or
    • it has been processed unlawfully; or
    • to comply with a legal obligation to which BNY Mellon is subject.

    We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:

    • for compliance with a legal obligation; or
    • for the establishment, exercise or defence of legal claims.

    Right to Restrict the Processing of Your Personal Information

    You can ask us to restrict your personal information, but only where:

    • its accuracy is contested, to allow us to verify its accuracy; or
    • the processing is unlawful, but you do not want it erased; or
    • it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
    • you have exercised the right to object and we are considering your request.

    We can continue to use your personal information following a request for restriction:

    • where we have your consent; or
    • to establish, exercise or defend legal claims; or
    • to protect the rights of another natural or legal person.

    Right to Transfer Your Personal Information

    You can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where: the processing is based on your consent or on the performance of a contract with you; and the processing is carried out by automated means.

    Right to Object to the Processing of Your Personal Information

    You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.

    If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

    Right to Object to How We Use Your Personal Information for Direct Marketing Purposes

    You can request that we change the manner in which we contact you for marketing purposes.

    You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes

    Right to Obtain a Copy of Personal Information Safeguards Used for Transfers Outside Your Jurisdiction

    You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred to countries not providing an adequate level of data protection.

    We may redact data agreements to protect commercial terms.

    Right to Lodge a Complaint With Your Local Supervisory Authority

    You have a right to lodge a complaint with your local data protection supervisory authority if you have concerns about how we are processing your personal information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

     

    Contact Us

    Please use the email address : privacy@insightinvestment.com for all enquiries in relation to this notice and your rights.

    If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first make contact as described above. We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event within the timescales provided by data protection laws.

    To Contact Your Data Protection Supervisory Authority

    You have a right to lodge a complaint with your local data protection supervisory authority (i.e. your place of habitual residence, place of work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before lodging a complaint with your local supervisory authority

    Employee Privacy Notices

    There is a separate privacy notice relating to the processing of data for employees here.

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