This Privacy and Cookies Policy (together with the website Terms and Conditions) explains what happens to any personal data that you provide to us, or that we may learn about you while you visit our websites (the “Website”), attend Woodford events, visit our offices, use our services or invest in one of the funds discretionary managed by us. This notice also informs you about your privacy rights and how the law may protect you.
We update this Policy from time to time, so please do review it regularly.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
How and from where we may receive personal data
- When you contact or correspond with us (for example, by phone (including during recorded calls), e-mail or otherwise) for any other reason (for example, to request services from us);
- When you use our Website, post comments on our Website or via social media;
- When you report a problem with the Website;
- When you:
- register to receive information from us;
- meet with us;
- attend our events;
- interact with us at third party events;
- hand us your business card;
- subscribe for blog alerts and bulletins;
- sign up to receive news and updates from us;
- participate in our surveys, competitions, questionnaires etc.; or
- When you provide us with feedback, opinions and / or comments regarding the Website or our services.
Data from other sources
Like many other businesses, we may receive personal data from many sources. This section seeks to list various places from where we may receive personal data about you.
Data we indirectly gather about you:
- When you use the Website, details of your usage (including the date, time, location or duration of the usage);
- If you visit the Website, certain technical information, for example, the type of device (and its unique device identifier) you use to access the Website, the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, mobile network information and platform; and
- Information about your visit to the Website including the full Uniform Resource Locators (URL), clickstream to, through and from the Website (including date and time), pages you viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Data we may receive from third parties
- Companies that introduce you to us (such as financial advisers)
- Financial advisers
- Investment platforms through which you access our clients (investment companies and funds)
- Investment fund administrators or shareholder/unitholder registrars
- Social networks (e.g. Google, Twitter – see below for further details and our cookies policy below)
- Public information sources such as Companies House or the Financial Conduct Authority’s Register
- Market researchers/Data providers who collect and provide personal data from many sources for the specific and approved purpose of sharing such data with businesses like ours to help with our internal analysis (including assessing market trends, fund distributions statistics etc).
- Marketing partners engaged to help distribute content on us and our services through any medium
- Agents, consultants and advisers. These can be specialist companies who advise us on ways to develop and improve our services and products. These can also be types of firms that help us to prevent, detect and reports unlawful acts and fraudulent behaviours, in particular with regards to financial crime.
- Government and law enforcement agencies
Purpose and legal basis for processing your data
|Purpose of processing||Type of personal data||Legal basis for processing|
|To enable us to check your identity||Name, address, date of birth, passport details, driving license details and any other information you may provide us with||Legal obligation|
|To enable us to complete anti-money laundering checks to prevent financial crime and guard against market abuse activities||Name, address, date of birth, passport details, driving license details and any other information you may provide us with||Legal obligation|
|To deal with any enquiries, correspondence, concerns or complaints you have raised||Name, phone number, email address and details of the enquiry raised||Legitimate interests – to enable us to improve our services and the Website|
|To process any relevant payments||Bank, credit or debit card details||Performance of a contract with you|
|To enable us to process a referral from a third party (for example, a financial adviser)||Name, address, telephone number, email address, details of the referral and details of the third party making the referral||Legitimate interests – to enable us to process the referral|
|To compile internal reports and statistics of usage of the Website and our products and services||Name, details of any products or services purchased and the technical information mentioned above||Legitimate interests – to enable us to develop and manage our brands, products and services|
|To process your registration made via our Website to enable you (whilst acting on behalf of your company) to access the Woodford services||Your name, email address and company details (if applicable)||Legitimate interests – to enable us to provide you (where you have registered on behalf of your company) with Woodford online services|
|To send you our news items, marketing materials, product information, blog posts, insights and articles via email||Your name and email address||Legitimate interests – to enable us to communicate with business contacts or Consent – where we contact you in your personal capacity, for example where you are a user of our Website|
|To provide you with information, products or services that you request from us or which we feel may interest you||Your name and email address||Legitimate interests – to enable us to communicate with business contacts or Consent – where we contact you in your personal capacity, for example where you are a user of our Website|
|To assess how people use our products and services||Technical information as mentioned above||Legitimate interests – to enable us to improve our products and services|
|For our internal operations, including data analysis, testing, research, statistical purposes and troubleshooting||Technical information as mentioned above||Legitimate interests – to enable us to improve our products and services|
|As part of our efforts to keep the Website safe and secure||Technical information as mentioned above||Legitimate interests – to enable us to improve our products and services|
|To communicate with you if you wish to post on our Website||Your name, contact details, details of the post you wish to make and technical information as mentioned above||Legitimate interests – to review your request|
|To invite you to Woodford events||Your name, email address and details of the event||Legitimate interests – to allow us to obtain attendees for Woodford events|
|To enable us to host an event||Your name, email address, details of the event and any applicable dietary requirements (including relevant medical information)||Legitimate interests – to allow us to host Woodford events for attendees The legal basis for processing any medical information to ensure we adhere to your dietary requirements and allergies will be consent.|
|To enable us to comply with our health and safety obligations when hosting an event (such as fire marshal duties)||Your name and details of the event you are attending||Legal obligation|
|To administer any quizzes and prize competitions we may run||Your name, email address, telephone number and your prize competition entry or quiz entry||Legitimate interests|
|To run polls in which you may choose to participate, for example via Twitter. We may then use the results of our poll (including your views) to inform our market insight or articles we may write||Your Twitter handle (or other relevant social media handle), the IP address associated with you (if relevant) and details of your response to the poll||Legitimate interests – collecting and analysing information for market analysis purposes, which you submit voluntarily|
|To receive feedback on our corporate governance and performance, including any views of investors in the funds that we manage||Your name, email address, telephone number and details of the feedback provided||Legitimate interests – collecting and analysing feedback on our performance and the performance of funds that we manage|
|To personalise the content you may see from us online (either on our Website or the websites of our online partners) if you have agreed to targeted advertising cookies||Your IP address and your consent to the use of targeted advertising cookies||Consent|
|To share your details (where you are an independent financial adviser business contact) with suppliers who carry out market analysis and information relating to IFAs, to enable them to take you into account in their research and analysis||Your name||Legitimate interest of the supplier – to carry out research and analysis on IFA market activity and publish information a directory of such activity – we would contractually require suppliers to whom we provide data to comply with data protection laws in their use of that data|
Where we have a legal basis to use your personal data without consent (as we have described above), this Privacy and Cookies Policy fulfils our duty to process personal data fairly and lawfully and in a manner that you would expect given the nature of our relationship with you, by giving you appropriate notice and explanation of the way in which your personal data will be used.
Where consent is required for our use of your personal data as described above, we will request your consent. Typically, we would collect your consent by you performing an action such as ticking the appropriate consent box or otherwise communicating your consent to us (for example, by email or by you providing us with non mandatory information), you consent to our use of that personal data as set out in this policy.
You can always change your mind about our processing of your personal data. If you change your mind you can contact us by email at firstname.lastname@example.org, or in respect of marketing messages you can unsubscribe by using the unsubscribe link at the bottom of our marketing messages.
No cookies used by Woodford store personally identifiable data such as:
- Phone numbers
- Email addresses
- Mailing addresses
- Financial data
If you would like to limit or block the usage of cookies, you can do so in your browser settings. These settings differ between browsers.
If you choose not to allow cookies, the quality of your browsing experience may be reduced and you may not be able to access all or parts of the Website. You can opt out of some individual cookies as described below.
For more detailed information about cookies and how they can be managed and deleted, please visit www.allaboutcookies.org.
Retaining personal data
We will retain the personal data we receive or collect about you for the period reasonably required for us to use it in accordance with this Privacy and Cookies Policy or in accordance with our legal rights and obligations. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
You have the following rights with regard to your personal data:
- Access: You have the right to access data we hold about you. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Rectification or erasure: You have the right to request that we rectify or delete any personal data that we hold about you (unless we have the legal right to retain it). If you request that we erase any personal data that we require in order to provide our products and services to you, you may no longer be able to use it. This right does not extend to non-personal data. It is likely to be necessary for us to retain your personal data to enable us to carry out a contract with you, and your rights under applicable law to request erasure may be limited accordingly. This means your rights under applicable law to request erasure may be limited accordingly.
- Data portability: You have the right to obtain personal data we hold about you, in a structured, electronic format, and to transmit such data to another data controller if the legal basis for processing such personal data is consent or on the basis of performance of a contract.
- Restriction: You also have the right to restrict us from processing your personal data if the data is inaccurate, the processing is unlawful or we no longer need to your personal data for the purposes for which we hold it.
- Object / Change of preferences: You have a right to request that we stop processing your personal data where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your personal information for direct marketing purposes. For example, if you have given your consent to receive updates from us about new products or services, but have changed your mind, you have the ability to opt out from receiving such communications going forward by contacting us using the details provided below or clicking the relevant link in any communications you receive. Please note, if you submit a request for us to stop processing your personal data in a certain way and this type of processing is required in order to provide you with our products and services, you will no longer be able to use our products and services following your request for us to stop the relevant processing.
- Complaints: If for any reason you are not happy with the way that we have handled your personal data, please contact us. If you are still not happy, you have the right to make a complaint to the Information Commissioner’s Office.
Please note that if you ask us to stop processing your personal data in a certain way or erase your personal data, and this type of processing or data is needed to facilitate your use of any of our products or services you may not be able to use them as you did before. This does not include your right to object to direct marketing, which can be exercised at any time without restriction. Please allow at least 5 working days for your request to be actioned.
Please note that the rights mentioned above do not extend to non-personal data. Please also note that it is likely to be necessary to retain your personal data for the purposes of assessing and verifying data that is submitted by you and to manage our products and services, so therefore your rights under applicable law to request erasure may be limited accordingly.
If you would like to exercise any of the rights mentioned above, please contact us at email@example.com.
Disclosure of your personal data
- investment funds/trust or companies (including their agents or service providers) discretionary managed by us, such as the LF Woodford Equity Investment Fund;
- other companies in the Woodford Group and their agents;
- service providers (for example, IT services), business partners, suppliers and sub-contractors for the performance of any contract we enter into with you, and for processing of our data on the basis of our legitimate interest (as we have explained in this policy) including providing you with marketing communications or developing and tailoring products. Such service providers may help us to update your records, carry out marketing fulfilment services (such as distributing our materials and reports) and help us analyse data for our own internal purposes;
- analytics, market researchers, data partners and search engine providers that assist us in the improvement and optimisation of the Website, our services, our products and their distribution;
- government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons (this may include your location information);
- in the event that we sell any business or assets or receive investment into our business, in which case we may disclose your personal data to the prospective buyer or investor;
- if we or substantially all of our assets are acquired by a third party, in which case personal data held by us, including your personal data, will be one of the transferred assets; and
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the Terms and Conditions for our website or any other contract between you and us;
- or to protect the rights, property or safety of Woodford, our users, and others.
Storing your personal data and transferring data outside of the EEA
In operating our website and our services it may become necessary to transfer data that we collect from you to locations outside of the European Economic Area (EEA), such as the US and Australia, for processing and storing. By providing your personal data to us, you agree to this transfer, processing or storing. This may involve the transfer of data by electronic media, including the internet.
There is no adequacy decision by the European Commission in respect of the US or Australia which means that the laws of these countries are not deemed to provide an adequate level of protection to your personal data. However, to ensure that your personal data receives an adequate level of protection we may implement any mechanism that is approved under data protection laws to ensure that your personal data is treated by those third parties in a way that is consistent with EU and UK laws on data protection. These measures could include the following:
- EU-US Privacy Shield; and/ or
- EU standard contractual clauses.
If you would like to find out more about this or obtain a copy of the relevant standard contractual clauses, please contact us at firstname.lastname@example.org.
Our Website can also be accessed and used worldwide, which means your data may be processed outside the EEA. Please note that the country from which you are accessing personal data may not provide an adequate level of protection for your personal data.
All information you provide to us is stored on secure severs. We will use appropriate technical and organisational measures to safeguard your personal data.
Where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
We maintain (and ensure that anyone we share your personal data with maintains) appropriate technical and organisational measures to ensure that an appropriate level of security in respect of all personal data we process. Unfortunately the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via the website or any of our services; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access or inadvertent disclosure.
Third party links
Letting us know if your information is incorrect
If any of the information which we hold about you is incorrect, please tell us and we will amend it. You can write to us at Woodford Investment Management Ltd, 27 Old Gloucester Street, London, WC1N 3AX or email us at email@example.com.
How to complain
This section tells you how you can contact us to complain about our data privacy processes and how you can contact appropriate government regulators.
Please let us know if you are unhappy with how we have used your personal data. You can contact us using firstname.lastname@example.org.
You also have the right to complain to the regulator, and to lodge an appeal if you are not happy with the outcome of a complaint.
In the UK this is the Information Commissioner’s Office. Find out on their website how to report a concern.
How to withdraw your consent and implication of not providing personal data
This section explains what to do if you no longer want us to hold or use your personal data. This section also explains the effects of not choosing to provide personal data.
You can withdraw your consent at any time. Please contact us at email@example.com if you want to do so.
This will only affect the way we use information when our reason for doing so is that we have your consent.
If you withdraw your consent or do not provide minimum personal data (like contact details), we may not be able to
- provide information on certain products or services to you;
- keep you informed on our business developments;
- contact you regarding your desire to post on our website; or
- report back to you on the status of any complaints you have made.
Please contact us if you have any questions relating to this Privacy and Cookies Policy at firstname.lastname@example.org.