Privacy

Information about you that we collect and use includes:

• Information about who you are e.g. your name, date of birth and contact details
• Information connected to your product or service with us
• Information about your contact with us e.g. meetings, phone calls, emails / letters
• Information that is automatically collected e.g. via cookies when you visit one of our websites
• Information if you visit one of our offices e.g. visual images collected via closed circuit television (CCTV)

Where we collect and use sensitive personal information, this information will only be collected and used where it's needed to provide the product or service you have requested or to comply with our legal obligations, and where we have also obtained your explicit consent to process such information.

We may collect your personal information directly from you, from a variety of sources, including:

• Phone conversations with us
• Emails or letters you send to us
• Meetings with us
• Registering for one of our events
• Participating in research surveys to help us understand you better and improve our products and services
• Our online services such as websites, social media and mobile device applications

If you have a financial adviser, the information we collect and use will most likely have been provided by them on your behalf.

We may also collect personal information about you from places such as business directories and other commercially or publicly available sources e.g. to check or improve the information we hold (like your address) or to give better contact information if we are unable to contact you directly.

We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only if we are able to satisfy one of the lawful processing conditions set out in the data protection laws. This will be the case where:

• it's necessary to provide the product or service you have requested e.g. if you wish to invest in one of our funds or products we will require some personal information which may include your name, address, date of birth, and bank account details
• it's necessary for us to meet our legal or regulatory obligations e.g. to send you Annual Reports or Statements, tell you about changes to Terms and Conditions or for the detection and prevention of fraud
• it's in our legitimate interests i.e. to deliver appropriate information and guidance; where we need to process your information to better understand you and your needs so we can send you more relevant communications about the products you have with us and to develop new products and services. Where the processing is in our legitimate interests, we will always conduct an assessment to ensure that this use of your personal information is not excessive or unnecessary or otherwise more intrusive than it needs to be
• you have given us your permission or consent to use your information in this way. For example, if we are collecting and using your sensitive personal information or for certain types of direct marketing
• If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with our products or services.

Where you have given your permission to do so (or when given the opportunity have not objected), we will send you information about products and services offered by us and/or partners with whom we have entered into sponsorship arrangements or similar partnering arrangements. Even though the materials may refer to the third party, we (and not the third party) will send you the information about such events and sponsorship activities. These are parties we have chosen to work with whose products or services we believe may be of interest and benefit to you.

You can withdraw your consent or manage your preferences by contacting the data protection officer, details above.

We may share your information internally, and with third parties for the reasons outlined in ‘Why we collect and use your information'.

We will share your information with:

• Parts of the Pacific Investments group who support us in the provision of the product or service you have
• Credit reference agencies for the purposes of conducting a credit check and ID verification
• Companies we have chosen to support us in the delivery of the products and services we offer to you and other customers. For example, registrars, research, consultancy or technology companies who help us improve our service to you
• Companies who can help us in our contact with you, for example an internet service provider
• Our regulators; including the Financial Conduct Authority and the Information Commissioner's Office (the ICO) in the UK
• Law enforcement and other appointed agencies who support us (or where they request the information) in the prevention and detection of crime; and HM Revenue & Customs (HMRC) for the purposes of tax reporting where necessary.

The majority of your information is processed in the UK and European Economic Area (EEA).
However, some of your information may be processed by us or the third parties we work with outside of the EEA, including countries such as the United States, Hong Kong, Singapore, and India.
Where your information is being processed outside of the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK / EEA data privacy laws e.g. we will put in place legal agreements with our third party suppliers and do regular checks to ensure they meet these obligations.

We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.

Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.

To meet our legal and regulatory obligations, we keep your personal information and copies of records we create (e.g. calls with us) while you are a shareholder, client or customer of ours.

Even when you no longer have a relationship with us, we are required to keep information for different legal and regulatory reasons. The length of time will vary and we regularly review our retention periods to make sure they comply with all laws and regulations.

You have a number of rights under data protection laws which may be exercised in certain circumstances. These are:

• the right to be informed about how and why we are processing your personal information
• the right of access to personal information relating to you
• the right to rectification of inaccurate or incomplete personal information
• the right to request erasure of your personal information
• the right to restrict processing of your personal information
• the right to data portability
• the right to object to processing of your personal information (e.g. profiling or direct marketing)
• the right not to be subject to automated decision making (including profiling) which significantly or legally affects you

More information can be found on your rights and how to exercise them on our website.

We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our Privacy Policy, please let us know immediately and we will do our utmost to make things right.

While we hope that we can resolve any complaints for you, you do have the option complain to your local data protection authority (e.g. the ICO in the UK). This is available to you whether or not you have exhausted our complaints procedure.

You can find your local data protection authority on the Europa website.