Privacy
Privacy Policy
This Privacy Policy explains how Majedie Asset Management Limited collects, uses and discloses the personal data you may provide, and your rights in relation to the personal data we hold.
In this Privacy Policy, “Majedie”, “us”, “we” and “our” refers to Majedie Asset Management Limited.
We may amend the Privacy Policy from time to time, including to reflect changes in law and in the way we process your personal data.
This Privacy Policy will apply from 1 January 2021.
It will supersede any previous version which you may have been provided with or have had access to.
Data Protection
Majedie will process your personal data as a data controller and is subject to the Data Protection Act 2018 (“DPA”).
Your Rights
Under the DPA, you have the following rights:
To have access to, and copies of, your personal data;
To require rectification of your personal data, if it is incorrect;
To require us to erase your personal data;
To require Majedie not to send you marketing communications;
To require Majedie to restrict processing of your personal data;
To object to Majedie processing your personal data; and
To transfer your personal data to another data controller.
Please note that these rights are not absolute and we may be entitled to refuse requests where exceptions apply.
More information on these rights and exceptions can be found at www.ico.org.uk.
What Information do we collect?
We may collect personal information in the following ways:
From information you provide to us via our employees, telephone, email or other forms of electronic communication (e.g. Contact Us forms);
When you complete an application form into a Majedie fund;
From third parties, including your agents, advisers and service providers; and
From publicly available sources.
What categories of data do we collect?
This Privacy Policy applies to all individuals for whom we may hold personal data, including clients, investors in Majedie funds and employees. Depending on your relationship with Majedie, we may (where relevant) collect the following categories of personal data about you:
Name, address, email address, telephone number;
Date of birth, tax identification number, passport number or equivalent details;
Information about your employment, education, family and personal circumstances and interests;
Financial information, including, where relevant, bank account details; and
Information or background checks for anti-money laundering/client due diligence purposes and for employee vetting.
What is the purpose & basis of collection?
Majedie processes personal data to enable us to provide investment management services, to operate the Majedie funds, to promote our investment management services and the Majedie funds, to manage our business, including reporting to and communicating with regulatory, fiscal, law enforcement and other governmental bodies and maintain our own accounts and records, and to manage and support our employees. The processing of personal data will be necessary for our compliance with a legal obligation, for our legitimate interests, or for the performance of a contract to which you are a party.
How is the data used and who do we share it with?
Depending on your relationship with Majedie, we may use your personal data:
To provide our investment management services;
To operate the Majedie funds;
To determine whether you may invest or continue to invest in the Majedie funds;
To perform our reporting obligations to and communicate with clients (e.g. via MajIQ);
To comply with our anti-money laundering and client due diligence obligations; and/or
To manage and support our employees.
Failure to provide us with personal data will prevent us from using your personal data as described above.
Sharing personal data
Majedie may sometimes need to share the personal data we process with other organisations. Where this is necessary, we are required to comply with all aspects of the DPA. What follows is a description of the types of organisations we may need to share some of the personal information we process with for one or more reasons.
Where necessary or required, we share information with:
Current, past or prospective employers;
Suppliers;
Service providers;
Other financial organisations;
Suppliers;
Regulatory, fiscal, law enforcement and other governmental bodies; and
Professional advisers.
Transfer of personal information
It may sometimes be necessary to transfer personal data outside the European Economic Area. When this is needed, information may be transferred to countries which may not have the same or equivalent data protection laws to the United Kingdom. Any transfers made will be in compliance with the DPA.
How long is personal information retained?
Subject to regulatory requirements, your personal data will be stored for no longer than is necessary for the purpose for which it is collected. Majedie is currently required to retain records of its business and internal organisation for a period of a least 5 years. There is no automated decision-making, including profiling when your personal data is submitted.
Website Usage Information
We may store and analyse site usage information in order to improve our website, but this information is aggregated and not used in any way to track individual users. Website usage information is collected using one or more cookies. See below for further information on cookies.
Telephone Calls
Telephone calls to Majedie may be recorded in order to comply with regulatory requirements.
Contact Information
If you have any questions about this Privacy Policy or your data protection rights, please write to:
Legal Team
Majedie Asset Management Limited
10 Old Bailey
London
EC4M 7NG
Or use the contact us form at the bottom of this page.
Cookies
Majedie’s Cookie Policy can be found here.
Complaints
If you would like to make a complaint with regards to Majedie’s processing of your personal data, you can contact the Information Commissioner’s Office through their website www.ico.org.uk/global/contact-us or in writing to the following address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
January 2021