More Privacy & Cookies Policy Enhance Group Limited is comprised of various entities across multiple jurisdictions (collectively, the “Enhance Group” or “Enhance”). This Privacy & Cookies Policy applies to the use of the Enhance Online Services and to the Enhance Group’s use of personal data / information gathered. Enhance Online Services comprises the Enhance Website and Client Portal, which have terms and conditions known as Website Terms and Client Portal Terms respectively in our legal documentation. Enhance Privacy Pledge At Enhance our purpose is to optimise investment performance for fiduciary, family office and charity investors around the world. Through interaction with our business and use of our Monitoring, Portfolio and Consultancy services we are committed to the principles of respecting your privacy, keeping your personal data safe and keeping the decision as to how your information is used and shared in your hands. Our privacy pledge: Enhance will only collect personal data that is useful and necessary for providing its services, improving its products, services and your experience; Enhance will maintain fairness and transparency, at all times with regards to how we collect and process personal data; Enhance will never sell your personal data and will only share your personal data when given your explicit consent to do so for a specific reason or where it is in our legitimate interests to utilise your data in specific circumstances; Enhance will never make decisions based solely on automated processing or profiling of personal data; and Enhance will always take the security of your personal data seriously. To learn more about the personal data collected by Enhance, please read our full Privacy & Cookies Policy below. Data Collection and Processing Subject to the relevant local laws, Enhance may process certain information about you if this information is necessary in order to perform our contract with you, if you give your consent, or where it is in our legitimate interests in order to provide our services to you in the most expedient manner. This personal data may include what is known as Personally Identifiable Information (PII). PII includes personal data that could personally identify you as a natural person such as your name, email, postal address or data that could be used in such a manner so that it could reasonably be linked back to you. Enhance processes your personal data in line with this Privacy & Cookies Policy and terms and conditions relevant to any contractual services relationship with you to provide you with the information that is of most interest to you, and deliver the services you have requested. Automated Profiling Enhance does not carry out automated profiling and will not make any decisions based on the automated processing of personal data. Sensitive Data Enhance does not seek to collect special categories of personal data (“sensitive data”), including but not limited to data revealing racial, or ethnic origin, political opinions, gender, religious or philosophical beliefs, health, genetic and biometric data, or trade union memberships, through this site. Please note that, if you freely provide Enhance with unsolicited sensitive data, subject to the relevant laws, you are explicitly consenting Enhance to use the said data in conformity with this Privacy & Cookies Policy. Using Enhance Online Services Enhance Website Enhance maintains one public website (www.enhance.group), known as Enhance Website or “Site” herein; We collect some personal data from anyone who visits our Site(s). When you enter an Enhance Site(s) we collect industry standard log data that records information about your visit, such as your browser type, the URL of the page that referred you, the different pages you visited and the amount of time that was spent on those pages. Enhance uses Google Analytics to gather this data and we use this type of information to ensure our Site is working properly and make improvements; for example, we may expand upon the information on the most frequently visited pages. This data may be shared across jurisdictions with multiple entities within the Enhance Group in accordance with local laws. We also collect data for cookies. For more details on what cookies are and how they are used, please ready our full Cookie Policy below. Client Portal Enhance maintains one secure web application ( www.mosaic.enhance.group/portal ), known as Client Portal; Client Portal is delivered as a user interface for clients of Enhance in order to view and interact with data relevant to the services provided. In addition, Client Portal provides clients with access to investment intelligence and management information. The level of access to data is determined through a permissions structure tied to the login credentials of the user of Client Portal. These permissions are based on the principle of least privilege and are subject to change from time to time. Link to Third Parties' Websites Enhance Privacy & Cookies Policy does not apply to third-party websites which Enhance Online Services link to or which advertise on Enhance Website or Client Portal. These third-party websites will have their own cookies and operate their own Privacy & Cookies Policy which we encourage you to read before disclosing any of your personal data. Cookies Policy This Cookies Policy is part of our Privacy & Cookies Policy. Enhance Online Services uses cookies to ensure that you receive the best user experience possible on Enhance Website and Client Portal. What are Cookies? Cookies are text files that are sent by servers to web browsers and stored on your computer. The cookies tell us which parts of the Enhance Site(s) you have visited so that we can ensure we provide you with information that you are interested in and make any future visits to our website simple and easy for you. The information and data collected by Enhance cookies expire after two years. Social Buttons: Social media tools, like widgets and plug-ins, are sometimes used so that you can share information from Enhance on other sites such as Twitter. These interactive mini-programs collect your IP address, record the pages you visit on our site, and set cookies that will enable the widget to function properly. Your interactions with these widgets are governed by the Privacy & Cookies Policy of the company providing them, not by Enhance’s Privacy & Cookies Policy. We may also use Twitter, Facebook and LinkedIn pixel tags to help us understand how effective our marketing is on those sites. Browser control: You can decline the use of cookies at any time by modifying your browser settings. By deleting or declining cookies, you may not be able to use some interactive features or access certain areas of Enhance Online Services that depend on cookies. If you do wish to decline the use of cookies please refer to the instructions for your file management software. Most browsers allow you to see what cookies you have and delete them on either an individual basis, or block them. You can block cookies for specific websites or for all websites, depending on your preferences. Email Marketing If you are subscribed to one of Enhance’s marketing lists, we may occasionally send you relevant updates. When you receive marketing emails from Enhance, we may use web beacons, customised links, or similar technologies to determine whether the e-mail has been opened and on which links you click, to provide you more focused e-mail communications or other information in the future. Unsubscribing You can stop the delivery of marketing emails from Enhance at any time by Unsubscribing/Opting Out. We include a link at the bottom of every marketing email which you can utilise to update your preferences by selecting and deselecting lists based on your personal interests, or you can unsubscribe from ALL marketing communications if you so wish. Alternatively you can make a direct request to unsubscribe by emailing the following address: privacy@enhance.group . Please note, that by unsubscribing from ALL marketing emails Enhance will proceed to remove your contact details from all mailing lists and place you on a “no mail” list. Alternatively you can update your subscription preferences to unsubscribe from certain mailing lists and remain on others that you feel are more relevant. If you wish to amend or update your subscription preferences at any time please use the link at the bottom of any Enhance marketing email or contact privacy@enhance.group. Cross Border Transfers and Third Parties Enhance may share your personal data with: Enhance Group, which includes any Enhance subsidiaries and affiliates part of the Enhance network of companies; Enhance services providers (third parties) who process information on Enhance’s behalf, including providers of information technology, identity management, website hosting and management, data analysis, data back-up, security and storage services; or, Other third parties where you have given your consent to the disclosure (either to Enhance or the third party). Enhance Group operates in compliance with the relevant data protection laws and regulations. Enhance services providers are legally obliged to follow Enhance express instructions in respect of the use of your personal information and they must comply with appropriate security measures to protect your personal information. Information Security Enhance is committed to protecting the security of your personal data. Enhance has implemented generally accepted standards of technology and operational security in order to protect personal data and information from loss, misuse, alteration or destruction. Enhance ensures that all appropriate confidentiality obligations and technical and organisational security measure are in place to prevent any unauthorised or unlawful disclosure or processing of such information and data and the accidental loss or destruction of or damage to such information and data. Only authorised Enhance employees and services providers are allowed to access the data and they are legally obliged to ensure confidentiality of this information. Data Retention The data you submit to Enhance will only be retained for as long as is required for the purposes for which it was collected or as required by the relevant laws. When the data is no longer necessary to the purpose for which it was collected; Enhance will proceed to erase all your personal data held in its systems without undue delay. Right of Access and Correction Subject to the relevant laws, you have the right to know what personal data we hold about you. If you would like a copy of the information you are entitled to, you may contact Enhance by email to info@enhance.group. Please note that for the execution of this request, you must provide us with a clear identification of yourself and the personal data you require. Also, you have the right to request rectification of inaccurate personal data concerning to you. If you would like to exercise this right, you may provide Enhance with a supplementary statement by email to info@enhance.group. Please note Enhance does not assume responsibility for verifying the ongoing accuracy of the personal data provided. Right to be Forgotten If at any point you wish to withdraw your consent for Enhance holding your personal data you can contact us and request this via the following email address: info@enhance.group. Please note, if you wish to exercise your “right to be forgotten” we recommend that you authorise Enhance to retain your information on its “no mail” list. If you are totally removed from the system you could be legitimately and legally added back into the system at some point in the future and therefore could receive future communications from Enhance. If your data is kept on the “no mail” list you will never receive marketing communications from Enhance again, unless you change your preferences and explicitly request it. Legal Disclosure Enhance may disclose your personal information to law enforcement, regulatory, or other government agencies or to other third parties as required by, and in accordance with, applicable laws or regulations. Contact and Complaints If you have any questions about this Privacy & Cookies Policy, you may contact us via info@enhance.group or via regular mail to: Enhance Group Limited 3rd Floor 29-31 Esplanade St Helier Jersey JE2 3QA Should you wish to make a complaint to the Office of the Information Commission in respect of Jersey matters please contact enquiries@oicjersey.org or in respect of UK matters www.ico.org.uk/concerns. Amendments Enhance may update the terms of this Privacy & Cookies Policy in line with new regulations or directions by the relevant Information Commissioner at any time and without notice. When we make changes to this Statement, we will amend the revision date at the bottom of this page, and such modified or amended Privacy & Cookies Policy shall be effective concerning you and your information as of that revision date. We encourage you to periodically review this Privacy & Cookies Policy to be informed about how we are protecting your information. Last Updated: 22nd October 2020. LinkedIn Twitter Facebook Monitoring Portfolio Consultancy Mosaic Team Careers Publications Contact Website Terms Privacy & Cookies Policy This website is provided for information purposes only and is not to be construed as financial advice. It promotes the services of Enhance Group Limited, which wholly owns the trading companies Enhance Investment Reporting Limited and Enhance Wealth Consultancy Limited. Enhance Wealth Consultancy Limited is regulated by the Jersey Financial Services Commission to conduct investment business under the Financial Services (Jersey) Law 1998. 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