NEWS ABOUT US CONTACT US CALL US ON 0121 227 6320 HOW WE WORK WITH YOU OUR INVESTMENT SOLUTIONS OUR INVESTMENT APPROACH LITERATURE LOG IN Home About us Website conditions ABOUT TILNEY Our expertise Our team Contact us Our registered details WEBSITE CONDITIONS Last reviewed: 1 August 2014 We set out in this document important terms and conditions that govern your use of this website. You should read this information carefully. By accessing this website, you agree to be bound by these terms and conditions. If you are unclear about its contents please contact us - contact details are to be found on the ‘contact us’ link on this website or below. Owner and operator of this website This website is owned and operated by the Tilney Bestinvest group of companies, comprising the firms Tilney Investment Management Ltd, Bestinvest (Brokers) Ltd, Bestinvest (Consultants) Ltd and HW Financial Services Ltd (“Tilney Bestinvest” or “we” or “us” or “our”). Legal and regulatory status Tilney Investment Management Limited is incorporated in England & Wales under number 02010520. Our registered office is at 6 Chesterfield Gardens, London, W1J 5BQ. Our telephone number is 020 7189 2400. We are authorised and regulated by the Financial Conduct Authority whose address is 25 The North Colonnade, Canary Wharf, London E14 5HS. We are entered on The Financial Services Register with registration number 124255. You can check this on The Financial Services Register, which can be found at fsa.gov.uk/register/home.do or by contacting the FCA on 0845 606 1234. Ownership of the content of this website and restriction of use The entire content of our website is protected by copyright laws and intellectual property rights. You may download and use information and material from our website for your personal use. However you may not copy, reproduce, distribute or modify the content of the Tilney Bestinvest website for commercial or public use without prior written consent from us. You should not rely solely on the information on our website All services and products displayed on our website are subject to their own specific Terms of Business (also referred to as Terms and Conditions), which may change from time to time. If you choose to buy any product or service listed on this website, you should not rely solely on the information contained on our website. You should read carefully the Terms of Business relating to any product or service you intend to purchase. These may be obtained via our website or from us - contact details can be found on the ‘contact us’ link on this website. Type of information we provide on our website We provide information on investments or markets, such as research recommendations, market trends, investment analysis or commentary on the performance of selected funds, companies and other financial instruments (“Investment Information”); various tools to assist you with your own investment decisions; and, non-investment information of a general nature. We do not provide nor intend to provide a personal recommendation or investment advice on our website. Therefore, you must not treat any information on our website as a personal recommendation or as investment advice given to you. If you require a personal recommendation or investment advice please contact us for details on our other services - contact details are to be found on the ‘contact us’ link on our website. Jurisdiction and local laws The information on this website is directed at investors in the UK and does not constitute an offer to sell or invitation to buy securities in any other jurisdiction where such an offer or invitation is unlawful, or where the person making such an offer is not qualified or authorised to do so. Information from this website must not be issued or promoted in any other jurisdiction where prohibited by law and must not be used in any way that would be contrary to local law or regulation. Accordingly, the investment information detailed in our website does not constitute an offer to transact business in any jurisdiction where such an offer would be considered unlawful. The Information does not constitute an offer or solicitation to buy or sell any investment fund or other products, services or information to anyone in any jurisdiction in which an offer or solicitation is not authorised or cannot legally be made or to any person to whom it is unlawful to make an offer or solicitation. For information specific to your jurisdiction, please contact your financial adviser. Data privacy policy Tilney Bestinvest treats the privacy of our investors and potential investors very seriously and we are registered under the UK Data Protection Act. This privacy policy sets out the basis on which any personal data we collect from you will be processed by us. Please note that this privacy policy only applies to this website, so when you link to other websites you should read the privacy policies for those websites. We are not responsible for the privacy policy or practices of third party websites. Information we may collect from you We may collect and process the following data about you: Information that you provide to us when you register with us or in relation to products or services we provide to you, whether via this website, over the phone or by post. The details we hold about you and your transactions (and may also include personal information concerning your family members, if provided to us); and/or Where you are a corporate customer, details we hold about your staff and corporate contacts (including if applicable their individual customers and such customers’ family members), and may include information obtained from third parties; and/or Where you are a trustee of a trust, the details of all trustees and any other beneficial owners, settlors and protectors as we deem appropriate. website usage information which is collected using cookies (see below in the section on cookies). We may keep a record of correspondence with you and we may use tracking technology on any emails which we send to you. Cookies A “cookie” is a small piece of encoded information sent by a web server to be stored on your web browser (e.g. Internet Explorer, Firefox) so that it can remember something about you such as username, password or references at a later date. This process enables us to provide you with personalised information and simplify your user experience. A cookie is installed to ensure that there is a unique identification when a user visits the Tilney Bestinvest website. This cookie enables us to determine what page the user will see next time he/she visits the website. Tilney Bestinvest uses persistent cookies that do not expire at the end of a user session. We also use Session Cookies, which are temporary cookies that remain in the cookie file of your browser until you leave the site. It is important that your browser is set to accept these cookies, otherwise you will not be able to enjoy the site fully. The cookies stored on your web browser do not contain any personal information. The cookies are encrypted and only the Tilney Bestinvest web servers can read them. If you do not know what cookies are, or how to control or delete them, then we recommend you visit http://www.aboutcookies.org for detailed guidance. The following describes the cookies we use on this site and what we use them for. Currently we operate an ‘implied consent’ policy which means that we assume you are happy with this usage. If you are not happy, then you should either not use this site, or you should delete Bestinvest cookies having visited the site, or you should browse the site using your browser’s anonymous usage setting (called “Incognito” in Chrome, “InPrivate” for Internet Explorer, "Private Browsing" in Firefox and Safari etc.) "Session" cookies We use a session cookie to remember your log-in for you, what you’ve put in the basket. These we deem strictly necessary to the working of the website. If these are disabled then various functionality on the site will be broken. More information on session cookies and what they are used for at http://www.allaboutcookies.org/cookies/session-cookies-used-for.html Persistent cookies for site analytics and performance Google Analytics – we use this to understand how the site is being used in order to improve the user experience. User data is all anonymous. You can find out more about Google’s position on privacy as regards its analytics service at http://www.google.co.uk/intl/en/analytics/privacyoverview.html Email tracking Some emails that we send you have no tracking in at all e.g. service emails. Other emails we send we put in tracking so that we can tell how much traffic those emails send to our site. Some emails we can track, at an individual level, whether the user has opened and clicked on the email. Sometimes we do use the personal information e.g. to re-email people who did not click the first time. If you want to be sure that none of your email activity is tracked then you should opt out of Bestinvest’s emails which you can do via any email you receive from us. Survey and contests From time to time our site may request information from users via surveys, contests or for a particular service (e.g. newsletter). Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information. Information requested may include contact information. We will use the contact information to notify winners. We will not publish winners' details on the site though on request we will provide details of any winner's name and location. Uses made of your personal information We may use and share your personal information with other members of the Tilney Bestinvest group of companies and our agents to help us and them: to manage and administer any account(s) you have with us; to offer you investment products and services (except where you have asked us not to do so); to contact you with details of changes to products you have bought; for internal analysis and research; to comply with legal or regulatory requirements, including the prevention of fraud or money laundering; to identify you when you contact us; understand your requirements; recover a debt; assess financial and insurance risks; develop new products and services; provide details of changes to investment products. We may use external third parties to process your personal information on our behalf in accordance with these purposes. Sharing of your personal information with others Where you have notified us of your adviser or other personal representative or where you have chosen our service where your account(s) is linked to those of other individual(s); the personal information provided may be shared with such persons or entities. We do not disclose information about identifiable individuals to our own advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may disclose your personal information to any member of our group, which means our subsidiaries, our holding company and its subsidiaries including their staff and officers. We may disclose your personal information to non-affiliated subcontractors that perform support services for us. We may disclose your personal information to third parties in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets. We may disclose or share your personal information with any regulatory authority, or to any person legally empowered to require such information; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. We may transfer your personal information outside the EEA for the purposes set out above. In such instances we will put in place appropriate safeguards to protect your personal information. Where we store your personal information We will take all reasonable steps necessary to ensure that your data is treated securely and in accordance with this privacy policy. All information you provide to us is stored on our secure servers. 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 to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Your rights You have the right to receive details of the personal information we maintain on you, subject to certain restrictions under the Data Protection Act. We reserve the right to require appropriate proof of identity and to charge an administration fee, currently set at £10.00 per request for providing this information. Please contact us by post or email at the address below if you wish to do this. You may instruct us not to process your personal data for marketing purposes. You can exercise this right at any time by contacting us at the address or email below. Updating your personal information Please let us know if the personal information which we hold about you needs to be corrected or updated. Contact If you have any questions about this privacy policy or our treatment of your personal information, please write to us: by email to info@tilneybestinvest.co.uk; or by post to Tilney Bestinvest, 6 Chesterfield Gardens, London W1J 5BQ; or by telephone on 020 7189 9999. Your data controller For the purposes of the UK Data Protection Act 1998, the data controller in respect of any personal information provided to us is Tilney Investment Management Limited. Our data protection registration number is Z5940263. Changes to our data privacy policy We keep our Data Privacy Policy under regular review and we may update this policy and place a new version on our website. You should check this page occasionally to ensure you are happy with any changes. Complaints We pride ourselves on providing high standards of customer service and care. However, we accept that there may be times when we do not achieve these standards or fall short of the standards you expect of us. If this happens we will make every effort to resolve any outstanding problems quickly and to your satisfaction. You may complain to us by writing or telephoning at the address and telephone number under ‘Legal and Regulatory Status’ (third paragraph of this document). However, should we fail to resolve a complaint to your satisfaction or if we fail to do so within eight weeks of receiving your complaint, you can also direct your complaint to the Financial Ombudsman Service at South Quay Plaza, 183 Marsh Wall, London E14 9SR. Telephone: 0800 0 234 567 or 0300 123 9 123 and their website financial-ombudsman.org.uk/ Security of our website We do not guarantee the security of our website, but we use our best endeavours to maintain it to current security standards. Messages sent over the Internet cannot be guaranteed to be completely secure as they are subject to possible interception or loss or possible alteration. We are not responsible for them and will not be liable to you or anyone else for any loss in connection with any message sent by you to us or by us to you over our website. You should also specifically note that email communication is not secure and you should not send sensitive or personal information in them. Where we provide you with login details you should not share them with anyone else and it is your responsibility to protect them. If you are accessing our website from a shared computer (i.e. one that you do not have sole use of) it is important that you log out of the website when you have finished, otherwise, others may gain access to your login details and access your Bestinvest account(s). Accuracy of information Whilst all reasonable steps have been taken to ensure that the information contained on our website is accurate and complete at the date of publication, no warranty or guarantee is given and no liability is accepted for any loss incurred. Errors or omissions in the information may occur because of a number of factors which are inherent in any Internet access system and are not within our control. The information contained in this website is subject to change without notice. Tilney Bestinvest and any of its affiliates, subsidiaries, officers, directors, employees or agents (collectively, “Tilney Bestinvest” or “we” or “us) provide the website and the information on an “as is” basis. We do not make any express or implied warranties, representations, endorsements or conditions with respect to the website or the information. This includes, without limitation, warranties as to operation, non-infringement, usefulness, completeness, accuracy, currency, reliability and fitness for a particular purpose. Any links on this website that lead to sites maintained by third parties, over which Tilney Bestinvest has no control, are provided solely as a convenience to users and use of those sites will be at your own risk. Supported browsers Our website is designed to work with current versions of the most popular web browsers. The site may not display properly if you are using an old version of an internet browser. In addition we have designed the website to work best with Javascript enabled. If you choose not to turn on Javascript in your browser, you may find some areas of the site have reduced features. No liabilities This paragraph excludes or limits our legal liability for the website. You should read it carefully. It applies only as far as the law permits, and in particular we do not exclude or restrict our duties and liabilities to you under the Financial Services and Markets Act 2000 (the “Act”), or the rules of the Financial Conduct Authority (“FCA”) for the conduct of business. Bestinvest is not responsible for and will not be liable to you or anyone else for any damages whatsoever (including direct, indirect, incidental, special, consequential, exemplary or punitive damages) arising out of or in connection with your use of or inability to use the website or the information, or any action or decision made by you in reliance on the website or the information, or any unauthorised use or reproduction of the website or the information, even if we have been advised of the possibility of these damages. MENU Our team Our investment solutions Our investment approach Literature POLICY Cookie policy Website conditions Risk warnings GET IN TOUCH Email us Tilney Investment Management is authorised and regulated by the Financial Conduct Authority. Registered in England. (No. 02010520). Registered office: 6 Chesterfield Gardens, Mayfair, W1J 5BQ. IMPORTANT INFORMATION This website has been prepared for use by professional advisers and intermediaries only. It is not intended for use by retail clients. The value of your investment can go down as well as up, and you can get back less than you originally invested. Past performance or any yields quoted should not be considered reliable indicators of future returns. Restricted advice can be provided as part of other services offered by Tilney, upon request and on a fee basis. Before investing in funds please check the specific risk factors on the key features document or refer to our risk warning notice as some funds can be high risk or complex; they may also have risks relating to the geographical area, industry sector and/or underlying assets in which they invest. Prevailing tax rates and relief are dependent on your individual circumstances and are subject to change.