Contact Capital Administration Advisory Sectors About us Privacy Policy EPIC Investment Partners (we, us or our) is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we use any personal data we may collect from you or you may provide to us when you use our website or when you contact us, for example by phone or email. Where you become a recipient of services or make use of products provided by us or one of our group companies, you will be provided with another Privacy Policy that explains how we and/or our group companies will use your personal data as a result of this. This Privacy Policy supplements any such privacy notices and is not intended to override them. 1. Who is responsible for your personal data? We are EPIC Investment Partners LLP, trading as EPIC Investment Partners, and we are the controller of the personal data we collect via our website and when you contact us. Our contact details are: Registered office: Audrey House, 16-20 Ely Place, London, EC1N 6SN Telephone: +44 (0) 20 7269 8860 The contact details of our Data Protection Officer are: Name: Hiren Patel Email: Hiren.Patel@epicip.com If you have any queries, comments or requests regarding this Privacy Policy, you have a complaint or you would like to exercise any of your rights set out at the end of this Privacy Policy, you can contact us using the details set out above. Whilst EPIC Investment Partners operates the website, the website contains information provided by or about EPIC Investment Partners’ group companies. Details of such group companies and links to their privacy policies are provided at [LINK]. Where personal data is provided by or collected from you when you use our website or contact us, this personal data may be shared with one or more of these group companies for the purposes set out in this Privacy Policy. 2. What personal data do we collect? The types of personal data we may collect and use about you will depend on how you use our website or contact us, and the information you choose to provide. The types of information we may collect directly from you are: Name Email address Telephone number Job title and company (if applicable) Interests and preferences The types of information we may collect from you automatically are: IP and MAC address Browser types and language Operating system and platform type General location data- the country from which you accessed our website Software and hardware attributes (including device IDs) Referring and exit pages and URLs The number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on our websites, the date and time you used the website, any form submitted, error logs, and other similar information. We will use this information to assess and improve the performance of our website, our services, our marketing activities and the information we provide. We may use a variety of technologies, including cookies and similar technologies, to assist in collecting this information. Our Cookies Policy sets out information about the cookies we use on our website. 3. Ensuring the lawful use of your data We will only use your personal data where we have a lawful basis to use it. We will only use your data where it is necessary for us to enter into or perform our contract with you (for example, to provide you with products or services you have requested), or in a way which might reasonably be expected as part of running our business and which does not materially impact your interests, rights or freedoms. For example, to respond to a query you have raised or provide you with the factsheets and prospectuses you have requested. Please get in touch with us using the contact details provided at the beginning of this Privacy Policy if you would like further information about this. We may sometimes need to use data to comply with our legal obligations (for example to pass on details related to fraud). In other instances, we will ask for your consent to use your data, for example, to send email or SMS marketing to you. Further details of how we use your personal data are provided below. 4. How and for what purposes will we use your personal data? We use your information for various purposes depending on the types of information we have collected about you and the website features you use. In particular, we collect your information for the following purposes: To contact you in response to your enquiry about our products and services; To provide you with collateral you have requested such as factbooks and prospectuses; To send you email or SMS marketing (where you have consented to us doing so); To personalise the marketing we send you; To respond to you if you report a problem with our website; and To enhance and improve your experience on our website, ensure the security of our facilities and develop the services and products we offer. 5. With whom will we share your personal data? We may share your personal data with other companies within the EPIC Investment Partners group for the purposes set out in this Privacy Policy. This website contains information relating to various EPIC Investment Partners group companies and the services they provide. When you raise a query or request collateral or further information relating to a particular service or group company, we will pass on your details to the group company that is best placed to deal with your query or request for them to respond to you. They will provide you with their own Privacy Policy which explains how they will use your personal data as a result of your interaction with that group company. Our group companies may also share your personal data for analytics and marketing purposes, where permitted by data protection laws. We will only share your personal data with third parties (including our group companies) for them to use for their own direct marketing purposes when you have given your consent for us to do so or it is otherwise permitted by data protection laws. We may also share your personal data in connection with a business transition (such as a merger, acquisition by another company, or a sale of all of or portion of our assets). In these circumstances, we may need to share your personal data with a prospective buyer and external professional advisors such as accountants, insurers, lawyers or financial institutions. We may be required to share your personal data with the police, administrative authorities (such as HMRC) or other enforcement, regulatory or Government bodies, where we are legally obliged to do so. We may also share your personal data with our external professional advisors such as accountants, insurers, lawyers or financial institutions to comply with our legal obligations and enforce our legal rights. 6. International transfer of your personal data As some of our group companies are located in countries outside of the UK and the EEA, it may be necessary for your personal data to be transferred to or accessed from outside the UK and the EEA in order for you to use our website and for us to manage our relationship with you. If we do this, we have procedures in place to ensure your data receives the necessary protections. Where we transfer your personal data to countries deemed to provide an adequate level to data protection by the UK Information Commissioner’s Office, we rely on that decision to transfer your personal data. For transfers of data to group companies outside the UK and the EEA where no adequacy decision applies, we use standard contractual clauses or other transfer tools provided for in the applicable data protection legislation to protect your personal data. Any transfer of your personal data will comply with applicable laws and we will treat the information according to the principles set out in this Privacy Policy. If you would like further information or a copy of the standard contractual clauses we use, please get in touch with us using the contact details provided at the beginning of this Privacy Policy. 7. Keeping personal data secure We will take appropriate technical and organisational measures to keep your personal data confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to personal data. However, the internet is not a completely secure medium. 8. For how long will we retain personal data? We will only keep your personal data for as long as we need to in order to fulfil the purposes for which it was collected, as set out in this Privacy Policy, and for as long as we are required to keep it by law. For further information, please contact us using the details provided at the beginning of this Privacy Policy. 9. Your rights You have certain rights with respect to your personal data which are summarised below. Some of the rights are complex therefore, not all details are included in the summary: Right of access: you can ask for copies of all the information that we process about you; Right to rectification: you can ask to have inaccurate information held about you corrected; Right to erasure: you can ask for the information held about you to be erased (subject to certain criteria); Right to restriction of processing: you can ask us to restrict the processing of your information (under certain circumstances); Right to data portability: you can, under certain circumstances, request that we transmit your personal data to another provider of services. 10. Right to object Where we are processing your personal data on the basis of our legitimate interests, you can ask us to stop processing it and we must do so unless we believe we have an overriding legitimate reason to continue processing your personal data or we need to process it for the purposes of legal claims. 11. Exercising your rights If you would like to exercise any of your rights mentioned above, you can do so by contacting us using the details provided at the beginning of this Privacy Policy. 12. Your right to withdraw consent Where you have provided consent for us to process your information (for example, where you have consented to receiving SMS or email marketing from us), you can withdraw your consent at any time by contacting us using the details provided at the beginning of this Privacy Policy. 13. Your right to make a complaint If you have a complaint about the way we process your personal data or think that we have not complied with your rights, you can make a complaint to your data protection regulator. In the UK, this is: The Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Telephone: 0303 123 1113 or 01625 545745 Fax: 01625 524510 Website: www.ico.org.uk We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner’s Office (or, if you are based outside of the UK, your data protection regulator), so please do contact us in the first instance. 10. Changes to this Privacy Policy and Updating Your Personal Data This Privacy Policy was last updated in July 2021. We reserve the right to update and change this Privacy Policy from time to time in order to reflect any new legal requirements or any changes to the way in which we process your personal data, by publishing the updated Privacy Policy either on our website or in some other way. The changes will take effect as soon as they are published. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us or if you wish to cancel any request you have made of us, by contacting us using the details provided at the beginning of this Privacy Policy. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us. Privacy Policy Cookies Policy Website Terms of Use Corporate and Regulatory Disclosures Acceptable Use Policy © 2021 EPIC Investment Partners LLP. All Rights Reserved EPIC Investment Partners LLP is an appointed representative of EPIC Investment Partners (UK) Limited EPIC Investment Partners (UK) Limited is authorised and regulated by the Financial Conduct Authority EPIC Investment Partners (UK) Limited’s FCA reference number is 217457 EPIC Investment Partners LLP’s FCA reference number is 451580