Privacy Policy

What is the purpose of this document?

This privacy notice describes how Freedom Asset Management Limited (“Freedom”) and its Group companies collects and uses personal information about you in accordance with the applicable data protection legislation.

Freedom recognizes the importance of this data and the risks related to its possession of such data. Freedom is committed to protecting the privacy and security of your personal information.

Freedom is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. To comply with data protection legislation and best practice we are required to notify you of the information contained in this privacy notice.

This notice sets out your rights under applicable data protection laws as well as our commitment to you regarding how we treat your data. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Freedom Asset Management Limited Group

Together Freedom Asset Management Limited, Freedom Asset Management (Asia) Limited, and Freedom Asset Management, Middle East Branch form “Freedom Group”.

We have appointed a Freedom Group Information Officer to oversee compliance with this privacy notice for the Freedom Group.

If you have any questions about this privacy notice or how we handle your personal information, please contact your Freedom Local Information Officer or the Group Information Officer, contact details of whom are set out below. You have the right to make a complaint at any time to your local regulator for data protection and privacy issues. You can also request data access and corrections from local information officers. Details of the information officers and local regulators are also set out below:

Freedom Group Information Officer

Charles Vorster

+44 1481 727300 Investor@freedomasset.com

Guernsey

Local Information Officer:

Charles Vorster

+44 1481 727300

Investor@freedomasset.com

Regulator: Office of the Data Protection Authority

Abu Dhabi

Local Information Officer:

Charles Vorster

+44 1481 727300

Investor@freedomasset.com

Regulator: Office of Data Protection

Hong Kong

Local Information Officer:

Anson Chau

+852 6433 8534

Investor@freedomasset.com

Regulator: Office of the Privacy Commissioner for Personal Data

Data protection principles

We will comply with applicable data protection law. Whilst these obligations differ between the various jurisdictions the Group operates in, Freedom has committed to applying the highest standards across the Group. This means that the personal information we hold about you must be:

· Used lawfully, fairly and in a transparent way.

· Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

· Relevant to the purposes we have told you about and limited only to those purposes.

· Accurate and kept up to date.

· Kept only as long as necessary for the purposes we have told you about.

· Kept securely.

The personal information we hold

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

· We may collect, store, and use the following categories of personal information about you:

1. Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.

2. Date of birth.

3. Gender.

4. Marital status and dependents.

5. Next of kin and emergency contact information.

6. National Insurance number.

7. Tax Identification Number.

8. Bank account and transactional details, records and tax status information.

9. Information about your legal requirements and sector of interest.

10. Information about your personal and business assets and information relevant to a specific legal issue you seek advice upon.

11. Copies of identification documentation.

There are “special categories” of more sensitive personal data which require a higher level of protection.

· We may also collect, store and use the following “special categories” of more sensitive personal information:

1. Information about criminal convictions and offences.

2. Information about your family and personal life relevant to your personal legal advice requirements.

How we collect personal information

We collect personal information about you in the course of our business. In most cases this will be when you provide us with your contact details, such as by giving us a business card, or when you send us a letter or email. From time to time we may obtain this information from your company or employer’s website or from a third party to the extent information about you is in the public domain.

We collect personal information about you through your onboarding as a Freedom client, and as a result of, and through our ongoing work for you. We may sometimes collect additional information from third parties including, credit reference agencies or other background check agencies or databases. We will collect additional personal information in the course of our work for you.

How we will use information about you?

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

· Where we need to perform the contract, we have entered into with you.

· Where we need to comply with a legal obligation.

· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

· Where we need to protect your interests (or someone else’s interests).

· Where it is needed in the public interest.

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our

own or those of third parties, provided your interests and fundamental rights do not override those interests.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

The situations in which we will process your personal information are listed in Schedule 1, together with the purpose or purposes for which we are processing or will process your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you.

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations (such as to ensure you are property identified for the progress of anti-money laundering legislation).

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use sensitive personal information

“Special categories” of sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

· In limited circumstances, with your explicit written consent.

· Where we need to carry out our legal obligations.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about you in the course of legitimate business activities with the appropriate safeguards.

Do we need your consent?

We do not need your consent if we use your personal information in accordance to carry out our legal obligations or exercise specific rights under the law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Information about criminal convictions

We envisage that we will hold information about criminal convictions.

Where appropriate, we will collect information about criminal convictions as part of the client take-on process or we may be notified of such information directly by you in the course of our relationship.

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our legal obligations.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We may also process such information about you in the course of legitimate business activities with the appropriate safeguards.

Data sharing

We do not sell your data but we may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the EU. If we do, you can expect an equivalent degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. This may involve us sharing your information with:

· Third party service providers who help us work with you and operate our business;

· Revenue and customs agencies, regulators and other authorities;

· Financial services compensation schemes;

· Credit reference agencies;

· Fraud prevention agencies;

· Entities working with you or your business’ product or service;

· Organisations that introduce you to us;

· Companies that we introduce you to;

· Market researchers;

· Companies you ask us to share your data with; and

· Credit card companies and direct debit operators.

If the make-up of the Freedom Group changes or such changes are proposed we may share your data with third parties to allow us to sell, merge or transfer aspects of our business or acquire or merge into other businesses. We will only do this if they agree to keep your data to the same standards we have set for holding your data. Following such a change other parties may use your data in line with these standards.

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group.

Due Diligence checks are carried out by third-party service providers on behalf of Freedom.

How secure is my information with third-party service providers and other entities in the Freedom group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

When might you share my personal information with other entities in the group?

We will share your personal information with other entities in our group, to the extent required in the context of a business reorganization or group restructuring exercise.

Transferring information outside the EU

We will transfer the personal information we collect about you to the following countries outside the EU:

· Abu Dhabi

· Hong Kong

· Guernsey

· United Kingdom

In order to perform our contract with you. There is not an adequacy decision by the European Commission in respect of all of those countries. This means that some countries to which we transfer your data are not deemed to provide an adequate level of protection for your personal information.

However, to ensure that your personal information does receive an adequate level of protection we have put in place binding contract clauses in line with international

standards to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the applicable laws on data protection. If you require further information about these protective measures, you can request it from your Local Information Officer.

Data security

We have put in place measures to protect the security of your information.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Retention periods for your personal information are decided by considering the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. This will vary depending upon the relationship we have with you but in general terms for legal advice relationships we will retain your information for 7 years after the end of our relationship unless we are required to keep it longer for legal reasons.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. If you have any questions regarding data retention, please speak to your Local Information Officer.

Marketing

We may use your personal information to let you know about those of our products and services we think may be of interest to you. Before doing so we may use your personal information to better understand what services or products you are likely to need or have use for.

If you ask us to stop using your personal information to market to you, we will do so, and you can change this choice at any time.

Rights of access, correction, erasure, and restriction Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

· Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

· Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

· Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

· Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

· Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

· Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact your Local Information Officer in writing.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact your Local Information Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

Schedule
How Freedom use your data


How we use client data	Our basis for doing so	Freedom’s legitimate interests (where appropriate)
To operate and maintain our relationship with clients.	Freedom’s legitimate interest. Freedoms legal obligations.	Developing and growing the business. Obtaining your consent where needed for contact.
		Maintaining proper practice and efficiencies in meeting our legal and commercial obligations.
Marketing and updating clients on our products.	Freedoms legitimate interests.	Developing and growing the business. Obtaining your consent where needed for contact.
To monitor services levels provided.	Freedoms legitimate interests.	To improve/maintain client relationships and service levels.
Working with service providers who help Freedom operate their business.	Freedoms legitimate interests.	Developing and growing our business. Maintaining proper practices and efficiencies.
Providing and managing investment products and services.	Freedoms legitimate interests.	Maintaining proper practices and efficiencies.
Making and delivering client and beneficiary payments, monitoring and managing interest levels, charges and fees on client accounts.	Freedom’s legitimate interests. Freedoms legal obligations.	Maintaining proper practices and efficiencies in meeting our commercial obligations.
Risk Management.	Freedom’s legitimate interests. Freedoms legal obligations.	Maintaining proper practices and efficiencies in meeting our commercial obligations.
Responding to complaints.	Freedom’s legitimate interests. Freedoms legal obligations.	Maintaining proper practices and efficiencies in meeting our commercial obligations.
Obeying applicable laws and regulations including.	Freedom’s legitimate interests. Freedoms legal obligations.	Maintaining proper practices and efficiencies in meeting our commercial obligations.
To properly, efficiently and lawfully operate the business of Freedom Group with proper regard to financial and business planning and monitoring, internal communications and corporate governance, audit and oversight.	Freedom’s legitimate interests. Freedoms legal obligations.	Maintaining proper practice and efficiencies in meeting our legal and commercial obligations.
To exercise Freedom Group’s contractual right including the collection of monies owed to Freedom.	Fulfilling contracts.

Privacy Policy

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