Privacy & Cookies

Please find below a summary of our privacy notice and policy and what we do with the personal data we collect.

In summary, we:

  • Believe in the protection of personal information and the fundamental concept of privacy
  • Will only collect the bare minimum of your data required for us to conduct our business effectively
  • Strive to be transparent with you and the regulators when it comes to cyber-attacks and or intrusion attempts on our business
  • Take all possible and sensible measures to protect the confidentiality and integrity of your personal information
  • Do not sell or trade in your personal information

What information do we collect?

As a minimum we may keep:

  • Name
  • Corporate or personal email
  • Contact telephone number
  • Job title and company you work for
  • Employment background
  • Age
  • Marital status
  • Hobbies and interests
  • Information or background checks for anti-money laundering/client due diligence purposes and for employee vetting in order to meet regulatory/legal requirements
  • Information contained in the application form to subscribe to our funds

We do not collect the following from you:

  • Sexual orientation
  • Religion
  • Health or fitness
  • Political views
  • Family data

Why do we need your information?

We process personal data to enable us to provide investment management services, to promote our investment management services and our funds, to manage our business, maintain our own accounts and records, and to manage and support our employees. We only process personal data where it is necessary for our compliance with our legal obligations, for our legitimate business 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?

We may use your personal data in the following ways, dependent on your relationship with us:

  • To provide our investment management services
  • To manage business relationships
  • To comply with our anti-money laundering and client due diligence obligations
  • To report to and communicate with regulatory and legal bodies

What we do not do with your information:

  • We do not sell your personal data
  • We do not share your information with any third parties other than when expressly required for regulatory or legal reasons

How do we protect your data?

We take several precautions to ensure your data is not subject to unauthorised access. Some of the steps we take include, but are not limited to:

  • Limiting access to systems and email via increased security measures
  • Only storing data within specialist provider environments
  • Ensuring our staff are constantly made aware of their responsibilities towards protecting your personal information

How long do we keep your information?

Your personal data will be stored for no longer than is necessary for the purpose for which it is collected, or for as long as is required to meet our regulatory or legal obligations. We have deemed that prospect and ex-client data will be retained for a period of no longer than 7 years.

What are your rights under GDPR?

Under GDPR, 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 that we do not send you marketing communications
  • To require us to restrict processing of your personal data
  • To object to us processing your personal data
  • 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, for example where there is a regulatory or legal requirement that we do not delete your data. Please see www.ico.org.uk for further information on these rights and exceptions.

Cookies

Cookies are used on our website. Most browsers now recognize when a cookie is offered and permit you to refuse or accept it. If you are not sure whether your browser has this capability, you should check with the software manufacturer, your company's technology help desk or your Internet service provider. We do not use cookies for collecting personal information.

Cookies are primarily used to enhance your online experience and are not used to track the navigational habits of identified visitors,
unless we obtain your permission to do so. If you visit our sites to read or download information, such as news stories or articles, much of the information we do collect is statistical only (e.g., the domain from which you access the Internet, the date and time you access our site, and the Internet address of the website from which you linked directly to our site) and not personally identifiable. We use this information about the number of visitors and their use of the sites in aggregate form to make our sites more useful and attractive to you.

Telephone calls

We may record telephone calls to Montanaro in order to comply with regulatory requirements.

Questions

Due to the limited personal or sensitive data that is processed by Montanaro, an official data protection officer has not been appointed. However if you have any questions or complaints relating to this policy, please contact Cedric Durant des Aulnois:

Email: cedric@montanaro.co.uk

Montanaro Asset Management Limited
53 Threadneedle Street
London EC2R 8AR

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