Privacy Policy

Guinness Asset Management Ltd, trading as Guinness Global Investors (“we”, “us, “our”) is committed to protecting personal data we receive about our investors, service providers and suppliers (“you”, “your”) and complying with the UK General Data Protection Regulation (“UK GDPR”), the EU General Data Protection Regulation (“EU GDPR”) and any other applicable data protection law.

This Privacy Policy explains how we look after the personal information you provide to us, the choices you have about the marketing we send you, and your privacy rights. We may update this Privacy Policy from time to time, the current version is always available on the GGI website, and we encourage you to review it periodically.

Guinness Global Investors which is a trading name of Guinness Asset Management Limited which is authorised and regulated by the Financial Conduct Authority (FCA registered company number 223077) offers a range of specialist, quality funds that focus on compelling investment areas and ideas for long-term investors. GVL: Guinness Ventures Limited, an appointed representative of Guinness Asset Management Ltd, provides investment products for private investors, including Enterprise Investment Scheme (EIS) services, Seed Enterprise Investment Scheme (SEIS) services, co-investment services, a Venture Capital Trust (VCT), and an estate planning service. Should you have any questions or concerns about this Privacy Policy or the processing of the personal data we hold about you, please contact us:

By Post Guinness Global Investors, 18 Smith Square, London SW1P 3HZ

By Phone +44 (0) 20 7222 5703

By Email info@guinnessgi.com

Data protection law derives from the Data Protection Act 2018 and the UK GDPR Personal Data. Personal data is any information relating to an identifiable person . Such data may only be processed where a lawful bases (reasons) applies. The GDPR provides six lawful bases under which personal information can be processed (used) in a way that is lawful. For the processing to be permitted by law (lawful), at least one of the lawful bases must apply.

The lawful bases most relevant to GGI’s use of personal information are:

• Consent
• Legitimate Interest
• Contract
• Legal Obligation

We will only process your personal information where:

• We have asked you and hold a record of your express consent;
• We have legitimate interest to do so , where we have a business or commercial reason to use your information, which will explain to you, applied fairly and never unduly affecting your rights;
• We have a contract with you that can only be fulfilled by using your personal information; or
• We have a legal obligation to use or disclose information about you – for example, retaining records of business activities for a minimum period.

We will not unduly prioritise our interests over yours, and will only use personal information in ways you would reasonably expect under this Notice. We will not sell your personal information to other organisations for their own marketing purposes.

We use different kinds of personal information (depending on the customer type) and categorise them as shown in the table below:

We may collect personal information about you from the following sources:

Data provided by you:

• When you invest in our products and services.
• When you speak to us on the phone.
• When you use our website.
• In emails and letters.
• If you take part in our promotions.

Data we collect when you use our services. including:

• Payment and transaction data.
• Data to understand how you interact with our website. This is collected from the devices you use to connect to the website.

Data from third parties we work with, such as:

• Companies that you introduce us to.
• Financial advisers and Investment platforms.
• Public information sources such as Companies House.
• Agents working on our behalf.
• Government and law enforcement agencies.

We may share your personal information with other companies in the Guinness Group and the following organisations:

• Our management companies
• Third parties, selected by us, with respect to certain activities
• Agents and advisers we use to help run our services
• HM Revenue & Customs, regulators and other authorities
• UK Financial Services Compensation Scheme
• Any party linked with you
• Companies that we have an agreement to co-operate with
• Companies that you introduce us to
• Companies that we introduce you to
• Companies that introduce you to us
• Financial Advisors and Investment platforms
• Companies you ask us to share your data with.

If our structure changes in the future, we may also share your personal information with other parties:

• In the case of a sale, merger, acquisition or transfer of business, we may share your data with other parties, provided that they agree to keep your data safe and secure.
• If the structure of our business changes, other parties may use your data in the same way as set out in this Privacy Policy.

Operating our services, may require us to transfer the data we collect from you to locations outside the UK and the European Economic Area (EEA) for processing and storage. Where we do so, we ensure it is protected to the same standard as within the UK and EEA, using one of the following safeguards:

• Transferring it to a country with data protection laws that the UK or EU has assessed as providing an equivalent standard of protection (an adequacy decision).
• Putting in place a contract with the recipient requiring them to protect the data to UK/EEA standards – for example the UK International Data Transfer Agreement (IDTA) or UK Addendum to the EU Standard Contractual Clauses
• Transfer it to organisations that are part of the Data Privacy Framework. This is a framework that protects the fundamental rights of anyone in the EU whose personal data is transferred to the United States for commercial purposes.
• Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA and the UK.
• Put in place a contract with the recipient that means they must protect it to the same standards as the EEA and the UK.

Further information on the safeguards is available from the Information Commissioner’s Office and European Commission.

We use artificial intelligence (“AI”) technologies to operate, secure, improve our services and to assist our staff and clients. This may involve processing information you provide, usage data, and content generated through our services.

We do not allow providers to train public models on your personal information without authorisation.

Significant decisions are not made solely by automated decision making without appropriate safeguards.

We may need to collect your personal information under the terms of a contract we have with you or by law. If you do not provide it, we may be unable to meet our obligations, and this could result in delay or cancellation of a product or service. We will make clear at the point of collection where providing information is optional.

From time to time, we may use your personal information for marketing purposes to tell you about relevant products and services, drawing on information you provide, information collected through your use of our services, and information from third parties we work with.

We only send marketing messages where we have received your consent or legitimate interest to do so, and we will not act against your interests, rights and freedoms in doing so. You can ask us to stop marketing messages at any time. We may periodically ask you to confirm or update your marketing preferences, including when the law or our business structure changes.

Our web pages and emails may contain; cookies, web beacons or pixel tags or any other similar type of data analysis tools which allow us to track receipt of correspondence and to count the number of users that have visited our webpage or opened our correspondence.

We will not keep personal information for longer than is necessary for the purposes for which it is being processed (used). We will keep your personal information for as long as we have a business relationship with you. After the business relationship ends, we may keep your information for up to 10 years for one of the following reasons:

• Respond to any questions or complaints.
• Demonstrate that we treated you fairly.
• Maintain records as required by the rules that apply to us.
• Comply with a legal obligation

We may retain your data for longer than 10 years where we are unable to delete it for technical or legal reasons.

You have the right to access the personal information we hold for you by was of a Subject Access Request. Additionally, you have a right to lodge a complaint if you are not happy with how we have used your personal information. If you want to contact us you can do this by:

• Writing to us at our registered address: 18 Smith Square, London SW1P 3HZ
• Calling us: +44 (0) 20 7222 5703
• Contacting us via email: info@guinnessgi.com

You also have the right to complain to the Information Commissioner’s Office. https://ico.org.uk/

You have the right to have inaccurate personal data rectified or incomplete data completed. If you believe that the information we hold is incorrect or incomplete, please contact us and we will then use our best endeavours to verify and correct it.

You have the right to object to our use of your personal information (the “right to object”), and the right to ask us to delete data we no long need (the “right to erasure” or “right to be forgotten”), subject to any legal or other legitimate reason we may have to retain it.

In certain circumstances you may ask us to restrict processing instead of erasing it. For example if:

You can ask us to restrict the use of your personal information if:

• You do not believe that it is accurate and we are verifying it;
• The data has been used unlawfully, but you do not want it erased;
• We no longer need the data, but you want it retained for a legal claim; or
• You have already objected to our use of the data and are awaiting confirmation of whether our use will continue.

To exercise any of these rights, please contact us using the details above.

You may withdraw your consent at any time by contacting us. If you do so, we may be unable to provide certain products or services, and will let you know if this is the case.

You have a right to receive the personal information we hold about you in a format that can be reused across different services, and to ask us to transmit it directly to another organisation where this is technically feasible. Our processing system may not always be technically compatible with those of other organisations.

To find out more about how we use cookies, please see our Cookie Policy.