Privacy

If you have any questions about this Privacy Notice, or how we process your personal information, please contact:

FAO Data Protection Officer

Aberdeen Group plc
1 George Street
Edinburgh
EH2 2LL
Email - DPOffice@aberdeenplc.com

This privacy notice includes the following sections:

Where you invest in the Company directly, we (and / or the Registrar) will collect and use:

• Name and contact address (email address, postal address, contact telephone numbers)
• Shareholder reference number (‘SRN’)
• Number of shares held (where required under the Companies Act 2006)
• Date of birth, gender, nationality, national ID number, tax identification number
• Bank account details 
• Power of attorney information (where applicable)
• Voting history for AGMs
• Photographs or video footage from AGMs or other shareholder events
• Information collected automatically through cookies or online tools e.g. username, your activity on our website. Some information will only be collected where you have turned on the relevant cookies - see our Cookie policy as above for more information

Where you invest indirectly in the Company i.e. through a third party platform or share dealing service, we may be legally required under the Companies Act 2006 to obtain certain details about you (such as your name, address, and shareholding). We have engaged a third party company (RD:IR – part of the Equiniti Group) to collect this information on our behalf and they provide it to us solely for these regulatory purposes.

We will collect your personal information directly from you, and from a variety of sources, including:

• Application forms
• Correspondence you sent to us
• AGM registrations or attendance 
• Requests for marketing / information about Aberdeen Investment Trusts or event invitations
• Our websites and online services
• Social media interactions
• Third party investment platforms, share dealing services or RD:IR acting on our behalf under statutory requirements

We will only use your personal information where it is necessary, fair and lawful to do so. This includes:

• Contractual necessity: To administer your investment in the Company.
• Legal obligation: To maintain the shareholder register and comply with Companies Act 2006 requirements.
• Consent: where you request to receive updates and other information about our Investment Trusts.
• Legitimate interests: To analyse investor engagement in our Investment Trusts to improve our services to you.  Where the processing is in our legitimate interests, we will always conduct an assessment to ensure that this use of your personal information is not excessive or unnecessary or otherwise more intrusive than it needs to be. If you wish to object to this processing, please contact us (see Contact Us section).

We will share your information with:

• Other Aberdeen Group plc subsidiaries where they provide administrative or operational support
• Technology companies, software suppliers, or companies we have chosen to support us in the delivery of our products and services, and contact with you, for examples an internet service provider, or print fulfilment providers
• Regulators, including the Financial Conduct Authority (FCA) and the Information Commissioner’s Office (ICO)
• Law enforcement, tax authorities and other appointed agencies, where legally required for the prevention and detection of crime or tax fraud
• Third parties responding to regulatory disclosures or complaints under the Companies Act 2006

We only share personal information where necessary and in line with our obligations to keep your information safe and secure. 

For more information on how the Company’s Registrar processes your information, please read their privacy notice available on their website.

The majority of your information is processed in the UK or European Economic Area (EEA).

However, some of your information may be processed by us, or the third parties we work with, in locations outside of the UK or the EEA. Where your information is being processed outside of the UK or the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK or EEA Data Protection Laws e.g. we will put in place legal agreements with third parties and Aberdeen subsidiaries with ongoing oversight to ensure they meet these obligations.

We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.

Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information whether it is being processed by us or a third party acting on our behalf.

Our colleagues also protect sensitive or confidential information when storing or transmitting information electronically and must undertake annual training on this. We also use internal and external audit and specialist third party consultants to conduct regular, independent assurance and benchmarking exercises across our business to ascertain the effectiveness of our security control environment and our security strategy. 

We retain your personal information for as long as you hold an investment with the Company or remain subscribed to our marketing lists. After your relationship with us ends, we keep your information for a period required by legal, regulatory or operational needs—typically a minimum of seven years for investors.

You have a number of rights under data protection laws which may be exercised in certain circumstances. 

These are:

Right to be informed

You have a right to receive clear and easy to understand information on what personal information we hold, why, and who we share it with – we do this in our Privacy Notice on our websites and within, for example, application forms and terms and conditions. 

You have a right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request (‘DSAR’) by contacting the Data Protection Officer for Aberdeen Group plc [see Contact Us section]

Right to request that your personal information be rectified

If your personal information is inaccurate or incomplete, you can request that it is corrected.

Right to request erasure of your personal information

You can ask for your information to be deleted or removed if there is not a compelling reason for us to continue to have it.

Right to restrict processing of your personal information

You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don’t use it in the future for those reasons you have restricted.

Right to data portability

You can ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way. For example, if you were moving your investments/assets to another company.

Right to object to processing of your personal information

You can object to us processing your personal information where: it is based on our legitimate interests; for direct marketing (including profiling); and if we were using it for research and statistics.

Right to not be subject to automated decision-making including profiling

You have the right to ask us to:

• Give you information about its processing of your personal information
• Request human intervention or challenge a decision where processing is done solely by automated processes
• Carry out regular checks to make sure that our automated decision making and profiling processes are working as they should.

If you would like to exercise any of these rights, please contact Aberdeen Group plc’s Data Protection Officer [see the How to Contact us section].

We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our Privacy Notice, please let us know immediately and we will do our utmost to make things right.

While we hope that we can resolve any complaints for you, you do have the option complain to your local data protection authority. This is available to you whether or not you have exhausted our complaints procedure.

You can also raise a complaint with the UK Information Commissioner’s Office (ICO):

ICO helpline (UK): 0303 123 1113
ICO helpline (outside UK): +44 1625 545 700
Email: casework@ico.org.uk
Website: https://ico.org.uk/concerns