+353 1 662 3001 info@greshamhouse.ie

Data Privacy Policy – Gresham House Asset Management Ireland Limited

Effective 14.04.2020

Gresham House Asset Management Ireland Limited takes privacy and the protection of your personal data very seriously.
In this document, we explain how we collect your personal information, how we use it and how you
can interact with us about it. We try to keep it as concise as possible, but if you are unfamiliar with
our terms, or would like more detail on any of the information here, please contact us at dpc@greshamhouse.ie

1. Who we are

Throughout this document, “Gresham House”, “we”, “us”, “our” and “ours” refer to Gresham House Asset Management Ireland Limited.

2. The information we collect about you

We may collect the following information:

  • Names
  • Contact information including home address
  • email address
  • Gender
  • Phone number
  • Date of Birth
  • Marital status
  • Employment and education details
  • Financial Background
  • Copy of passport
  • Copy of PPS number
  • Bank account details
  • Next kin information
  • Health information*

*Note, we may collect health information if it is pertinent to the assessment of

  1. Investment suitability advice
  2. Clients ability to understand and interpret investment risks

3. How we collect information about you

Gresham House collects personal data directly from clients under the following scenarios:

  • Opening an account with Gresham House
  • Submit information in connection with an application for any of our funds
  • Dealing with Gresham House by phone, email or letter or website**.
  • Visit and interact with our website**•
  • Subscribe to marketing materials
  • Meet with the Gresham House Client Relationship staff for review meetings

**Note, our websites uses cookies to enable us to improve our service to you and to provide certain
features that you may find useful. Cookies are small text files that are transferred to your computer’s
hard drive through your web browser to enable us to recognise your browser and help us to track
visitors to our site; thus enabling us to understand better the products and services that will be most
suitable to you.

A cookie contains a unique id to allow us to identify your computer when you travel around our site.

Most Web browsers automatically accept cookies, but, if you wish, you can set your browser to
prevent it from accepting cookies. The “help” portion of the toolbar on most browsers will tell you
how to prevent your browser from accepting new cookies, how to have the browser notify you when
you receive a new cookie, or how to disable cookies altogether. The cookies we use do not detect any
information stored on your computers.

4. How we keep your information safe

We are committed to ensure that personal information is secure. In order to prevent unauthorised
access or disclosure, we have put in place suitable physical, electronic and managerial procedures to
safeguard and secure the information we collect.

5. How long we keep your information

How long we hold your information depends on the nature of the information and the purposes for
which it is processed. We determine appropriate retention periods which meet our legal and
regulatory obligations. We hold your information while you are a client and for a period of time after
that. We do not hold it for longer than necessary. If the purpose for which the information was
obtained has ceased and the personal information is no longer required, the personal data will be
deleted or anonymised (i.e. all identifying characteristics are removed).

6. How we use your information and the legal basis

We use information about you to:

  • to manage your funds
  • to market our products and services to you
  • to better understand your needs
  • to improve our services to you
  • to provide information on our products and services to you
  • to comply with applicable laws and regulations

To use your information lawfully, we rely on one or more of the following legal bases:

  • your consent; ( you may withdraw your consent at any time)
  • performance of a contract;
  • legal obligation (e.g. Anti-Money Laundering );
  • protecting the vital interests of you or others; (in exceptional circumstances)
  • our legitimate interests

7. Your information and third parties

When providing our services to you, we may share your information with:

  • Your authorised representatives
  • Service providers who provide us with support services
  • Statutory and regulatory bodies and law enforcement authorities

8. Using companies to process your information outside the European Economic Area (EEA)

In some cases, we may transfer information about you and your products and services with us to our
service providers outside the EEA. We will always take steps to ensure that any transfer of information
outside of the EEA is carefully managed to protect your privacy rights.

9. Your personal information rights

When your personal information is handled by Gresham House in relation to a product or service, you are
entitled to rely on a number of rights. These rights allow you to exercise control over the way in which
your personal information is processed. For example, we may help you in:

Accessing your personal information

You can ask us for a copy of the personal information we hold about you.

Correcting and updating your personal information

If you believe that any personal information we hold about you is inaccurate or out of date, you can
look for the information to be corrected at any time.

Withdrawing consent

You can change your mind wherever you give us your consent, such as for direct marketing.

Deleting your information (your right to be forgotten)

You may ask us to delete your personal information.

Moving your information in electronic form (your right to Portability)

You may request (in certain cases) that your personal information is transferred to you or another
organisation in digital form.

How to exercise your rights

You may execute any of these rights free of charge. You may do so by contacting us:

Phone: + 353 1 6623001

Email: dpc@greshamhouse.ie

When you contact us to ask about your information, we may ask you to identify yourself. This is to
help protect your information. Once we are satisfied that we have effectively verified your identity,
we will respond to the majority of requests without undue delay and within a one month period (i.e.
30 calendar days) of receipt of the request. These periods may be extended in exceptional
circumstances and we will inform you where the extended period applies to you along with an
explanation of the reasons for the extension.

10. Data Protection Co-ordinator

Our Data Protection Co-ordinator oversees how we collect, use, share and protect your information
to ensure your rights are fulfilled. You may contact our Data Protection Co-ordinator at
dpc@greshamhouse.ie or by writing to: Data Protection Co-ordinator, 42 Fitzwilliam Place, Dublin 2

11. Making a complaint

If you have a complaint about the use of your personal information, please let a member of staff know,
giving them the opportunity to correct things as quickly as possible.

If you wish to make a compliant you may do so in writing and by email at dpc@greshamhouse.ie

You may also contact the Data Protection Commissioner in Ireland to lodge a complaint (details below)

Data Protection Commission

Canal House, Station Road, Portarlington, Co. Laois, R32 AP23
Phone: + 353 57 868 4800 / + 353 761 104 800
Fax: + 353 57 868 4757
Web: www.dataprotection.ie
Email: info@dataprotection.ie

12. Updates

We keep this notice under regular review and will make changes from time-to-time, particularly when
we change how we use your information, and change our technology and products or services. We
will inform you of material changes to the contents of this Data Privacy Policy, through a notification
posted on our website or through other communication channels.

Dated: 14.04.2020