For the purposes of the General Data Protection Regulation (EU) 2016/679 (the ‘GDPR’), the data controller is the Ardea UK entity.
1. Information Ardea UK may collect and process about you
However, Ardea UK uses personal data it ensures that the usage complies with law and the law allows and/or requires it to use personal data for a variety of reasons. These include where Ardea UK:
- has obtained your consent.
- has legal and regulatory obligations that it must discharge (including recording of telephone calls).
- needs to do so in order to establish, exercise or defend its legal rights or for the purpose of legal proceedings.
- is fulfilling contractual obligations.
- is using your personal data for the legitimate business interests of Ardea UK and the Ardea group, such as:
- allowing it to manage and administer the operation of its business effectively and efficiently.
- maintaining compliance with its internal policies and procedures.
- monitoring the use of its copyrighted materials.
- enabling quick and easy access to information on Ardea UK and Ardea group products and the investment opportunities offered by each; and
- offering optimal, up-to-date security solutions for mobile devices and IT systems; and
- obtaining further knowledge of current threats to network security to update its security solutions.
2. Sensitive data
Ardea UK does not seek to collect sensitive personal data (such as data revealing political opinions, religious beliefs or data concerning health or sex life). If Ardea UK does seek to collect such data, your explicit prior consent will be sought.
3. International transfers and storage of personal data
The Ardea Group is an investment management business and its partners with members of the Challenger Limited group. Those members of the Challenger Limited group provide the Ardea Group with various services. Our customers and operations are spread around the world. As a result, the data that Ardea UK collects from you may be transferred to, and stored at, destinations inside or outside the United Kingdom and/or the European Economic Area (“EEA”). It may also be processed by staff operating inside or outside the UK and/or EEA who work for Ardea UK, the Ardea Group or the Challenger Limited group, or for one of its agents. Such staff may be engaged in, amongst other things, the provision of support services.
Where Ardea UK transfers your personal data to another country outside the UK and/or the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of the EEA, for example, this may be done in one of the following ways:
- the country that Ardea UK sends the data to might be approved by the United Kingdom or the European Commission as offering an adequate level of protection for personal data.
- the recipient might have signed up to a contract based on “model contractual clauses” approved by the United Kingdom or the European Commission, obliging them to protect your personal data.
- where the recipient is in the US, if it is a certified member of the EU-US Privacy Shield scheme; or
- in other circumstances the law may permit Ardea UK to otherwise transfer your personal data outside the UK or Europe.
You can obtain more details of the protection given to your personal data when it is transferred outside the UK or Europe (including a copy of the standard data protection clauses which Ardea UK have entered into with recipients of your personal data) by contacting us as described in paragraph 11 below.
Unfortunately, the transmission of information via the internet is not completely secure. Although Ardea UK will do its best to protect your personal data, Ardea UK cannot guarantee the security of your data transmitted to its website; any transmission is at your own risk.
4. Purposes of processing
Ardea UK uses information held about you in the following ways:
- to provide you with discretionary investment management services and products, investment advice or information including but not limited to newsletters about products or services that you request from Ardea UK or products or services offered by Ardea UK, the Ardea Group and/or its associated entities or entities with which Ardea UK has a commercial relationship which Ardea UK feels may interest you, where you have consented to be contacted for such purposes (or in the other circumstances described in this paragraph 4);
- to administer the services and products we provide to you.
- compliance with legal obligations (e.g. comply with diversity disclosures or anti- money laundering and anti-terrorism financing purposes).
- compliance with contractual obligations; or
- to notify you about changes to your investment, as well as other products or services.
If there is any change to your personal data which you have submitted to Ardea UK, please contact Ardea UK at the address in paragraph 11 so that it may ensure its records of your personal data are accurate and, where necessary, kept up to date. Personal data shall not be retained for longer than is necessary for the purpose for which it is held.
5. Disclosure of your information
Ardea UK may disclose your personal information to the following categories of third parties and for the following purposes:
- with our business partners including but not limited to the Challenger group. For example, this could include our partners from whom you or your company or your organisation invested in the Ardea product(s). Personal data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation.
- if substantially all of Ardea UK’s assets or business are acquired by a third party, in which case personal data held by it may be one of the transferred assets; or
6. How long Ardea UK keeps your personal data
How long Ardea UK will hold your personal data for will vary and will be determined by the following criteria:
- the purpose for which Ardea UK is using it – Ardea UK will need to keep the data for as long as is necessary for that purpose; and
- legal obligations – laws or regulations may set a minimum period for which Ardea UK has to keep your personal data.
7. Your rights
In all the above cases in which Ardea UK collects, uses, or stores your personal data, you may have the following rights, and, in most cases, you can exercise them free of charge. These rights include:
- the right to obtain information regarding the processing of your personal data and access to the personal data which Ardea UK holds about you.
- the right to withdraw your consent to the processing of your personal data at any time. Please note, however, that Ardea UK may still be entitled to process your personal data if it has another legitimate reason for doing so. For example, it may need to retain personal data to comply with a legal obligation.
- in some circumstances, the right to receive some personal data in a structured, commonly used, and machine-readable format and/or request that Ardea UK transmits those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided directly to Ardea UK.
- the right to request that Ardea UK rectifies your personal data if it is inaccurate or incomplete.
- the right to request that Ardea UK erases or puts beyond reasonable use your personal data in certain circumstances. Please note that there may be circumstances where you ask Ardea UK to erase or put beyond reasonable use your personal data, but it is legally entitled to retain it.
- the right to object to, or request that Ardea UK restricts, its processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask Ardea UK to restrict, its processing of your personal data but it is legally entitled to refuse that request; and
- the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by Ardea UK.
You can exercise your rights by contacting Ardea UK at the address given below.
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10. How to contact Ardea UK
Bridge House, L3, 181 Queen Victoria Street, London, EC4V 4EG, United Kingdom
Telephone: +44 (0) 207 832 0900.
or via e-mail at email@example.com
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from our Compliance Officer, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, Ardea UK’s Compliance Officer will provide you with the contact information for that regulator.