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Privacy policy

Last updated 17 June 2015, last reviewed on 30 June 2017


This Website is brought to you by EdenTree Investment Management Limited (“EdenTree”) Reg. No. 2519319.   EdenTree is registered in England at Beaufort House, Brunswick Road, Gloucester GL1 1JZ UK. EdenTree is authorised and regulated by the Financial Conduct Authority. We take the privacy of our Website users and customers very seriously. We ask that you read this Privacy Policy carefully as it contains important information about how we will use your personal data.

Definitions

The terms “we”, “us”, “our” and “ours” when used in this Privacy Policy means EdenTree. The terms “you”, “your” and “yours” when used in this Privacy Policy mean any user of our Website, enquirer or customer. 

Introduction to Privacy Policy

We are committed to the privacy and confidentiality of information provided by you to us. This Privacy Policy describes our current policies and practices with regard to Personal Data collected by us from you directly and/or through the Website where such Personal Data is protected by the Data Protection Act 1998 (“DPA”). The term “Personal Data” refers to personally identifiable information about you, such as your name, job description, health related data, date of birth, e-mail address or mailing address.

Please note that by submitting Personal Data manually or in electronic form to us and/or by using our Website you give your consent that all Personal Data on each occasion that you submit may be processed by, and/or shared within EdenTree, in the manner and for the purposes described in this Privacy Policy.

Notification of changes to this Privacy Policy

We are continually improving our methods of communication and adding new functionality and features to this Website and to our existing services. Because of these on-going changes, changes in the law and the changing nature of technology, our data practices will change from time to time. If and when our data practices change, we will notify you of the changes via this page. We encourage you to check this Privacy Policy frequently.

Collection of Personal Data including e-mail addresses

You may provide us with your Personal Data in order to receive information or services from us.  We may request personal information about you such as your name, postal address, email address, telephone numbers and we may ask for information which enables us to provide a personalised service to you. The information you give us is either manually or electronically stored in our databases.

We sometimes supplement the information that you provide with information that is received from third parties.  For instance, if inaccurate post codes are received, we will use third party software to fix them.

To comply with money laundering regulations, we may need to request additional evidence of identity from you, and may use a credit reference agency for this purpose (who will record that an enquiry has been made).

We also reserve the right to monitor and/or record your communication with us by mail, voice, email or any other form of transmission for the purposes of quality control, security and other business needs. Any Personal Data contained in such recorded information will be processed in accordance with the terms of this Privacy Policy.

We may also receive your Personal Data from our service providers, agents, advisers or business partners.  Where Personal Data is disclosed to us by third parties, it is the obligation of the disclosing party to ensure such Personal Data is disclosed with requisite authority and consent and we will process such Personal Data in accordance with this Privacy Policy.

If you provide us with the Personal Data of a third party pursuant to a power of attorney, we may process such Personal Data (including information about the third party’s mental health) in order to provide information or services to the third party for whom you act as attorney. In addition, we may hold information about your position as attorney for the purpose of administering products or services to the third party for whom you act as attorney.

Use of Personal Data

We process your Personal Data, and share your Personal Data with other parties, only for specific and limited purposes. We ask only for data that is adequate, relevant and not excessive for those purposes.

The types of Personal Data which EdenTree collects may include:

  • Information we receive from you on applications or other forms, whether we receive the form in writing or electronically. For example, this information includes your name, address, tax identification number, birth date, investment selection, beneficiary information, and possibly your personal bank account information and/or email address if you are signing up for certain products or services;
  • Information about your investment transactions and funds history with us, including transactions you request from us. This category also includes your communications to us concerning your investments;
  • Information we may receive from our business partners, and from other organisations such as credit reference agencies and fraud prevention agencies.
  • Other general information that we may obtain about you such as demographic information.

The purposes for the collection and use of Personal Data are as follows:

  • To provide you with products and services you have requested and to notify you about important changes or developments to the features and operation of those products and services;
  • To service any account or portfolio you hold with us;
  • To allow us to undertake financial reviews and transactional analysis;
  • To improve the content and design of the Website.
  • To place you on a mailing list. If you ask to join our mailing list we may send you (including by email) information about EdenTree or contact you about our business and funds information from time to time.
  • To contact visitors (with their permission) to respond to feedback.
  • To contact you occasionally to inform you of services provided by us, or third parties whose products and/or services we think you may be interested in. We may contact you by letter, telephone or email for this purpose.
  • To process your request for information or advice.
  • To help diagnose any problems with our server and administer our Website.

If you would prefer not to be contacted you can always contact us as described in this policy.

Anonymous data collected through this Website

In addition to the information we collect as described above, we use technology to collect anonymous information about the use of our Website. For example, we use technology to track which pages of our Website our visitors view. We also use technology to determine which Web browsers our visitors use. This technology does not identify you personally; it simply enables us to compile statistics about our visitors and their use of our Website.

We use this anonymous data to improve the content and functionality of our Website and our e-mail updates, to better understand our customers and visitors, and to improve the services we offer.

Cookies

In order to collect the anonymous data described in the preceding paragraph, we may use temporary “cookies” that remain in the cookies file of your browser until the browser is closed. We consider none of them to be intrusive to you; in fact some will enhance your experience on our Website. The cookies that we collect are:

Cookie Law Compliance - This cookie is placed if you click the Allow button in the cookie message. It tells us you have given your consent to the use of cookies on our site and stops this message from displaying.

Session and Person ID Cookies – These allow us to place you on a more suitable page based on your previous visits to our Website – it will enable you to get to the content we believe you want, quicker.  We collect no personal data that would enable us to physically identify you from this Cookie.

Website Analytics data – We will not collect data that enable us to identify you. The only cookies which you may consider could be intrusive are those that identify which county/area of the country you come from, and if you are a new, or returning visitor.

You Tube cookie – We use this cookie to help maintain the integrity of video statistics, prevent fraud and improve site and video experience. If you play any of the videos in our Website, it will drop a cookie.

_utma, __utmb, __utmc and __utmz cookies - We use Google Analytics. This allows us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way our Website works, for example by making sure users are finding what they need easily.

NID & PREF cookies – These cookies are third party cookies used by Google. Please take a look at the Google policy to see how they use these cookies. www.google.com/intl/en/policies/privacy/

Google maps - We use Google maps to provide the maps on this Website. Cookies from Google may also be set when Google Maps are displayed on this Website.

Google re-marketing code – We use a cookie to track you on other sites and show adverts to you based on where you have visited on our Website. We do this to remind you of our services in case you wish to come back and buy them. We only use these cookies for 30 days after your last visit to our Website. We do not control these cookies, so these will be unaffected by the choice you make today. You may opt out of the use of cookies by visiting Google advertising opt-out page.

Google AdSense – We use this cookie to report to us how the adverts shown on our Websites are performing. User data is all anonymous.

The Exchange Lab – The Exchange Lab helps advertisers connect with consumers who may be interested or could benefit from advertisers’ products by using various technology suppliers to supply these adverts to a computer or device. When your computer or device receives an advert, the technology suppliers place a cookie on your computer to enable it to identify the computer or device in the future. All information collected by these cookies is non-personal identifiable information.

The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive. Cookies do not damage your computer. You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not.

We also use your IP address to help diagnose problems with our server and to administer our Website. An IP address is a numeric code that identifies your computer on a network, or in this case, the Internet. Your IP address is also used to gather broad demographic information, such as determining how many of our visitors are from outside of the UK.

We may also perform IP lookups to determine which domain you are coming from (i.e.: aol.com, yourcompany.com) to more accurately gauge our users' demographics.

If you choose to accept these cookies, we believe that it will only enhance your experience on our Website. If you choose to accept these cookies, we can’t change that choice for you in the future.

We may add further cookies which we consider to not be intrusive in the future. By agreeing to the cookies today, you are also agreeing to cookies which we may choose to use in the future.

By using this Website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. 

How to Control and Delete Cookies

EdenTree does not use cookies to collect personally identifiable information about you. We use them to help us provide you with a better service. However, if you wish to restrict or block any cookies you can do this through your browser settings. The Help function within your browser should tell you how. Visit the Google website to find out how to reject or delete the Google Analytics cookie.

AboutCookies.org is an independent site which offers a guide to the use of cookies online. You can find general information about how to delete and control cookies through your browser.

Disclosure of your Personal Data

We do not share with, nor sell nor distribute your Personal Data to unrelated third parties which are not part of our group of companies, except under these limited circumstances:

  • We might use personal information provided by you in order to conduct appropriate identity checks. Personal information that you provide may be disclosed to a credit reference or fraud prevention agency, which may keep a record of that information.  Personal Data may occasionally be transferred to third parties who act for us for further processing in accordance with the purposes for which the data was originally collected or for purposes to which you have consented or otherwise in accordance with this Privacy Policy. For example, sometimes a third party may have access to your Personal Data in order to support our information technology or to handle mailings on our behalf.
  • We may share your personal information with other companies such as investment advisers, the distributor of our funds, and financial service providers offering banking, trust, and custodial products and services.
  • We will only share non-public personal information with outside parties in the limited circumstances permitted by law. For example, this includes situations where we need to share information with companies who work on our behalf to service or maintain your account or process transactions you've requested, when the disclosure is to a party representing you, or when required by law (for example, in response to legal process). Additionally, we will ensure that any outside companies assisting us in marketing our products and services, or with whom we have joint marketing agreements, are under contractual obligations to protect the confidentiality of your information, and to use it only to provide the services we've asked them to perform.
  • Unless you have given us your consent to the processing of your Personal Data for a specific purpose, we will not share or disclose your Personal Data to any unrelated third parties for their own marketing purposes.
  • We may share or transfer the information in our databases to comply with a legal or regulatory requirements, for the administration of justice, interacting with anti-fraud databases, to protect your vital interests, to protect the security or integrity of our databases or this Website, to take precautions against legal liability, or in the event of our sale, merger, reorganisation, transfer of business, dissolution or similar event.
  • If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies.
  • Law enforcement agencies may access and use this information.
  • We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when checking details of applicants.
  • We and other organisations may access and use from other countries the information recorded by fraud prevention agencies. Please contact the Data Protection Officer at the address below if you would like to receive details of the relevant fraud prevention agencies.
  • If we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets.  Where appropriate, before disclosing Personal Data to a third party, we contractually require the third party to take adequate precautions to protect that data and to comply with applicable law.
  • Data will be shared by EdenTree with other companies which are part of the same legal group.  EdenTree is part of the Ecclesiastical group of companies which is owned by Allchurches Trust Limited, which includes Ecclesiastical Insurance Office plc (EIO) Reg. No. 24869. Ecclesiastical Insurance Group plc (EIG) Reg. No. 1718196. Ecclesiastical Life Ltd (ELL) Reg. No. 243111.  EdenTree Investment Management Limited (EIM) Reg. No. 2519319. Ecclesiastical Financial Advisory Services Ltd (EFAS) Reg. No. 2046087.  E.I.O. Trustees Ltd Reg. No. 941199.  All companies are registered in England at Beaufort House, Brunswick Road, Gloucester, GL1 1JZ, UK. 

Sensitive Personal Data

From time to time we may ask you to provide some Sensitive Personal Data. This may include personal information regarding racial or ethnic origins, political opinions, religious beliefs, health and also information regarding criminal offences.  If we do ask for this information, we will process it in accordance with this Privacy Policy.

Data Integrity and Security

We strive to maintain the reliability, accuracy, completeness and currency of Personal Data in our databases and to protect the privacy and security of our databases. The security measures in place on our Website and computer systems, aim to protect the loss, misuse or alteration of the information you provide to us. We keep your Personal Data only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or regulatory requirements, or our data retention policy. 

Data Access

Upon receipt of your written request and enough information to permit us to identify your Personal Data, we will (subject to the exceptions to the requirement to disclose under the DPA) disclose to you the Personal Data we hold about you, for which we may make a small charge.

Requests to delete Personal Data are subject to any applicable legal and regulatory requirements or document retention obligations and any of our current contracts which are still in force.
If you wish to make a subject access request, relating to Personal Data held about you by EdenTree, please write to:

The Data Protection Officer

EdenTree Investment Management
Beaufort House
Brunswick Road
Gloucester
GL1 1JZ.

Inaccurate Data

We encourage you to ensure that your Personal Data is accurate and kept up to date so please regularly update any information you have given to us by sending an email to info@edentreeim.com or by writing to us. We will correct, amend or delete any Personal Data that you notify us is inaccurate and notify any third party recipients of necessary changes. 

Links to other websites

Our Website may contain hyperlinks to websites that are not operated by us. Any such hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party websites or any association with their operators. We do not control these websites and are not responsible for their data or privacy practices. We urge you to review any privacy policy posted on any site you visit before using the site or providing any Personal Data about yourself.

Our Website contains hyperlinks to other pages on our Website. We may use technology to track how often these links are used and which pages on our Website our visitors choose to view. Again this technology does not identify you personally – it simply enables us to compile statistics about the use of these hyperlinks.

Transfer of Data Abroad

We may transfer data between members of our group of companies, and our offices and third party processors which may be located outside the EEA. Where your Personal Data is transferred outside the EEA we will ensure that the recipient agrees to keep your information confidential and hold it securely in accordance with the requirements of the DPA.

If you are visiting our Website from a country other than the country in which our servers are located (currently the UK), the various communications will necessarily result in the transfer of information across international boundaries.

By providing us with your Personal Data, you consent to the processing and transfer of your data as set out in this section.

Unsubscribe

We hope you will be delighted with our services. If you no longer wish to receive information from us and want to be removed from our standard mailing list you can "unsubscribe" by email or post by contacting us at the address given below. Please allow twenty eight days for the unsubscribe process to be completed.  Remember that by stopping the information that you receive from us may not benefit you.

If you do not want to receive unsolicited mail from any source, you can stop this by registering with the "Mailing Preference Service". There are also telephone, fax and email preference services.  For more information on the preference services, please visit the Direct Marketing Association's website.

Governing Law

This Privacy Policy forms part of our Website Terms of Use and as such shall be governed by and construed in accordance with the laws of England and Wales. You agree to submit any dispute arising out of your use of this Website to the exclusive jurisdiction of the courts of England and Wales. 

Feedback

We welcome comments about this Privacy Policy. If you have any questions about this Privacy Policy, or any part of our service, you may contact us by emailing info@edentreeim.com or telephoning the Data Protection Officer on 0800 011 3821.

EdenTree Investment Management Limited (EdenTree) Reg. No. 2519319. Registered in England at Beaufort House, Brunswick Road, Gloucester, GL1 1JZ, UK. EdenTree is authorised and regulated by the Financial Conduct Authority and is a member of the Investment Association.