Smithson Investment Trust
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Privacy Notice

1. Important information and who we are

This Privacy Notice describes the types of personal data that the Smithson Investment Trust plc. (“we”, “our”, “us”, “Fund”), may obtain and process, how we may use this data, with whom we may share this data, how long we will retain this data, and your choices regarding our use of your data.  
We also describe the measures we take to safeguard personal data and tell you how to contact us about our privacy practices as provided for under applicable data protection legislation and regulation to which we are subject, in particular, the UK’s retained EU law version of the General Data Protection Regulation 2016/679 (“UK GDPR”) and the Data Protection Act 2018.  

For the purpose of UK GDPR, the Fund is the data controller responsible for your personal data.

The website www.smithson.co.uk (“Website”) is not intended for children and we do not knowingly collect data relating to children. The Website is operated by the Fund’s investment manager, Fundsmith LLP (“Investment Manager”).

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified. 
We may collect, use, store and transfer the following categories of personal data:

  • Identity Data includes first name, last name, or similar identifier, title, date of birth and gender;
  • Contact Data includes address, email address and telephone numbers;
  • Financial Data includes bank account details and information resulting from “know-your-client” and anti-money laundering checks;
  • Transaction Data includes details about transactions you undertake when buying and selling shares in the Fund;  
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this Website;
  • Usage Data includes information about how you interact with and use our Website and the Fund;
  • Profile Data includes, preferences, feedback and survey responses;  
  • Marketing Data includes your preferences in receiving marketing from us.

From time to time, we may aggregate personal data we hold about you such that the data no longer directly or indirectly reveals your identity (and therefore no longer constitutes personal data). For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our Website to help improve the Website and our service offering.

We may collect special categories of personal data, which include, but are not limited to, information revealing racial or ethnic origin, political opinions, religious or similar beliefs, physical or mental health conditions and sexual orientation. For example, if you are identified as a politically exposed person through client due diligence checks, we may receive information revealing your political opinions. 

We may also be required, in connection with the fulfilment of our legal and/or regulatory obligations, to collect information regarding criminal offences or alleged criminal offences that have been committed by you.

3. How is your personal data collected?

We may collect your personal data, through a number of different methods including:

  • Your interactions with us. For example, when you:
    • invest in the Fund;
    • communicate with us by phone, e-mail, writing or otherwise;
    • elect to receive marketing communications from us.
  • Website. As you interact with our Website, we may collect Technical Data about your equipment, browsing actions and patterns by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. As the operator of the Website, please see the Investment Manager’s Cookie Policy for further details.
  • Third parties or publicly available sources. We may collect your personal data from various third parties and public sources, including when you:
    • engage with an organisation that has a business relationship with the Fund, such as the Fund's registrar;
    • are subject to money laundering and “know-your-client” checks;
    • are the beneficiary of a trust, the assets of which have been invested in the Fund.

4. How we use your personal data

Legal basis

We rely on one or more of the following legal basis when collecting and processing your personal data:

Performance of a contract with you: We may process your personal data where we need to perform a contract we are about to or have entered into with you.

Legal obligation: We may process your personal data where it is necessary for compliance with a legal obligation that we are subject to (for example, where we conduct anti-money laundering / “know-your-client” checks to confirm your identity). 

Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose (for example, if you subscribe to receive marketing material from us). 

Legitimate interests: We may process your personal data where it is necessary to conduct our business and pursue our legitimate interests (for example, to enable us to give you the best and most secure customer experience and make improvements to our business). We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by your interests, fundamental rights or freedoms (unless we have your consent or are otherwise required or permitted to by law).

Substantial public interest: We may process your personal data where there is a substantial public interest in us doing so (for example, to prevent or detect unlawful acts or for the purposes of compliance with a regulatory requirement relating to unlawful acts and dishonesty).

Purposes for which we will use your personal data 

We have set out below, in a table format, a description of the purposes for which we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. 

Purpose/Use Legal Basis
  • Managing the assets of the Fund;
  • Facilitating the buying and selling shares in the Fund;
  • Providing periodic and annual reporting;
  • Managing payments and distributions.
  • Performance of a contract with you
  • Legitimate interest
To manage our relationship with you we will respond to your queries, requests (including complaint handling) and all correlated communications including the provision of investor services.
  • Performance of a contract with you
  • Legitimate interest
  • Legal obligation
Undertaking anti-money laundering / “know your client” checks to confirm your identity in accordance with anti-money laundering and counter-terrorist financing obligations.
  • Legal obligation
  • Substantial public interest
To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
  • Legitimate interests
  • Legal obligation
To deliver relevant Website content and online marketing to you and measure or understand the effectiveness of the marketing we serve to you.
  • Consent
  • Legitimate interests
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing.
  • Consent
  • Legitimate interests
To send you relevant marketing communications that may be of interest to you based on your Profile Data.
  • Consent
  • Legitimate interests
Reporting to and/or cooperating with supervisory and regulatory bodies, and/or other authorities pursuant to applicable laws and regulations and complying with general prudential duties.
  • Legal obligation

5. Disclosures of your personal data

Where it is necessary in connection with the purposes set out at section 4 above, we may share your personal data with certain third parties. 

In particular, we may share your personal data with the following recipients, some of whom will be based outside the UK and/or use sub-processors based outside the UK:

  • the depositary of the Fund;
  • the Investment Manager and any of its affiliated entities;
  • suppliers and service providers to our business, including IT and communication services providers, accountants, auditors, tax advisors, lawyers and “know-your-client” / client due diligence verification providers;
  • your financial advisor, where you have provided details of their identity;
  • banking establishments;
  • governmental, judicial or administrative bodies;
  • any public register to be used for ultimate beneficial owners’ declarations (as accessible online as the case may be).

We also may disclose information about you: (i) if we are required to do so by law, regulation or legal process (such as a court order or subpoena or for tax reporting purposes), (ii) in response to requests by government agencies, such as law enforcement or regulatory authorities, (iii) for the purpose of or in connection with legal proceedings, or otherwise for the purpose of establishing, exercising or defending our legal rights, or (iv) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. 

We also reserve the right to transfer any information we have about you to potential third party acquirer(s) in the event we sell or transfer all or a portion of the Fund’s assets (including in the event of a reorganization, dissolution, liquidation or other corporate event.

6. International transfers
In case of transfers of personal data to entities outside the UK, such transfers will rely on appropriate safeguards as permitted or required under UK GDPR. 

In these circumstances, we will take those steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Notice and UK GDPR. This means that we will transfer your personal data to third parties: (i) that are located in countries that have been confirmed by the UK Government to provide an adequate level of protection;  (ii) that have agreed (by way of a contract or some other form of data transfer mechanism approved by the UK Information Commissioner's Office) to provide all protections to your personal data as required by UK GDPR; or (iii) where you have provided your express consent for us to do so.

7. Data security

We have put in place appropriate security measures intended to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those persons parties who have a business need to have such access and are, in each case, subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of any actual personal data breach where we are legally required to do so.

8. How long will you retain my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for (including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements) and in any event for no longer than is permitted pursuant to UK GDPR. 
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we collected your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see section 9 below for further information.

9. Your legal rights

Within the limits set out in the UK GDPR, you have the right to:

  • know what personal data we process about you and access such personal data;
  • request any incomplete or inaccurate personal data be corrected;
  • require us to delete your personal data and/or otherwise restrict our processing of your personal data in some circumstances;
  • object to our processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data and which overrides your right to object;
  • object to our processing of your personal data where we send you direct marketing;
  • "data portability", which is a right to require us to transfer your personal data to you or to a new service provider in a structured, commonly used and machine-readable format.

If you wish to exercise any of the rights set out above, please contact us through the means outlined at section 10.

10. Contact details
If you have any questions about this Privacy Notice, our use of your personal data or you want to exercise your privacy rights, please contact us on the following: 

E-mail: smithson@fundsmith.co.uk

Postal address: 

Smithson Investment Trust plc. 
c/o Apex Listed Companies Services (UK) Limited
140 Aldersgate St,
Barbican,
London EC1A 4HY
United Kingdom

Telephone: 020 3327 9720

11. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK regulator for data protection matters (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

12. Cookies

For more information about the cookies we use on our Website and how to change your cookie preferences, please see the Investment Manager’s Cookie Policy.

13. Changes to the Privacy Notice 

This Privacy Notice may be updated periodically to reflect changes in our personal data practices. By continuing to use the Website, communicate with us, or otherwise provide us with your personal data, you agree to any updated version of this Privacy Notice. 

 

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Disclaimer - Important

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THE WEBSITE YOU ARE SEEKING TO ACCESS IS MADE AVAILABLE BY SMITHSON INVESTMENT TRUST PLC (THE "COMPANY") IN GOOD FAITH AND IS PROVIDED FOR INFORMATION PURPOSES ONLY.
THE INFORMATION CONTAINED ON THIS WEBSITE IS INTENDED FOR PERSONS IN THE UNITED KINGDOM ONLY AND IN PARTICULAR IS NOT FOR RELEASE, PUBLICATION OR DISTRIBUTION, DIRECTLY OR INDIRECTLY, IN WHOLE OR IN PART, IN OR INTO ANY MEMBER STATE OF THE EUROPEAN ECONOMIC AREA (EEA), THE UNITED STATES OF AMERICA (UNITED STATES), CANADA, AUSTRALIA, THE REPUBLIC OF SOUTH AFRICA OR JAPAN OR ANY OTHER JURISIDICTION WHERE ITS RELEASE, PUBLICATION OR DISTRIBUTION IS OR MAY BE UNLAWFUL.

Please read this notice carefully – it applies to all persons who view this website. Please note that the terms set out below may be altered or updated without notice. You should read the following provisions in full each time you visit the site. In addition to this disclaimer, you should read the Legal Notice applicable to this site before you access it. A link to this site's Legal Notice can be found at the bottom of each page on this site.

The information on this website is intended for, and may be accessed only by, persons in the United Kingdom. Viewing the materials you are seeking to access may not be lawful in other jurisdictions.

No securities of the Company have been or will be registered under the US Securities Act of 1933, as amended (the "Securities Act") or under the securities laws of any state or other jurisdiction of the United States and may not be offered, sold or delivered, directly or indirectly, in or into the United States, or to or for the account or benefit of any US person (within the meaning of Regulation S under the Securities Act). In addition, the Company has not been, and will not be, registered under the United States Investment Company Act of 1940, as amended. There will be no public offer of securities in the United States.


If you are not permitted to view this website or are in any doubt as to whether you are permitted to view this website, please exit this website immediately by clicking on the "Disagree" button below. The contents of this website must not be released or otherwise forwarded, distributed or sent, directly or indirectly, in whole or in part, outside the United Kingdom and in particular in or into any Member State of the EEA, the United States, Australia, Canada, the Republic of South Africa or Japan or any other jurisdiction where the distribution of such materials would or may breach any applicable law or regulation or would require any registration or licensing within such jurisdiction. Persons receiving any such materials (including, without limitation, custodians, nominees and trustees) should observe these restrictions and must not, directly or indirectly, in whole or in part, forward, distribute or send them in, into or from any jurisdiction outside the United Kingdom. Neither the Company, Fundsmith LLP ("Fundsmith") nor their respective advisers accept any responsibility for any violation by any person of any of these restrictions.

Basis of access

Access to this website is for information purposes only. Any person seeking access to this website represents and warrants to the Company and to Fundsmith that they are doing so for information purposes only. Making this website available does not constitute an offer to issue or sell or the solicitation of an offer to subscribe for or buy securities in the Company. Further, it does not constitute a recommendation by the Company or Fundsmith or any associated company or any other person to subscribe for or buy securities in the Company. The information on this website is general in nature and does not in any way constitute investment, tax, legal or other advice.
None of the Company, Fundsmith or any other person has, or accepts, any responsibility or duty to update any information, document or announcement contained on this website and the Company reserves the right to add to, remove or amend any information available on this website at any time.

Investec Bank plc ("Investec"), which is authorised by the Prudential Regulation Authority and regulated in the United Kingdom by the Financial Conduct Authority and the Prudential Regulation Authority, is acting exclusively for the Company and no-one else in connection with the matters referred to on this website and will not be responsible to anyone other than the Company for providing the protections afforded to clients of Investec or accordingly for providing advice in relation to any matters referred to on this website. Apart from the responsibilities and liabilities, if any, which may be imposed on Investec by the Financial Services and Markets Act 2000, as amended, or the regulatory regime established thereunder, Investec does not accept any responsibility whatsoever for the contents of this website or for any statement made or purported to be made by it, or on its behalf, in connection with the Company. Investec accordingly disclaims all and any liability whether arising in tort, contract or otherwise (save as referred to above) which they might otherwise have in respect of such material or any such statement.

The information on this website is general in nature and may be subject to amendment and updating without notice. None of the Company, Fundsmith nor any other person guarantees the accuracy or completeness of any information on this website and each such person disclaims all representations and warranties, whether express or implied, to the greatest extent permitted by applicable law and regulation. By continuing to use this website, you agree to the exclusion by such persons, to the greatest extent permitted by applicable law and regulation, of any and all liability for any direct, indirect, punitive, consequential, incidental, special or other damages, including, without limitation, loss of profits, revenue or data arising out of or relating to the provision of and your use of this website and its content.


Neither the Company, its directors, Fundsmith nor any other person accepts any responsibility in respect of any information contained on any other website which may be linked to or from this website.

Confirmation of understanding and acceptance of terms

By clicking on the "Agree" button below, you confirm, represent and warrant to the Company and to Fundsmith that you are located in the United Kingdom and you agree that you will not forward, distribute or send any materials contained in this website to any person outside the United Kingdom.

I have read and understood the terms set out above, which I understand may affect my rights and I agree to be bound by those terms. By clicking on the "Agree" button below, I confirm that I am permitted to access the website.