WEBSITE PRIVACY POLICY

SMITHSON INVESTMENT TRUST PLC

Smithson Investment Trust plc and our investment manager, Fundsmith LLP ("we", "our" or "Smithson"), are committed to protecting and respecting your privacy, including when you visit our website www.fundsmith.co.uk (the/our "Website"). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. 

For the purpose of the EU General Data Protection Regulation or any replacement legislation (together, the “Data Protection Legislation”). Fundsmith LLP of 33 Cavendish Square, London, W1G 0PW, United Kingdom and Smithson Investment Trust plc of Mermaid House, 2 Puddle Dock, London EC4V 2DB are separate data controllers. 

By visiting and/or accessing services on the Website, you acknowledge and where required you consent to the collection, use and transfer of your information as set out in this privacy policy.

This privacy policy covers:

  1. The information that we collect from you
  2. The information that we receive from other people
  3. Our use of your information
  4. How we share your information
  5. Our security and data retention measures, and any transfers we make outside of the EEA
  6. Your rights in respect of your information and third party websites
  7. Accessing and updating your information
  8. Changes to our privacy policy
  9. Our contact information

INFORMATION THAT WE COLLECT FROM YOU

  1. When you visit or otherwise use the Website we may collect and process the following data about you:
  2. details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access;
  3. information that you provide by filling in forms on the Website. This includes information provided at the time of registering to use the "My Account" section of the Website, using the dealing service available on the Website or requesting further information;
  4. details of transactions you carry out through the Website; and
  5. if you contact us, we will keep a record of that correspondence.
  6. Some of this information is collected and processed so that the contract with you can be performed, some for the purpose of legal compliance and some for the purposes of our legitimate business interests (subject to your rights), namely to analyse the use of our Website and services in order to continually improve our business and services. 

INFORMATION THAT WE RECEIVE FROM OTHER PEOPLE

We work closely with third parties who may collect personal information from you and pass it on to us. Where this is the case the third party is responsible for obtaining the relevant consents from you to ensure you are happy with the ways in which your personal data will be used. 

USE OF YOUR INFORMATION

We will use your personal information to (a) ensure that the content of the Website is presented in the most effective manner for you and for your computer; (b) carry out our obligations arising from any contracts entered into between you and us; (c) to allow you to participate in interactive features of our services, when you choose to do so; and (d) to notify you about changes to our products or services.[We will also use the information we collect from you [for the purposes of statistical analysis] and to help us prevent fraud and/or money laundering. 

Where you have consented at the time we collected your data or where we otherwise have a right to do so, we may use your information to let you know about our products and services that may be of interest to you and/or inform you about important changes or developments to our services, by post, telephone, mobile messaging (e.g. SMS, MMS etc.) as well as by e-mail. 

If you change your mind about us using your data in the ways described in this policy, please let us know by contacting us using the details set out in section 9 below. You may also opt out of receiving marketing from us by following the instructions outlined in the relevant communication. 

SHARING YOUR INFORMATION

In order to provide our services to you we have to share your information with certain third parties such as:

  1. where you have notified us of your financial or investment adviser, the personal information provided to us may be shared with that adviser. You should notify us if you no longer wish personal information to be shared with your adviser or of any change in the adviser. 
  2. if we undergo a group reorganisation or are sold to a third party, the personal information provided to us may be transferred to that reorganised entity or third party and used for the purposes above. and/or 
  3. if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. 

    We may also disclose your personal information to any member of our group to the extent that it is necessary for us to provide our services to you. 

    By submitting your personal information to us, you acknowledge that the third parties listed above processing your information. Smithson asks all third parties to treat your data securely and in accordance with this privacy policy, and will take reasonable steps to enforce this. 

    We may use the information that you provide to us if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation; or in order to enforce the terms of any agreement; or to protect the rights, property, or safety of Smithson, its employees or others. This includes exchanging information with other companies and other organisations for the purposes of fraud and/or money laundering protection and prevention. 

SECURITY, DATA TRANSFERS OUTSIDE THE EEA AND DATA RETENTION

We take steps to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction and damage. We will only keep your information for as long as we reasonably require and, in any event, only for as long as Data Protection Legislation allows. 

Where you have chosen a password which allows you to access certain parts of the Website, you are responsible for keeping this password confidential. We advise you not to share your password with anyone. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your information, we cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. 

The information that we collect from you may also be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your personal data, you are acknowledging this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this privacy policy and the Data Protection Legislation. This means that we will only transfer your information to third parties that (a) are in countries that have been confirmed by the European Commission to provide adequate protection to personal information; or (b) have agreed to provide all protections to your personal information as set out in the Data Protection Legislation. 

YOUR RIGHTS AND THIRD PARTY WEBSITES

Should you have any queries or complaints in relation to how we use your information, please contact us via the details set out at section 9 below. Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner's Office regarding such issues. 

Our Website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their related policies. Please check these policies before you submit any personal information via these websites. 

ACCESSING AND UPDATING YOUR INFORMATION

You have the right to see the information we hold about you and to ask us to: (a) make any changes to ensure that any information we hold about you is accurate and up to date; (b) erase or stop processing any information we hold about you where there is no longer a legal ground for us to hold it; or (c) transfer any information we hold about you to a specified third party. If you wish to request details of the personal information held by us you should write to us at Smithson Investment Trust plc, Mermaid House, 2 Puddle Dock, London EC4V 2DB or Fundsmith LLP, 33 Cavendish Square, London, W1G 0PW or email us at enquiries@fundsmith.co.uk. If any information held by us is incorrect please let us know and it will then be changed. 

CHANGES TO OUR PRIVACY POLICY

Smithson may amend this privacy policy at any time without notice. By continuing to use the Website, communicate with us, or otherwise provide us with your personal details, you agree to the updated privacy policy. If you do not agree to any changes that we make, you should not use or access (or continue to use or access) the Website and/or our services. Any changes to our privacy policy will be posted on the Website and, where appropriate, notified to you by e-mail. 

CONTACT US

Questions, comments and requests for further information regarding this privacy policy are welcomed and all comments, queries and requests relating to our use of your information are also welcomed (including in relation to transfer of data outside the EEA) and should be addressed to us at Smithson Investment Trust plc, Mermaid House, 2 Puddle Dock, London EC4V 2DB or Fundsmith LLP, 33 Cavendish Square, London, W1G 0PW. Alternatively you can contact us by email at enquiries@fundsmith.co.uk.

LAST UPDATED: SEPTEMBER 2018