1.2 “Schroders”, “we or “us” means Schroder Investment Management Limited of 31 Gresham Street, London, EC2V 7QA or any of its subsidiaries, affiliates, managed syndicates and other companies in the Schroders group (together the “Schroders Group”), details of which can be found on the Schroders website (www.schroders.com).
2. THE TYPES OF PERSONAL DATA WE COLLECT
2.1 When you visit the Preference Centre, we may collect and process the following personal data about you:
- Information that you provide to Schroders. Such information may include details of your marketing preferences (i.e. the marketing materials that you would like to receive from the Schroders Group and/or its third party business partners).
- Cookies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. The Preference Centre uses “strictly necessary” cookies. These are cookies that are required for the operation of the Preference Centre. You can choose not to accept certain cookies by turning this feature off within your browser settings, however doing this may detract from your user experience and your ability to properly use the Preference Centre.
3. HOW WE USE YOUR INFORMATION
3.1 Your personal data may be stored and processed by us in the following ways and for the following purposes:
- to understand your marketing preferences and keep them up to date;
- to communicate with you in order to provide you with information about Schroders and the products and services offered by Schroders Group that might be of interest to you; and
- for the administration and maintenance of databases storing your marketing preferences.
- it is necessary for our legitimate business interests, because it allows us to:
- keep a record of what our contacts are interested in hearing about and how they would like to hear about it;
- ensure that we only send our contacts marketing materials that they would like to receive and that may be of interest to them; and
- conduct more effective business development and marketing activities; and
- you may have consented for us to use your personal data to send you certain marketing materials when you submit your marketing preferences to us via the Preference Centre.
4. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
4.1 We may share your personal data within the Schroders Group for the purposes described above.
4.2 We may also share your personal data outside of the Schroders Group as further described below:
- with our business partners where you have specifically indicated that you would be interested in hearing about their products, services or events;
- to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation, or to establish, exercise or defend our legal rights;
- if we sell our business or assets, in which case we may need to disclose your personal data to the prospective buyer for due diligence purposes; and
- if we are acquired by a third party, in which case the personal data held by us about you will be disclosed to the third party buyer.
5. INTERNATIONAL TRANSFERS OF PERSONAL DATA
5.1 Schroders is a global business. Our customers and our operations are spread around the world. As a result we collect and transfer personal data on a global basis. That means that we may transfer your personal datato locations outside of your country.
5.2 Where we transfer your personal data to another country outside 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 we send the data to might be approved by 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 European Commission, obliging them to protect your personal data;
- where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
- in other circumstances the law may permit us to transfer your personal data outside Europe.
5.3 You can obtain more details of the protection given to your personal data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us as described in paragraph 10 below.
6. HOW LONG WE KEEP YOUR PERSONAL DATA
6.1 How long we will hold your personal data for will vary and will be determined by the following criteria:
- the purpose for which we are using it (as further described in this policy) – we will need to keep the data for as long as is necessary for the purpose of communicating with you in order to provide you with information about Schroders that might be of interest to you; and
- legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.
7. YOUR RIGHTS
7.1 In all the above cases in which we collect, use or store 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 we hold about you;
- the right to withdraw your consent to the processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so;
- in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit 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 Schroders;
- the right to request that we rectify your personal data if it is inaccurate or incomplete;
- the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
- the right to object to, or request that we restrict, our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are 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 us.
7.2 You can exercise your rights by contacting us using the details provided at paragraph 10 below.
8. OTHER WEBSITES
8.1 If you follow a link to another website (including a website operated by Schroders), different privacy policies may apply. You should read these policies before you submit any personal data to these websites and agree that use of your personal data by those websites will be subject to those privacy policies.
10. QUESTIONS AND CONCERNS