Privacy and Cookies
Privacy
This Notice explains how Brickwood Asset Management LLP collects, uses, shares and otherwise processes your Personal Data in accordance with applicable data privacy laws, including, the UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018, as amended (DPA), and EU General Data Protection Regulation (EU GDPR).
What data do we collect?
Brickwood Asset Management LLP collects the following data:
- The kinds of Personal Data we may request from you including your contact details (such as your name, email address, telephone number, job title), your identification details which we are required to collect in connection with carrying out anti-money laundering and related checks (such as copies of identification documents) and such other necessary details which the law or our regulators require us to collect. In addition, we will collect any Personal Data you choose to provide to us, for example, where you contact us by letter, telephone, email or any other means of electronic or personal communication (including in any face-to-face meetings).
- We may also collect your Personal Data from third parties where required for the purpose of carrying out our business for you, or from publicly available information.
How do we collect your data?
You directly provide Brickwood Asset Management LLP with most of the data we collect. We collect data and process data when you:
- Register online or fill out a contact form for any of our products or services through the website, by email or post, as well as in person.
- Use or view our website via your browser’s cookies.
Personal information may also be obtained from publicly accessible sources of information, such as public databases, industry associations, social media and online professional networks.
How will we use your data?
Brickwood Asset Management LLP collects your data so that we can:
- Process your Personal Data only to the extent applicable law provides a lawful basis for us to do so. In most cases, we will process your Personal Data because we (or a third party) have a legitimate interest as a business providing investment management services which is not overridden by your interests or fundamental rights and freedoms, or, because we need it to perform a contract we have entered into with you or a Brickwood client you represent. In some instances, we may process your Personal Data on the basis that you have expressly consented to us doing so, or because it is necessary in order to comply with a legal or regulatory obligation.
- We process your Personal Data:
- To provide our services;
- To run our business affairs;
- To facilitate the opening of a client account;
- To facilitate the management and administration of a client’s holding(s) and/or any related account on an on-going basis which is necessary for the performance of Brickwood’s investment management services, which may include the processing of subscription, redemption, conversion, transfer and additional subscription requests, marketing and the payment of distributions;
- To carry out anti-money laundering checks and related actions which Brickwood considers appropriate to meet any legal and regulatory obligations imposed on Brickwood relating to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, and tax evasion;
- To further Brickwood’s legitimate commercial purposes in maintaining good business relationships, to ensure that communications are made to the appropriate individuals, and for promoting or marketing our products and services;
- To facilitate the purchase or sale of securities and other investments by Brickwood;
- To comply with regulatory requirements from our regulators, in the course of our business; and
- To comply with our obligations for tax, regulatory or corporate filings in any relevant jurisdiction.
Brickwood Asset Management LLP may share information with our appointed service providers, trading counterparties, IT providers and regulatory or enforcement agencies as required by law.
What are your data protection rights?
Brickwood Asset Management LLP would like to make sure you are fully aware of all your data protection rights. Every user is entitled to the following:
The right to access
You have the right to request Brickwood Asset Management LLP for copies of your personal data.
The right to rectification
You have the right to request that Brickwood Asset Management LLP correct any information you believe is inaccurate. You also have the right to request Brickwood Asset Management LLP to complete the information you believe is incomplete.
The right to erasure
You have the right to request that Brickwood Asset Management LLP erase your personal data, under certain conditions.
The right to restrict processing
You have the right to request that Brickwood Asset Management LLP restrict the processing of your personal data, under certain conditions.
The right to object to processing
You have the right to object to Brickwood Asset Management LLP’s processing of your personal data, under certain conditions.
The right to data portability
You have the right to request that Brickwood Asset Management LLP transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us directly.
Contact information can be found on the contact us page.
How long will we retain your information?
We will only retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. To determine the appropriate retention period for your Personal Data, we will 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 process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. Upon expiry of the applicable retention period, we will, to the extent reasonably feasible, securely destroy your Personal Data in accordance with applicable laws and regulations.
Privacy policies of other websites
The Brickwood Asset Management LLP website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website you should read their privacy policy.
Fees applicable when exercising your rights
You will not normally have to pay a fee to exercise any of your individual rights mentioned in this Notice. However, we may charge a reasonable fee if we, in our discretion, believe your request is manifestly unfounded or excessive or, we may refuse to comply with the request in such circumstances.
Changes to our privacy policy
Brickwood Asset Management LLP keeps its privacy policy under regular review and places any updates on this website.
How to contact us
If you have any questions about Brickwood Asset Management LLP’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.
Contact information can be found on the contact us page on the website.
Data Controller
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in the European Union and other provisions related to data protection is:
Brickwood Asset Management LLP
Contact information can be found on the contact us page.
Cookies
Cookies are text files placed on your computer to collect visitor identification information and visitor behaviour information. When you visit our website, we may collect information from you automatically through cookies or similar technology. Cookies set by us are called first-party cookies. We may also use third-party cookies, which are cookies from a domain different than the domain of the website you are visiting, for our advertising and marketing efforts.
For further information, visit allaboutcookies.org.
How do we use cookies?
Brickwood Asset Management LLP uses cookies in a range of ways to improve your experience on our website, including:
- Helping you to navigate our website by retaining information relating to your use and preferences when visiting the website.
- Understanding how you use our website for the purpose of managing the performance the website.
- Understanding the pages you have visited and the links you have followed to make our website more relevant to your interests and identify products or Services that may be of interest to you.
What type of cookies do we use?
There are different types of cookies our website uses:
- Strictly Necessary Cookies – These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
- Functionality Cookies – Brickwood Asset Management LLP uses these cookies so that we recognise you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used. If you do not allow these cookies then some or all of these services may not function properly.
- Targeting Cookies – Brickwood Asset Management LLP uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Brickwood Asset Management LLP sometimes shares some limited aspects of this data with third parties for marketing purposes. If you do not allow these cookies, which collect information for analytics and to present you with targeted ads, they will be disabled on our website.
- Performance Cookies – These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.
How to manage cookies?
You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result. You can also manage your cookie preferences on our website.
Changes to our Cookie Policy?
We may change this Cookie Notice from time to time. If we make significant changes to this Cookie Policy, we will notify you of the changes when you next visit our site.
How to contact us
If you have any questions about Brickwood Asset Management LLP’s Cookie policy, please do not hesitate to contact us.
Contact information can be found on the contact us page on the website.
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