Welcome to Premier Miton Investors’ privacy notice.
Premier Miton Investors respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we look after your personal data when you visit our website (regardless of where you visit
it from) and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1: Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Premier Miton Investors collects and processes your personal data through your use of this website, including any data you may provide through this website when you use our online valuation service, apply for vacancies or send us feedback or register for alerts on our corporate site.
This website is not intended for children and we do not knowingly collect data relating to minors under the age of 18.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
In certain cases, as set out below, third parties may be involved in the processing of your personal data. Where Northern Trust Global Services SE (the “Administrator”) or Northern Trust Investor Services Limited (the “Depositary”) processes your personal information, they may be acting as data controller or joint data controller. Their EMEA Privacy Notice may be updated from time to time and is available at www.northerntrust.com/united-kingdom/privacy/emea-privacy-notice
Premier Miton Investors is the marketing name for the group of companies including Premier Miton Group plc, Premier Fund Managers Limited and Premier Portfolio Managers Limited. This privacy notice is issued on behalf of the Premier Miton Group of companies so when we mention ”Premier Miton Investors” or “Premier Miton” “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Premier Miton Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us.
Premier Asset Management Limited is the controller of and is responsible for this website.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Our full details are:
Full name of legal entity: Premier Asset Management Limited Contact: Data Protection Officer
Email address: [email protected]
Postal address: Eastgate Court, High Street, Guildford, Surrey GU1 3DE
If you are a resident in the EU you can either contact us directly or through our EU Representative by email at [email protected] premiermiton.com or by writing to The DPO Centre, Alexandra House, 3 Ballsbridge Park, Dublin, D04C 7H2.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (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.
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, including the administrators that provide our valuation services, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2: The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, username or similar identifier, title.
Contact Data includes home address, email address and telephone numbers.
Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
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 and other technology on the devices you use to access this website.
Profile Data includes your username and password, (on our third party valuation sites) purchases or orders made by you, and your feedback responses.
Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not intentionally collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). If you are investing in our products, attending events or applying for a vacancy, special categories of Personal Data may be processed as part of these processes. Special Category Data will be processed in accordance with our Processing of Special Categories of Personal Data and Criminal Convictions Data Policy.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- subscribe to our publications;
- request marketing to be sent to you; or
- give us some feedback
- Third parties or publicly available sources.
- We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers such as Google and search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services
- dentity and Contact Data from data brokers or aggregators
- Identity and Contact Data from publicly availably sources
4: How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of Data||
Lawful basis for processing including
basis of legitimate interest
|To register you as a new customer||
|Performance of a contract with you Necessary to comply with a legal or regulatory obligation (including fraud prevention)|
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) To manage or administer your account
(e) Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
Necessary to comply with a legal obligation
|To manage our relationship with you or the institution you represent||
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation
|Providing you with information about products and services which may be of interest to you or the institution you represent||
Necessary for our legitimate interests
Performance of a contract with you
|To deliver relevant website content to you and measure or understand the effectiveness of the advertising we serve to you||
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/ services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/ services, marketing, customer relationships and experiences||
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
We do not market directly to private individuals, only to Financial Advisers. Where we do market we strive to provide choices regarding certain personal data uses, including the right to unsubscribe.
If you are a financial adviser acting on behalf of one of our clients, you will receive marketing communications from us if your clients have purchased services from us, you have requested information from us or if we believe that we have a Legitimate Interest in providing you with information about our services, and, in each case, you have not opted out of receiving that marketing.
We will not share your personal data with any company outside the Premier Miton group of companies for marketing purposes.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service we provide under our contractual relationship with you or your client.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an
explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5: Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
The disclosure of personal information to the third parties set out above may involve the transfer of data to the USA and other jurisdictions outside the UK or the European Economic Area (EEA) in accordance with the requirements of data protection laws in the UK or EEA (as applicable). Such countries may not have the same data protection laws as your jurisdiction.
Where we transfer your personal data outside the UK including the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the UK and the EEA and that all transfers of personal data outside the UK are done lawfully. This can be done in a number of ways, for instance, under an agreement which covers the UK requirements for the transfer of personal data outside the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK (including to the EEA).
7. Data security
We have put in place appropriate security measures 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 employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are 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 a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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 the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External third parties
- Service providers acting as processors based in the UK who provide administration services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Fraud Prevention agencies based in the UK.
Your legal rights
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and
freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies
to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Joint privacy notice of Premier Miton Investors and MIGO Opportunities Trust plc
Where you have accessed this notice, or provided personal data, through www.migoplc.co.uk, each of Premier Miton Investors and MIGO Opportunities Trust plc shall be a data controller, as we each independently determine the purposes and means of processing your personal data.
Where Premier Miton Investors is the data controller, the privacy notice above applies.
Where MIGO Opportunities Trust plc is the data controller, this schedule constitutes the privacy notice for MIGO Opportunities Trust plc and references to “we”, “us” or “our” in this schedule shall mean MIGO Opportunities Trust plc.
MIGO Opportunities Trust plc’s contact details:
Frostrow Capital LLP, Company Secretary and Administration Manager of MIGO Opportunities Trust plc
25 Southampton Buildings, London WC2A 1AL
The type of personal information we collect
We currently collect and process the following information:
- Personal identifiers and contacts (for example, name and contact details).
How we get the personal information and why we have it
Most of the personal information we process is provided directly by you when you subscribe to receive marketing information.
We may share this information with our service providers.
Under the UK General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information is your consent. You are able to withdraw your consent at any time.
Your data protection rights
Under data protection law, you have rights including:
Your right of access – you have the right to ask us for copies of your personal information.
Your right to rectification – you have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – you have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction to processing – you have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing – you have the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – you have the right to ask that we transfer the personal information you agave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
How to complain
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk