Policy on Personal Information and Electronic Communications
This policy tells you about two things. First, it is a privacy notice and tells you what to expect when we collect personal Information from you. Second, it describes some of the risks that you should consider when you communicate with us electronically and the terms on which we do so.
The Generation Foundation (Charity No. 1113061, Company No. 05536312) is a distinct, not for profit, undertaking from the group of investment management businesses affiliated with Generation Investment Management LLP (Company No. OC307600) ("GIM"). Generation Foundation, a US 501(c)3 charity, is associated with The Generation Foundation. While the Generation Foundations are funded by GIM they are independent from it. Specifically, the Generation Foundations do not carry on any form of investment business and are not authorised to do so.
© 2015 The Generation Foundation.
1. Privacy of your information
We appreciate that you, or a third party on your behalf, has provided us with your personal information. Obtaining personal information from those we interact with is central to the goals of the Generation Foundations. However, we understand that in receiving this information, you expect us to treat it in an appropriate manner.
This policy is designed to provide you with further details on the type of information that we may collect about you, the purposes we might use that information for and the actions we may take to safeguard your information. When we use the term Generation Foundations below, we are referring to the Generation Foundation, a US 501(c)3 charity, and The Generation Foundation, a UK charity registered with the Charity Commission (Number 1113061).
2. Where we may collect information from
We will gather information from a number of sources. Typically, it is primarily drawn from applications for funding or other support from the Generation Foundations or as a result of the Generation Foundations working with you in respect of a collaborative project or pursuant to a request by you to one or other of the Foundations for information. After a relationship is established and develops, we may gather further information from you as you interact with us or make servicing requests of us.
In addition to the information provided directly by you, we may gather information about you from a broad range of third parties. This includes other persons that you may instruct to assist you with your dealings with the Generation Foundations, for example, your professional advisers. We may also seek information from individual reporting agencies about you. Third parties may be asked to undertake due diligence about you to assist us in respect of our responsibilities to combat financial crime, to ensure we are in compliance with applicable sanctions regimes, as well as helping us establish and maintain relationships which we believe are in the best interests of the Generation Foundations.
In line with market practice, we may record communications with you, including monitoring your e-mails. We will do this in a proportionate manner and always in accordance with applicable laws and regulations designed to protect your privacy in this sensitive area. Typically we would not access your information regularly in this way. Rather, it will be used for compliance, internal control or security purposes to help us comply with our legal and regulatory obligations.
Lastly, we may use close circuit television and recording systems in our offices to protect our staff and physical assets. The owners of the buildings we occupy may operate similar systems. As a result, your physical image may be captured by us on our premises.
3. The type of information we may collect
If you deal with the Generation Foundations, we may collect the following types of personal data about you.
|Type of Data||Examples|
|Personal details||Name, age, occupation and relationship status.|
|Contact details||Address, telephone, fax and email (both private and work related).|
|Identity documents||Passport, national identity card, armed forces identity document, driver's licence, gun licence.|
|Personal identifiers||Social Security Number, National Insurance Number, Tax File Number, Taxpayer Identification Number.|
|Photographs||A head and shoulders photograph of you from one of the identity documents specified.|
|Video Images and Audio||CCTV pictures and audio, recordings of phone conversations, presentations given by you to or with the Generation Foundations.|
|Details of your financial resources.|
|Your Personal History||Information about your current or former employers, education, business activities, affiliations, roles and responsibilities.|
Of course, except as otherwise agreed in particular contexts with us, you are not required to supply any of the personal information that we may request from you. However, please note that failure to supply such information may result in us being unable to deal with you. It may limit the interaction that we may have. While we make reasonable efforts to ensure that all information we hold about you is accurate, complete and up to date, you can help us in this regard by promptly notifying us if there are any changes to your personal information. In certain cases, this is of such importance that we will ask you to represent that you will do so.
4. How we use your information
We may use your personal information in a range of different ways.
|Funding||We, may use your information to determine whether you are appropriate to be funded by or to fund the Generation Foundations.|
|Contact Details||We will maintain records of your contact details and the manner in which you wish to be contacted, for example, by phone, fax, post or e-mail.|
|Provision of Research and other services||We may use personal information to provide you with information (such as research), or generic advice concerning the Generation Foundations.|
|Internal Controls and Processes||We may use personal information to facilitate our internal operations, including assessing and seeking to manage risk as well as fulfilling our legal and regulatory requirements.|
|Compliance Matters||We may use personal information to carry out various compliance checks as required by law, regulation or the Generation Foundations internal policies and procedures.|
|Regulator Interaction||We may use personal information to ensure compliance with our regulatory notification and reporting requirements anywhere in the world (including national and international regulatory bodies and other law enforcement agencies).|
|Litigation||If we are subject to a court action or other proceedings or require, to the extent necessary, to exercise and defend our legal rights we may be required to use your personal information.|
|Recording||We may record (visual and audio) and/or monitor communications, (including: cctv, e-mail, instant messaging, facsimile, telephone and other electronic communications), with you or your agent(s) for compliance, internal control and security purposes and as evidence of transactions.|
5. When we will disclose your information within Generation
In order to service you better, and reflecting the globally integrated nature of our firm, more than one entity within the Generation Foundations (including our investment advisory affiliates) may be given, or given access to, your personal information. For example, our UK entity might share your information with our US entity. At the date of this policy, the Generation Foundations have established offices in the United Kingdom and the United States. They may in the future open offices in other jurisdictions and will transfer your personal information between such present and future offices. In doing this, we will adhere to applicable legal and industry standards regarding the protection of personal information but the jurisdictions concerned may not have data protection laws as strict as those in the UK or the United States.
6. When we will disclose information to persons outside Generation
The Generation Foundations only disclose your personal information to third parties in accordance with this policy. We may provide your personal information to non-affiliated companies that collaborate with us on the work of our Foundations.
In a limited range of circumstances, we may disclose your personal information to third parties in accordance with applicable laws and regulations or pursuant to internal policies and procedures designed to facilitate compliance with such laws and regulations. Examples of this would be: when responding to a writ or similar legal process; cooperation with law enforcement or regulatory authorities; preventing fraud or other financial crime.
These third parties may operate from locations outside the European Economic Area and United States. Again, some of these jurisdictions may not have data protection laws as strict as those in the European Economic Area or the United States.
7. We will not sell your information
The Generation Foundations will not sell, rent or trade your personal information nor will it pass it on to third parties for their marketing purposes.
8. How we protect the privacy of your information
We endeavour to protect your personal information at all times. Primarily, we do this by utilising appropriate access controls to those data, so that only authorised employees of the Generation Foundations or their agents and our third party service providers have access. Where appropriate, we subject such third parties to confidentiality obligations. In addition, we maintain physical, electronic and procedural safeguards intended to protect your information against loss, misuse, damage or modification and unauthorised access or disclosure. Those policies and procedures include educating those working for or on behalf of the Generation Foundations on information security policies and responsibilities.
9. What rights do you have under European data protection laws?
In the EU, you have certain specific rights provided under European Union ("EU") data protection law. If you wish to access a copy of your personal data; or you wish to modify any personal data which we hold about you, you can do so by written request to our General Counsel at the address set out below. You are also entitled to have the Generation Foundations modify or delete any information that is incorrect or out of date; and in some limited circumstances you may have a right to object to our processing of your personal data.
In the case of a request for access to personal data, we and our affiliates reserve the right to charge an appropriate fee, if applicable. You may be asked to supply a valid means of identification as a security precaution to minimise unauthorised disclosure. We will process your request within the time provided by applicable law.
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IMPORTANT INFORMATION ON ELECTRONIC COMMUNICATIONS
When you receive an e-mail or other forms of electronic communication from the Generation Foundations, please be aware the information contained in or accompanying that communication may be confidential, subject to legal privilege, or otherwise protected from disclosure and (unless it expressly states otherwise) it is intended solely for the use of the intended recipient. If you receive a communication from the Generation Foundations and you are not the intended recipient of the communication, please delete it and destroy all copies in your possession, notify us that you have received the communication in error and note that any review or dissemination of, or the taking of any action in reliance on, any such electronic communication sent in error is expressly prohibited.
2. Risk of interception, viruses and defects
Electronic communications may contain computer viruses or other defects, may not be accurately replicated on other systems or may be intercepted, deleted or interfered with without the knowledge of the sender or the intended recipient. The Generation Foundations make no warranty in relation to these matters. As a result, it may be that you are not comfortable with the risks associated with e-mail messages and other forms of electronic communication. If that is the case, please get in touch with your Generation contact and we will be pleased to arrange another means of communication with the Generation Foundations.
3. No warranties made as to content; responsibilities to update
Neither the Generation Foundations nor their third party providers make any warranty, express or implied, concerning electronic communication. If you elect to receive electronic communications, that is at your sole risk. The Generation Foundations expressly disclaim any implied warranty of satisfactory quality or fitness for a particular purpose, including any warranty as to the use or the results of the use of information with respect to its correctness, quality, accuracy, completeness, reliability, performance, timeliness, or continued availability.
4. Content not to be construed as a solicitation or recommendation
Unless it expressly agreed between the parties to the contrary, material provided electronically is for information purposes only. The Generation Foundations are not soliciting any action based upon it. You should neither construe any of the material contained in an electronic communication as legal, regulatory, tax, or accounting advice.
5. No representations made as to other sites or links
Our electronic communications may provide links to certain Internet sites ("Sites") maintained by third parties. In this case, the Generation Foundations are providing such links solely as a convenience to you. Accordingly, the Generation Foundations make no representations concerning the content of the Sites. The fact that the Generation Foundations have provided a link to the Sites does not constitute an endorsement, authorisation, sponsorship, or affiliation by the Generation Foundations with respect to the Sites, their owners, or their providers.
6. Changes to our policy
This policy provides a general overview of the ways in which we seek to protect your personal information and important information on electronic communication. Please be aware that we may request certain further confidentiality arrangements be put in place in respect of your interaction with us, especially when we believe there is a risk such information could be material price sensitive information. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our website.
This version of the Policy is effective July 1, 2013.
Generation Investment Management LLP
20 Air Street
+44 207 534 4700