CITYWIRE PRIVACY NOTICE

WHO ARE WE?

Citywire Financial Publishers Limited (“Citywire”) (“we”) is the operator and copyright holder of all the websites operated by Citywire Financial Publishers Limited ("the Sites") including but not limited to www.citywire.co.uk. For a full list of websites operated by Citywire, please follow this link.

The Data Controller (Data User) is Citywire Financial Publishers Limited.

Citywire is an independent publisher of financial information and data provider.

IMPORTANT: YOUR CONSENT

Citywire is committed to protecting your data and respecting your privacy. Your choice to register with this Citywire site is a freely made, active indication that you agree to collection and use of your personal data as set out in this Privacy Notice[i]. If you neither understand nor agree to the use of your data in this way, please DO NOT REGISTER.

WHAT PERSONAL DATA DO WE COLLECT?

It is important that you understand WHAT personal data we collect.

When you visit our sites and chose to register as a user, complete questionnaire and/ or surveys you actively provide us with personal data which we use to build your ‘USER PROFILE’.

When you browse our sites you passively provide personal data via cookies and similar technologies which we use to build your user profile (see cookie information below).

This user profile, which includes a summary of the factsheets you have downloaded, the pages you have viewed, any articles sent via the email-a-friend facility, and comments you make about published stories will be used by Citywire as set out below.

HOW DO WE USE PERSONAL DATA

Registering and CONSENTING for Citywire to use the personal data you provide requires that you UNDERSTAND how we use personal data.

Citywire WILL USE the personal data in your user profile to help ensure that any marketing we direct to you via post, telephone, email and SMS is both relevant and informative.

Third party usage

Citywire is a data provider, providing a ‘host mailing’ service to commercial partners. This service enables other organisations to direct their marketing messages to you based on your user profile. As a ‘host mailing’ service we ensure that commercial partners never see nor retain your data unless or until you respond to their marketing. Citywire remains in control of your data.

The act of registering with a Citywire site indicates your consent for Citywire to use your personal data ‘for gain’ in this manner. You may withdraw this consent (opt out) freely and at any time via your My Account area on the website, by emailing privacy@citywire.co.uk or by calling 020 7840 5100.

If, after responding to marketing directed to you from one of our commercial third parties, you wish them to cease direct marketing, please contact the third party directly.

Research

Citywire is a research specialist, providing analysis of financial markets, its products and service providers. Your interaction with Citywire, the web pages you view, the documents you download and the comments you make will be used by us to formulate research reports for both internal and external (shared) use.

We will not disclose any personally identifiable information unless we have sought and gained your explicit consent. In accordance with professional market research guidelines we will ensure that our research maintains your anonymity. Citywire will ensure that you are fully informed as to how any personal data will be shared, to whom and for what purpose.

Publishing

Research by Citywire may be published online, through smartphone applications (Apps) or in print.

COOKIES AND ‘PASSIVE’ DATA COLLECTION

We may use cookies and similar technologies to store information such as your User ID and your session identifiers to enable us to identify whether you are registered on to the Sites and, if so, to make access faster and simpler.

Cookies also help us to build your ‘user profile’ by, for example, remembering pages you visit on our Sites and articles you may have read. If you allow us the record this information we can provide you with a ‘site experience’ and marketing tailored to your financial interests.

Should you wish a generic experience you can remove and/or disable cookies using the controls provided by your browser. If you are unfamiliar with these controls, please visit www.aboutcookies.org/ where you will find information to help manage important information storage choices.

You are free to choose whether to accept cookies or not, however we cannot guarantee full operability of our Sites should you disable cookies. This information storage occurs passively, without you interaction.

Plugins from third party platforms (e.g. Facebook button)

We are not responsible for the data policies, procedures or content of any other website that are linked to/from our Sites. Please read their privacy notices carefully before providing any personal information. For information on how these third parties use your data please read their privacy policies

OUR OBLIGATIONS

Keeping personal data accurate

To ensure that our records are up-to-date, we will maintain contact with you to check that the information we hold remains accurate.

Where appropriate we will contact you or a representative from your fund management group to ensure that our information remains accurate. If, however, any of the details you provided change and you would like us to reflect that change, please contact our Customer Services Department 020 7840 5100 or at privacy@citywire.co.uk and we will be happy to update your details.

Reporting and disclosure responsibilities

We have responsibilities under legislation to verify the identity of both registered users and users and may need to make enquiries and obtain information from you for that purpose. By using the Sites you confirm that all information you supply will be accurate and that we may pass on such information, as we consider necessary, to comply with any reporting requirements.

You agree that we may disclose to..

a. any regulatory authority to which we are subject;

b. any investment exchange on which we may deal or to its related clearing house (or to investigators, inspectors or agents appointed by them);

c. any person empowered to require such information by or under any legal enactment;

.. any information they may request or require relating to you or, if relevant, any of your clients.

Providing access to your information

You have the right to receive information about the personal information we hold on you. You can obtain a copy of the information by sending an email to privacy@citywire.co.uk or contacting us on 020 7840 2250. If you are concerned that any of the information we hold on you is incorrect, please contact us at privacy@citywire.co.uk.

If you have any questions about our privacy policy, please contact us at privacy@citywire.co.uk.

If you would like to request a comprehensive list of our current websites please contact us at privacy@citywire.co.uk.

Protecting data

Citywire is a global business with offices in London, Munich, Singapore, Hong Kong and New York.

This may result in your personal data being transferred out of the European Economic Area (EEA) to countries which have not been assessed by the European Commission as having adequate legal protection.

For further information on the adequacy of non-EU countries, please visit the European Commission website

Respecting individual choice

You can change your personal information preferences and/or details at any time. As a registered user you can access your preferences by logging on to www.citywire.co.uk using your username (email address) and password.

a. You may unsubscribe to any/all lists by sending an email request to privacy@citywire.co.uk.

b. You may ask Citywire to cease providing your data to third parties by sending an email request to privacy@citywire.co.uk.

c. You will ALWAYS be given a straightforward way to opt out from marketing each time you receive a communication from us or one of our commercial partners.

If you believe we have not met any of our obligations, please contact us in the first instance.

You may find more information from the UK Information Commissioner on their website.