This Public Facing Privacy Notice was updated on 28 March 2023. We reserve the right to amend this Privacy Notice from time to time to reflect new legislation or changes to our processing practices. Any such changes shall be effective from the date they are published on this website.
Introduction and background
Innisfree Group Limited is a private company limited by shares incorporated in England and Wales. References in this Privacy Notice to “Innisfree”, “we” or “us” are references to Innisfree Group Limited and its affiliated entities.
References in this Public Facing Privacy Notice to “personal data” means any information that identifies, or could reasonably be used to identify, a living individual, either on its own or together with other information.
The purpose of this Public Facing Privacy Notice is to outline how Innisfree has established measures to protect your privacy and information rights. It sets out the basis on which we process your personal data,and explains how your personal data will be processed and any third parties with whom your personal data is shared. Innisfree Limited is the primary data controller.
In this policy the term “Data Protection Legislation” means all applicable legislation relating to privacy or data protection in force from time to time, including any statute or statutory provision which amends, extends, implements, consolidates, or replaces the same, in particular the Data Protection Act 2018. The terms “personal data”, “controller”, and “process” shall have the meanings given to them in the Data Protection Legislation.
We recognise that you have rights as a “data subject”, and that we have an obligation to uphold these rights.
Depending on our reason for processing your data, your information rights may include:
|Right to be informed||This encompasses the obligation for us to be transparent in how we collect and use your personal data.|
|Right of access||You have the right to access your personal data and supplementary information.|
|Right to rectification||If the information we hold on you is inaccurate or incomplete, you can request we correct this.|
|Right to erasure||You can request we delete or remove personal data where there is no compelling reason for us to continue processing it.|
|Right to restrict processing||You have the right to request we cease processing your data (but not erase it):
|Right to data portability||Where you have consented to our processing your data, or where the processing is necessary for us to deliver a contract, you can request a copy of that data be provided to a third party in electronic form.|
|Right to object||You have the right to object to our processing under certain circumstances.|
|Rights relating to automated decision making including profiling||We do not apply automated decision making. If this were to change we must:
Information we collect and how this is used
Innisfree may collect, record and use your personal data in physical and electronic form and will hold, use and otherwise process it in accordance with the Data Protection Legislation:
- When you email us or provide such data to us in other formats; and
- As part of anti-money laundering and know your customer checks.
This information may be collected from sources other than directly from you, for example government or risk intelligence agencies or from public records.
The personal data we collect includes:
- Basic information such as your name, gender, date of birth, title, nationality and relationship to another person;
- Contact information such as your physical address, email address, telephone number and other contact details;
- Identification information we require as part of anti-money laundering or know your customer checks which may include photographic ID such as copies of passports; and
- Any other information which you may provide to us.
We may collect, hold and use your personal data:
- In connection with our normal business activities as a fund management group;
- In relation to our suppliers and their staff as necessary to receive the services.
- When inviting you to presentations and events and organising meetings between you and Innisfree’s representatives;
- For managing and securing our business systems and premises; and
- For any other purpose which you have provided the information to Innisfree.
In accordance with the Data Protection Act 2018, our legal basis for storing personal information that you provide to us is that such storage is necessary for the legitimate interest of administering and managing our business.
We may also collect, hold and use your personal data:
- When acting in compliance with legal or regulatory requirements including in relation to anti-money laundering, compliance screening and know your customer checks.
In accordance with the Data Protection Act 2018, our legal basis for this processing is the legitimate interest of managing the risks to our business and to comply with our legal obligations.
If you have provided express consent to the processing of data for purposes other than as listed above then we may do so for those purposes. You may withdraw this consent at any time.
Sharing of data
Innisfree uses an international network of advisers and service providers. Irrespective of how we obtain your personal data it may be necessary or desirable to share this personal data with third parties such as professional advisers, including their subcontractors, in jurisdictions outside of the UK and the European Economic Area. We will only do this for the purposes outlined in the ‘Information we collect and how this is used’ section, above.
Where we share your personal data in this way we will do this in accordance with Data Protection Legislation and will take appropriate steps to ensure the third parties undertake to ensure the appropriate safeguards are in place to protect the personal data.
Retention of data
Innisfree will retain your personal data in line with the life of its managed funds which is ordinarily for a period expiring 10 years after the expiry of its final long-term income fund.
Innisfree uses a perpetual archiving system for inbound and outbound email and personal data provided by you or transmitted by us in this medium will be retained within this archive indefinitely. Further, whilst Innisfree will make reasonable endeavours to destroy personal data when it is no longer reasonably required for the purposes it was supplied or gathered we may retain this personal data for additional periods to the extent deletion would require the destruction of archiving or back-up processes or where it is required or may be required for regulatory, legal or other statutory purposes.
Where data has been shared with third parties for the purposes described above this will be subject to retention by those third parties in accordance with their own data retention policies.
Securing your information
We will take appropriate and proportional technical and organisational measures to ensure appropriate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. Personal data will be stored in accordance with our policies concerning data storage, access and retention.
We recognise that you may have questions on how we process and/or store your data or may want to change either the data we hold on you or how we communicate with you in the future. If you have any questions in respect of this notice or would like to exercise your rights please contact firstname.lastname@example.org.
If you are unhappy that we have responded to your query adequately, you have the right to lodge a complaint with the appropriate supervisory authorities which in the UK is The Information Commissioner’s Office, https://www.ico.org.uk.