1. Introduction

Multrees Investor Services Limited (“Multrees” and “the Company”) is an independent provider of custody and investment administration services (“Services”) to investment managers (“Managers”) and their clients (“Customers”). Multrees is incorporated in England & Wales with company number 07225386 and has its registered office at One Carter Lane, London EC4V 5AN. Multrees is authorised and regulated by the Financial Conduct Authority under firm reference number 526528.

In connection with the performance of its Services, Multrees acts as both a data controller and a data processor, depending on the context and the type of data. Multrees is the data controller in respect of all personal data collected on or in relation to this website. Multrees is registered with the Information Commissioner’s Office (ICO) with registration number Z2487192. Multrees’ entry details on the ICO’s Data Protection Register can be found here: https://ico.org.uk/esdwebpages/search

This Privacy Policy has been updated in light of the rules set out in the General Data Protection Regulation 2016/679 (GDPR). We are committed to safeguarding the privacy of our website visitors; this Policy explains how we use any personal information we collect about you when you use this website or which we receive from your Manager.

2. What information do we collect about you?

If you are one of our Customers, we may collect information about you when you or your Manager registers with Multrees and requests that Multrees delivers Services to you (via your Manager). Website usage information is collected using cookies.

We may collect, store and use the following kinds of personal information, including:

• information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system type and version, referral source, length of visit, page views, website navigation paths and service usage); and
• information that you or your Manager provides us with for the purpose of registering for Multrees’ products and services.

3. How will we use the information about you?

Multrees may share your personal data with selected third parties in connection with the delivery of Services to you/ your Manager. Multrees will always ensure that those third parties treat personal data with the same high level of protection as Multrees does. Multrees will never permit any third party to send you direct marketing as a result of Multrees holding contact information about you.

Multrees may process your personal data as a data controller and/or a data processor, acting at all times in accordance with all applicable laws and regulations (including the Data Protection Act 1998, the General Data Protection Regulation (GDPR) or any amendments and/or re-enactments of any of the foregoing or any enactment of the UK Data Protection Bill 2017).

Multrees will receive and process personal data regarding you as strictly required in order for Multrees to act as a custodian and provide related services for you. This includes carrying out standard Anti-Money Laundering (AML) and Know Your Customer (KYC) checks. This personal data includes your contact details and identity details required for AML and KYC checks, and financial information required for Multrees’ provision of custody services. Multrees collects this personal data from you via your Manager and from publicly available sources (as applicable).

Multrees will process your personal data as necessary to deliver custody services to you/ your Manager, and as required for Multrees’ compliance with applicable law and/or regulation.

Multrees will keep the personal data it requires to provide custody related services for you for the duration of the Custody Agreement and for 7 (seven) years from the end of the year in which Multrees’ relationship with your Manager terminates. Multrees will keep the personal data it requires to demonstrate its compliance with financial regulations (including the Money Laundering Regulations 2017) for no longer than 5 (five) years after the end of the year in which Multrees’ relationship with your Manager terminates, at which point the personal data will be destroyed. By exception, Multrees may be required to retain this personal data for longer in order to comply with applicable laws and regulations. The full details of Multrees’ record retention policy is set out in our Data Protection Policy.

Multrees employs sub-custodians to (i) co-ordinate custody of your investment assets and (ii) provide day-to-day administration of your assets and other associated services. Multrees shall provide such personal data to sub-custodians, banks and other service providers as reasonably required to facilitate the custody and administration of your investments. Each of these parties will process your personal data on Multrees’ behalf, and may retain this information in such form and for such duration as may be required to perform these duties. Multrees and/or such other party may be required to transmit personal data to any country in which you hold investments or from where you derive income or profits. Multrees will ensure that any such transfers are safeguarded to the fullest extent possible.

Multrees has extensive technical and organisational measures in place to ensure the security of your data in compliance with applicable data protection laws. Multrees will never transfer your personal data to a country outside the European Economic Area without your consent (to be obtained via your Manager), unless (i) Multrees is comfortable that adequate safeguards are in place for these transfers and (ii) the relevant territory ensures an equally adequate level of protection. Please contact Multrees if you would like more details on safeguards used by Multrees to protect your personal data in this context.

If you have any further queries on how Multrees performs its safekeeping services, please ask your Manager for a copy of our latest summary of regulatory disclosures entitled Customer Custody Notification.

If you agree, we may use your personal information to contact your Manager about other products and services we think may be of potential interest to them (and, indirectly, you).

Personal Data submitted to us via this website or routed via your Manager will be used for the purposes specified in this Privacy Policy or in relevant parts of our website. We may use your personal information for various legitimate purposes, including to:

• administer our website and improve your browsing experience by personalising it to your specific interests;
• enable and enhance your use of our Services;
• deal with queries or complaints (if any) made by you or about you relating to this website; and/or
• providing third party suppliers (in particular any provider of Marketing support services) with statistical information about Multrees’ Clients and Customers using this website.

 

4. Legal basis for processing your data

All the data you provide to us will be processed subject to the restrictions and for the purposes pointed out in this notice. Depending on the context, Multrees will rely on one or more of the following objectives when processing your information:

• for the performance of the contract and the complete fulfilment of any contractual obligation we have with you and/or your company (or your Manager acting on your behalf) – this is likely to be either our Custody Agreement, Administration Services Agreement or Order Manager Agreement, as applicable ;
• for complying with obligations provided by laws, current regulations and European legislation ;
• for legitimate business purposes in the framework of ordinary commercial relationship ; and/or
• in accordance with express and informed consent given by you.

Whenever Multrees processes your personal data for a legitimate purpose we will ensure always to take account of your rights and to balance our requirements with them. We have conducted a Legitimate Interests Assessment to determine if we can rely on any legitimate interests for processing your personal data. Further details are set out in our full Data Protection Policy, please see details below on how you may request a copy of this.

You have the right to object to this processing if you wish. Please bear in mind that if you do this may affect our ability to perform our Services for your benefit.

5. Information disclosures

We may disclose information about you to any of our employees, officers, agents, suppliers or subcontractors insofar as reasonably necessary for the legitimate business purposes set out in this Privacy Policy. In addition we may disclose your personal information:

• to the extent we are required to do so by applicable laws and regulations;
• in connection with any legal proceedings or prospective legal proceedings; and/or
• in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

When we need to share your information with contracted third parties we always take reasonable steps to ensure that your privacy is protected in line with all applicable legal obligations.

6. Your rights under GDPR

You have various enhanced rights under GDPR as listed below. The full detail of your rights is set out in the Regulation. Should you have any queries about your rights, or should you seek assurance on how Multrees will protect such rights, please contact our Data Protection Officer at the address detailed below.

• Right of access (i.e. subject to various limitations, you may instruct us to provide you with any personal information about you);
• Right to rectification (i.e. should you identify that incorrect information is held by us you (or your Manager) may instruct us to amend that information;
• Right to erasure (i.e. in specific circumstances individuals have a right to have personal data erased and to prevent any processing of such data);
• Right to data portability (i.e. allowing individuals to obtain and reuse their personal data for their own purposes across different services);
• Right to object (i.e. you have the right to object to data processing under certain circumstances including direct marketing/ profiling/ automated decision making/ research and statistics ancillary to the Services;
• Right to withdraw your consent to the processing of your personal data;
• Right to restrict processing (i.e. in certain limited circumstances an individual may request that processing of their personal data is restricted);
• Right to make a complaint to the ICO (i.e. you have the right to raise a complaint about any aspect of the way the Company collects, processes, stores or deals with personal data, including any formal complaints.

Applying these rights in the context of Multrees’ services, you have the right to:

• access the personal data that Multrees holds about you in certain circumstances;
• ask Multrees to delete or correct any personal data that it holds about you (to the extent reasonable);
• prevent Multrees processing your personal data in certain circumstances;
• port your personal data in certain circumstances;
• not be subject to a solely automated decision;
• withdraw any consent that you have given (note that his does not affect the lawfulness of processing based on consent before withdrawal); and

lodge a complaint with the UK regulator, the Information Commissioner’s Office, if you have concerns about how Multrees uses your personal data. Please see https://ico.org.uk/concerns/ to find out more.

7. Security of your personal information

Multrees will always take reasonable and suitable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

Data transmission over the internet is inherently insecure, and we cannot entirely guarantee the security of data received or sent by us over the internet. To the extent applicable, you are responsible for keeping login password and user details confidential.

8. Marketing

*This section only applies to Managers and/or prospective clients, Multrees never sends direct marketing to our Customers.*

We would like to send information to your Manager about products and services of ours (including any other companies in our group) which may be of interest to you. Any consent to receive marketing from Multrees may be revoked at any time.
Multrees will never share your information for marketing purposes with any companies outside of our group.

You have a right at any time to stop us from contacting you for marketing purposes or sharing your information with any third parties.

If you no longer wish to be contacted by Multrees for marketing purposes, please click here.

9. Access to your information and correction

You have the right to request a copy of the information that we hold about you at any time. If you would like a copy of some or all of your personal information, please email DSAR@multrees.com or write to us at the address below. Normally, we will be able to provide you with what you are looking for free of charge, however there may be a small fee depending on the level of detail requested, the administrative cost of collating the information, and whether the request is considered excessive to reasonable requirements.

f.a.o. The Data Protection Officer
Multrees Investor Services Limited
33 Castle Street
Edinburgh
EH2 3DN

We want to make sure that your personal data is accurate and up-to-date. You may ask us to correct or remove any information that you think is inaccurate.

10. Cookies

Like many websites, we may use cookies. Cookies are small text files (often including unique identifiers) placed on your computer that are sent by web servers to web browsers and which may then be sent back to the server each time the browser requests a page from the server. Cookies collect standard internet log information and visitor behavior information. This information is used to track visitor use of our website and to compile standard statistical reports on website activity. More specifically, we use cookies in order to make our website function more efficiently, as well as to provide the following information to us as set out below:

• ‘Session-based’ cookies. This is essential for parts of our website to operate properly and has already been set. These type of cookies are used to maintain the state of a visitor’s online actions so as not to have to constantly request the same information from them over and over again during the same session.
• ‘Remember me’ cookies. These are permanent cookies which can remember who you are once you have logged into the website so you are not asked to log in for future visits.
• ‘Analytics’ cookies. These are used to collect information about how you use our website, such as where you have come through to the site from previously and which individual pages you have visited. We use this information to improve our website.

Cookies do not contain any information that personally identifies you, however personal information that we store about you may be linked by us to the information stored in and obtained from cookies.

Most browsers allow you to refuse to accept cookies. Further information about cookies is available at www.aboutcookies.org . You can set your browser not to accept cookies and the above website provides guidance on how you can remove cookies from your browser. However, you should note that in a few cases some of our website features may not function as a result of cookies being disabled.

Under GDPR a user’s online identifier (i.e. computer IP address) is expressly included in the revised definition of “personal data”. We will only ever use cookies to collect such data in accordance with GDPR rules and for the limited purposes detailed in this Privacy Policy.

11. International data transfers

Other than in response to express instructions received from you or your Manager, Multrees will never transfer your personal data to any countries which do not have data protection laws equivalent to those in force in the European Economic Area.

12. Ownership and copyright

Unless indicated otherwise, all information and images on our website are property of Multrees. Users of our website may print, copy, download or temporarily store information from this website for their personal use but all intellectual and other property rights shall remain at all times with Multrees; no rights shall be transferred to our users.

13. Trademarks

This website contains names and logos which are trademarks of Multrees. Any unauthorised use of any of these trademarks is strictly prohibited.

14. Content of the website

Whilst Multrees uses all reasonable skill and care in compiling the information contained in this website, errors or omissions may occur because of factors inherent in internet systems, e.g. unauthorised access or hardware, software or operator error or malfunction in data transmission.

Multrees believes that the information on this website is accurate at the date of publication but no warranty of accuracy is given and the Company may changes its website at any time without notice and without obligation to update information. Multrees accepts no liability whatsoever to any third party for any such error or omission.

15. Other websites

Our website may contain links to other websites. This Privacy Policy only applies to Multrees’ website so when you link through to other websites we would advise you to read their privacy notices too.

16. Job applicants

If you are applying for a role with Multrees, we will process your personal data as strictly required for us to evaluate your application. As with all personal data, Multrees will not keep your details for longer than necessary. If we think you may be suited for a different role, we may retain your personal data until that vacancy is filled.

17. Changes to this Privacy Policy

We keep this Privacy Policy under regular review and we will place any updates on this web page. You should check this page occasionally to ensure you are happy with any changes. This Privacy Policy was last updated on 12 April 2018.

16. How to contact us

Please feel free to contact us should you have any questions about this Privacy Policy or any information we hold about you. If appropriate, Multrees may share our full Data Protection and Information Security Policy (or relevant sections thereof) with you upon receiving a written request. Amongst other things, this policy:

(i) lists the categories of personal information that Multrees collects and the grounds on which we process such data;

(ii) provides more information on the third parties to whom Multrees may transfer your personal data in connection with the delivery of our Services; and

(iii) sets out the retention timeframes for which Multrees may keep personal information depending on the type of data and the context in which it is held.

If you have a legitimate enquiry and would like further detail on our policies, please contact the Multrees Data Protection Officer at the address above.

 

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