Your privacy is very important to us. Martin Currie (Holdings) Limited and its subsidiaries and affiliates (together "Martin Currie") are committed to preserving the privacy of all visitors to martincurrie.com, together with any associated sites, including the sites of the investment trusts for which Martin Currie acts as manager, (the "Martin Currie websites").
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, and how Martin Currie complies with its responsibilities under applicable data protection laws, including, when and to the extent in force, the Data Protection Act 1998, the General Data Protection Regulation (Regulation (EU) 2016/679) and the Privacy and Electronic Communications Regulation 2003 ("Data Protection Laws"). Please read the policy carefully.
For the purposes of the Data Protection Laws, the data controller of your personal information is Martin Currie (Holdings) Limited of Saltire Court, 20 Castle Terrace, Edinburgh EH1 2ES.
Personal data collection
To the extent any information you provide or which we obtain from the Martin Currie websites constitutes personal data, we have set procedures for the use of that information. We may obtain personal information from your IP address, operating system and web browser that you use to access our website or by some other means (such as via a business card). You may also provide us with personal information if you contact us by email, telephone or letter. If we invite you to submit any information about yourself or your organisation, the purpose of this request will be made clear.
We may collect the following information from institutional investors:
- individual contact name of representatives; and/or
- individual contact details (including email address, telephone number and postal address);
We may collect the following information from individual investors.
contact details (including email address, telephone number and postal address);
date of birth;
IP address; and/or
bank account details.
Purposes for which personal data is used and legal basis for processing
We may use your personal information to:
- conduct administrative or operational processes within our business;
- process and respond to requests, enquiries or complaints received by you;
- provide products and services requested by you;
- comply with applicable laws or regulations or a request of a competent regulatory authority (such as the recording of telephone calls and monitoring of emails);
- identify products and services you may be interested in;
- identify organisations who have visited the website to compile statistical data on the use of our website to track how users navigate through our site in order to enable us to evaluate and improve our site;
- communicate with you about our products and services;
- invite you to events;
- monitor and analyse our business;
- develop or improve our services and/or products that may be of interest to you and to carry out market research; and/or
- send you marketing information.
The legal basis on which Martin Currie processes personal information is to comply with applicable laws and regulations, to fulfil the firm’s contractual obligations with you and/or to pursue Martin Currie’s legitimate interests where these are not outweighed by your interests. In some circumstances, we may rely on your consent to send electronic marketing communications. You can withdraw your consent and/or opt out of receiving electronic marketing materials by asking to be removed from our marketing database by contacting us by email at firstname.lastname@example.org or by post to the Marketing Team, Martin Currie, 20 Castle Terrace, Edinburgh EH1 2ES.
Accessing and updating
You are entitled to apply to see the information held about you. This is called a data subject access request and you can make a request by contacting by email at email@example.com or by post to the Marketing Team, Martin Currie, 20 Castle Terrace, Edinburgh EH1 2ES. This request will be responded to within 30 working days and you will be provided with a copy of the information we hold about you. If we require more time to respond fully to any request, we will notify you in writing within the 30-day period referred to. Any additional copies of any information we provide to you may be subject to a reasonable fee.
You also have other rights under Data Protection Laws in relation to your personal data. In particular, you may have (i) the right to request that we rectify or erase information we hold about you in certain circumstances, (ii) the right to ask us to limit our processing of your information, (iii) the right (if we are processing information based on your consent, such as for marketing purposes) to withdraw your consent, (iv) the right to object to certain processing of your information (including the right to object to processing of your personal data for direct marketing purposes at any time), (v) the right to ask us to move, copy or transfer your personal information to another organisation. If you wish to exercise any of these rights, please contact us by email at firstname.lastname@example.org or by post to the Marketing Team, Martin Currie, 20 Castle Terrace, Edinburgh EH1 2ES.
Accuracy of personal data
Martin Currie seeks to ensure that your information is accurate and is up to date. Please assist us by ensuring that you inform us of any changes to your information.
We employ up to date data storage, back up and security measures that seek to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. We apply robust information security management processes which we believe are in line with the standards required and prevailing in our industry.
Disclosure and sharing of your personal data
We will not disclose personal information we hold to any third party except as set out below.
We may disclose personal data to other members of the Legg Mason group and to third parties who are providing services to us, including IT, marketing, law enforcement agencies, custodian and data cleansing service, or for any other purpose specifically permitted by applicable data protection laws or for any other purpose which you may authorise.
Martin Currie operates through various local legal entities and affiliates which we add to or reorganise from time to time. Please see details of how we treat your data in these circumstances below.
We may also disclose personal data we hold to third parties:
- in the event that we sell any business or assets, in which case we may disclose personal data we hold to the prospective buyer of such business or assets; and/or
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Transferring personal data outside the EEA
We may transmit, transfer or process information to, or through, any country in the world, as we deem necessary, and as appropriate or consistent with legal or regulatory obligations. When you provide information to any part of Martin Currie you will in most cases be providing it to the Martin Currie group as a whole, and you should be aware that it may be accessed from countries whose laws provide various levels of protection for personal data, not always equivalent to the level of protection that may be provided in your own country. However, for the processing of your data, Martin Currie seeks to ensure a level of protection equal to that in the European Economic Area. We share personal information among our affiliates and business units including to the US in connection with the purposes listed above to provide us with services, but we shall ensure that such transfers comply with applicable laws by putting appropriate safeguards in place. If you wish to obtain further information on these safeguards, please contact us by email at email@example.com or by post to the Marketing Team, Martin Currie, 20 Castle Terrace, Edinburgh EH1 2ES.
Retention of data
We will keep personal data as required by applicable laws and regulations and in accordance with our data retention policy.
Changes to this policy
We may make changes to this data protection policy at any time. Any changes we make will be posted on this page and, where appropriate, notified to you in writing. Please refer back to this page regularly to see any changes or updates to this policy.
All queries relating to our use of your information should be addressed to the Marketing Team, Martin Currie, Saltire Court, 20 Castle Terrace, Edinburgh, EH1 2ES or email firstname.lastname@example.org.
If you are not satisfied with our response to any queries or complaints you raise with us or believe we are not processing your personal data in accordance with the Data Protection Laws you can complain to the Information Commissioner's Office.
A "cookie" is a piece of information that is saved to the hard drive of your computer and "remembers" information about the configuration of your computer. Cookies perform different functions, such as letting you navigate between pages efficiently, remembering your preferences, and generally improving the user's experience.
We use this information to enable and improve certain functions on our websites, track your movements through our websites to find out how our websites are being used and assess their usefulness. The information we collect in this process will not identify you as an individual. In some circumstances our records will identify organisations visiting our sites and we may use that information in managing our relationships with those organisations, for example, in considering how to develop the services we offer them.
The browsers of most computers, smartphones and other web-enabled devices are initially set to accept cookies. If your browser preferences allow it, you can configure your browser to accept all cookies, reject all cookies or enable acceptance of specific cookies. It may also be possible to configure your browser settings to notify you each time a new cookie is set. Each browser is different, so check the "Help" section of your browser to learn about how to change your cookie preferences. By using our sites, you agree that we can place these types of cookie on your device.
However, please remember that cookies are often used to enable and improve certain functions on our website. If cookies are disabled, it may mean that you experience reduced functionality or will be prevented from using this site altogether.
Cookies can be classified as session or persistent cookies, depending on how long they are used:
- Session cookies are temporary and expire at the end of a browser session; that is when you leave the site and disappear from your computer or device when you close your browser. Session cookies allow the website to recognise you as you navigate between pages during a single browser session and allow you to use the website most efficiently.
- Persistent cookies in contrast to session cookies, persistent cookies are stored on your computer or device after the browser has been closed and last for the period of time specified in the cookie, or until they are deleted. These persistent cookies are activated each time you visit the site where the cookie was generated. They therefore enable the website to "recognise" you on your return, remember your preferences, and tailor services to you.
You can disable the cookies that we attach if your browser supports this. For further information on how to do this, please refer to www.aboutcookies.org. However, you should bear in mind that if you exercise this option, you may be unable to use some of our services.
Which cookies does Martin Currie use and why?
The following categories of cookies may be set on your device:
- 'Strictly necessary' cookies
These cookies are essential in helping you to move around our websites and use their features, such as accessing secure areas of the website. Without these cookies, a user would need to login to access each page on a secure area or accept the regulatory information on each page. These cookies do not gather information about you that could be used for marketing or remembering where you've been on the internet.
- Performance cookies
These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error message from web pages. These cookies do not collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. The information is only used to improve how a website works. Martin Currie websites may use persistent cookies when using performance cookies.
- Functional cookies
These cookies allow the website to remember choices you make and provide enhanced, more personal features. The information these cookies collect is usually anonymised which means we are not able to identify you personally. They do not gather any information about you that could be used for selling advertising or remembering where you've been on the internet, but do help with advertising. Martin Currie websites may use persistent cookies when using functional cookies.
In order to keep the Martin Currie websites relevant, easy to use and up-to-date, we use web analytics services to help us understand how people use them. These web analytics services may be designed and operated by other companies on our behalf. When you are viewing a website, a cookie is transferred to your browser by the web server and is stored on your computer. It can only be read by the server that gave it to you. Cookies allow web analytics services to recognise your browser or device and, for example, identify whether you have visited Martin Currie websites before, what you have previously viewed or clicked on, and how you found us. The information is anonymous and only used for statistical purposes. It allows us to track information, such as how many individual users we have and how often they visit our websites. It also helps us to analyse patterns of user activity and to develop a better user experience.
- Other third party cookies
On some pages of Martin Currie websites cookies may be set that are not related to Martin Currie or our authorised service providers. These service providers may set their own anonymous cookies on your web browser to track the success of their application or to customise their application for you. Martin Currie does not control the use of these cookies and cannot access them due to the way that the cookies work, as the cookies can only be accessed by the party who originally set them. You should check the third party websites for more information about these cookies. As with first party cookies, you are able to block third party cookies through your browser settings.
More information about cookies (including how to turn off cookies), can be found at www.allaboutcookies.org.
This is a list of the cookies used by the Martin Currie websites.
Do cookies store personal information?
Below is a list of the cookies used by the Martin Currie websites. The list sets out the purposes for which we use them.
|Website cookies (Sitecore CMS)
|Online notification form cookie
||These cookies are the default cookies used by ASPNET to uniquely identify the user's session on the site and relate the visitor's unique session to server side data. They are applicable for all types of connection. The cookie will expire at the end of the session (when you close your browser).
||Sitecore user ID
||To identify a sequence of HTTP requests from a single user, Sitecore sends this Engagement Analytics session cookie to the web client. They are applicable for all types of connection. The cookie will expire after ten years.
||To identify a sequence of HTTP requests from a single user, Sitecore sends this Engagement Analytics session cookie to the web client. They are Applicable for all types of connection. The cookie will expire at the end of the session (when you close your browser).
|Sitecore regional preferences
||These cookies are used by the website to store information about the regional preference set by the user.
Applicable for all types of connection. The cookie will expire after three years.
||This cookie is essential to ensure that once a user states their investor type and region, subsequent pages do not require the user to repeat this confirmation
||Price list / Fund tab
||Used to remember which tab on the price and fund pages was last selected
|__utma, __utmb, __utmc, __utmz
||These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us
improve the site. The cookies collect information in an anonymous form, including
the number of visitors to the site, where vistors have come to the site from and the
pages they visited. More information available on Google.
|Profundcom email marketing
||Profundcom cookies are used to track a contact's online engagement. A contact is "cookied" by clicking on an email or completing a landing page. These cookies personalise the buyer and customer journey. Cookies do not expire and are only removed when the contact deletes cookies from a browser.
|Other third party cookies
|Vzaar cookie list
||Vzaar video platform
||Vzaar or a third party may place a number of cookies in your browser when a video is embedded on this site. Some of the cookies will only be used if you use certain features or select certain preferences, and some cookies will always be used. The full list of cookies and what they do is available on Vzaar site.
|Google map cookies
||Shorthand presenter cookies
||Cookie used by Shorthand software that includes the IP addresses of devices you use to access presentation, the kind of web browser you use and the Shorthand stories you have visited. Used to implement the concept of a "session" in our web applications, and also to help streamline the user experience when you visit our websites. More information.