Privacy and Cookie Policy

Privacy policy

Please read the following privacy notice which applies to our global business and which is based on EU data protection principles to understand how we use and protect the information that you provide to us.

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 notice 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 United Kingdom’s Data Protection Act 2018, the General Data Protection Regulation (Regulation (EU) 2016/679) and the Privacy and Electronic Communications Regulation 2003 ("Data Protection Laws"). Please read the notice carefully.

You have the right to request access, amendments, or deletion of data we hold about you or to object to certain processing activity. If you wish to do so, please complete and return the Individual Rights Request Form.

If you are applying for a career at Martin Currie, please read the Candidate Privacy Notice to understand how we collect and process data during, and after, the application process.

Data controller

For the purposes of the Data Protection Laws, the data controller of your personal information is Martin Currie (Holdings) Limited of 5 Morrison Street, 2nd floor, Edinburgh, EH3 8BH.

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.

• name;
• 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 info@martincurrie.com or by post to the Marketing Team, Martin Currie, 5 Morrison Street, 2nd floor, Edinburgh, EH3 8BH.

Accessing and updating

You are entitled to request if Martin Currie processes your personal information, you have a right to access the personal information and be provided with a copy. You can make an access request by contacting by email at info@martincurrie.com or by post to the Distribution Team, Martin Currie, 5 Morrison Street, 2nd floor, Edinburgh, EH3 8BH. This request will be responded to within one month of the receipt. This may be extended by a further two months in certain circumstances, for example where requests are complex or numerous. 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 info@martincurrie.com or by post to the Distribution Team, Martin Currie, 5 Morrison Street, 2nd floor, Edinburgh, EH3 8BH.

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.

Security

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 Franklin Templeton 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:

1. 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
2. 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.

International transfers and data sharing

The countries to which we transfer data outside of the UK are the members of the European Economic Area (EEA) are United States, Singapore and Australia. 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 UK. 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 info@martincurrie.com or by post to the Marketing Team, Martin Currie, 5 Morrison Street, 2nd floor, Edinburgh, EH3 8BH.

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 notice 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 notice.

Contact

All queries relating to our use of your information should be addressed to the Marketing Team, Martin Currie, 5 Morrison Street, 2nd floor, Edinburgh, EH3 8BH or email info@martincurrie.com.

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.

Cookie policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a better experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree. Cookies contain information that is transferred to your device’s hard drive.

When entering this website, you will have been informed that we intend to use cookies and asked whether or not you consent to our use of cookies.

• If you have said “I agree” to cookies, your consent will be saved and you will not be asked again about cookies on subsequent visits to our website. We will still remind you that cookies are being used and give you information on how to disable them.
• If you have selected “No Thanks” to cookies, we will not store any on your hard drive for the duration of your session. You will be asked the same question about cookies the next time you visit this website.
• If you have chosen to navigate to another page on the website without choosing either option, we will assume that you acknowledge to the cookies used and your consent will be implied. On subsequent pages you visit, we will remind you that cookies are being used and provide you with information on how to disable them. You will be asked the same question about cookies the next time you visit this website.

Most web browsers allow some control of most cookies through the browser settings. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access parts of our site. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

This website uses Google Analytics cookies. To opt out of being tracked by Google Analytics across all websites.

Cookies we use

The cookies we use are "analytical" cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. You can find more information about the individual cookies we use and the purposes for which we use them in the table below: