Privacy Policy

Introduction

Argonaut needs to collect and use personal information about a variety of people including investors, staff and financial advisers. This policy explains what kind information we hold and how we use it.

Argonaut is committed to complying with all relevant data protection obligations and legislation inclusive of the Data Protection Act 1998, and to appropriate use and safeguarding of your personal information, If you are a corporate investor and provide personal information relating to individuals within your organisation, you agree to make such individuals aware of the uses and disclosures of information referred to in this policy.

What information do we collect?

Personal information could be provided by you or by others on your behalf, e.g. financial advisers. Usually this consists of the information provided on an application form for an investment in one of our funds. We may also collect information when you visit our website or when you complete a customer survey.

How will we use the information?

The main way in which the information will be used is to process transactions and administer the investment in your chosen fund or funds. However we may also use it for a variety of other purposes, for example, research and analysis, identity checking and to improve service. We may also use it for marketing. There is more information on this below.

Who will we disclose information to?

Your information may be sent to, and we may use information from, credit reference agencies and fraud prevention agencies. We may need to send your information to external parties if we are legally required or are permitted by law or regulation to do so. This could be as a result of, for example, a contractual obligation, a court order, a regulatory requirement (e.g. Financial Conduct Authority) or a request from another body or organisation such as the police, the Department of Work and Pensions or Her Majesty’s Revenue and Customs.

We use external outsourcers for a variety of purposes, e.g. to carry out administration on our behalf or to provide support services. As a result your information may need to be passed to them. This will change from time to time but currently includes by way of example administration services, document storage or retention and providers of IS services. In each case a contract will be put in place with these outsourcers or service providers with obligations about the use and security of your information.

In certain circumstances we may transfer your personal information overseas to countries that may not provide the same level of data protection as the UK. This is most likely to happen in the case of administration outsourcing. If we do this appropriate steps will be taken to ensure that your information is protected.

Your information will be disclosed to your financial adviser unless you ask us not to.

Will we carry out any marketing?

We would like to use your information from time to time to send to you information on other Argonaut products or services that we think you might be interested in. We will not send you this information unless you have ticked the consent box on the application form. If at any time you wish to be removed from marketing mailing lists please let us know. You can do this by phoning or writing to us using the following Argonaut contact details.

IFDS Mangers – Argonaut,
PO Box 11954,
Chelmsford,
CM99 2DR

Telephone: 0844 620 0290 (UK only)
+44 (0)1268 447403 (from outside the UK)
marketing@argonautcapital.co.uk

What are cookies?

A cookie is a small file of letters and numbers downloaded on to a device when the user accesses certain websites. Cookies allow a website to recognise a user’s device. A cookie can be used for authenticating, remembering specific information about users, such as site preferences or the contents of their electronic shopping carts.

The use of cookies on the Argonaut website is limited and currently only used to prevent our disclaimer pages from reappearing when you return to the site. If you do not wish to receive cookies you can disable the cookie acceptance function in your browser and delete all cookies from your browser. If you do so we will not be able to prevent the disclaimer pages from appearing when you return to the site.

For guidance on how to delete Cookies form your browser please follow the appropriate link below which is suitable to your browser.

Internet Explorer version 6,7 and 8 http://support.microsoft.com/kb/278835

Mozilla Firefox http://support.mozilla.com/en-US/kb/Deleting%20cookies

Google Chrome http://www.google.com/support/chrome/bin/answer.py?answer=95647

Opera http://www.opera.com/browser/tutorials/security/cookies/

By using the Argonaut website, you consent to the placing of cookies in the manner and for the purposes we have set out.

Google Analytics

The Argonaut website uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to compile anonymous, aggregated statistics that allow us to understand how users use our site and to help us improve the structure of our website, this information does include your IP address however we cannot identify you personally with that information.

The information collected will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Argonaut website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

To opt out of all Google Analytics tracking during your internet browsing you can download an Google opt out tool from http://tools.google.com/dlpage/gaoptout

By using this website, you consent to the processing of data about you by Google in the manner and for the purposes we have set out.

How do you access your personal information, update or correct it?

You have the right to ask for a copy of the information that we hold about you. We are entitled to make a small charge for providing this. If you would like information about, or a copy of some or all of, the personal information we hold please contact us using the details below.

If any of the information we hold about you is incorrect or has changed in any way please let us know and we will amend it.

IFAs, Professional Advisers, Sales contacts

We will hold name and other business contact details of IFAs, professional advisers, sales and prospect client contacts in our CRM (Client Relationship Management) database. This information is acquired from tender pitches, consultancy firms, seminars, roadshows, company websites, FCA register, and/or our sales team.

We will use the information to keep our contacts updated with any marketing or sales activity and other developments that we think might be of interest, carry out client reporting, send out fact sheets. We follow our recipient and/or sales staff requests for certain type of information when indicating contacts’ preferences to receive e-mail marketing in our database. We also use the information for marketing research and analysis. In some cases to enable us to provide a more personal client service and to build better client relationships we may hold more personal details.

If you want to change your marketing preferences or change your details please do so by contacting us using the email address marketing@argonautcapital.co.uk

Change requests in contact details or marketing preferences are actioned as soon as as received by sales support personnel.

We do our best to ensure data accuracy by cross checking details with FCA register and company web sites. With regards to institutional clients we maintain database entries with the help of information provided by Pooled Pensions. It enables us to keep track of our pooled clients, their Consultancy firm, Trustees and Auditors.

We collect, process, maintain and disclose our international clients’ data in accordance with UK data protection regulations.

Changes to this Privacy Policy

We keep our privacy policy under review and may change it from time to time. This policy was last updated in July 2012.

Queries or Complaints

If you have any queries about the personal information we hold or about this Privacy Policy please write to:

The Data Protection Officer
Argonaut Capital Partners
No.1 Grosvener Crescent
London
SW1X 7EF

Email: dataprotection@argonautcapital.co.uk

The Information Commissioner’s Office is the UK’s independent authority set up to promote access to official information and protect personal information. They provide lots of helpful advice and guidance. They can be contacted on: www.ico.gov.uk

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Tel: 08456 30 60 60 or 01625 54 57 45
Fax: 01625 524510