Privacy Notice

This Privacy Notice governs your use of Link Group websites. For our specific services or jurisdictions.

1. Who are Link Group?  

Link Group is a trading name of companies which offer corporate market services, fund solutions, retirement and superannuation solutions, and technology and operations services. The companies that offer banking and credit management services trade as Link Asset Services.

All the companies listed are wholly owned subsidiaries of Link Administration Holdings Limited which is a company incorporated in Australia and listed on the Australia Securities Exchange. The company’s registered address is Level 12, 680 George Street, Sydney, NSW, 2000, company registration number 120964098. Link Administration Holdings Limited together with its subsidiary companies form the Link Group (“Link Group”). For more information, please visit www.linkgroup.com.

2. What is this Privacy Notice?

At Link Group where we collect personal information about you, we are committed to protecting this information and your privacy. Set out below is an explanation of how we use, collect and safeguard your personal information. 

3. What personal information do we collect?

The principles of data protection are that only sufficient personal data should be collected and processed as is necessary for the purpose.  Link Group will collect and use only as much personal data from you as is necessary to be able to provide you with the products and services you have requested from us.

The information we collect depends on the nature of our relationship with you. For example, if you are a client invested in our funds, we collect personal information that may identify you, such as your name and contact details, your date of birth and information about your bank. Where other people are named in your investment such as beneficiaries, we may ask you to provide information in relation to these people too.

As part of your use of our website you have the option on certain pages within this site to submit personal information to us by email, online enquiry or quotation form. Depending on the services, products or information you request from us, we may process the following personal information:

• Name, address, email address, telephone number and other contact details which you provide us with on completing, for example, Enquiry Form, Events Form or Application Form; 
• A record of any correspondence you have with us, including certain telephone calls which we may be legally required to record (but we will inform you at the beginning of the telephone conversation if recording will be necessary); 
• Online identifiers including IP address and cookies; 
• We collect personal information about you from things you tell us yourself and from things we ask other people or organisations to share with us. Things you tell us could come from conversations we have on the phone, what you’ve written on a form or if you send us an email. We might also collect information about you from other people and organisations, such as the Financial Conduct Authority or by checking databases like the electoral register. Please see below for a list of some of the ways we collect your personal information.
• We collect personal information directly from you:
  • via application and various event registration forms;
  • through feedback forms and other forums;
  • when you purchase any of our products or services;
  • when you fill out a survey, or vote in a poll on our website;
  • via our telephone calls with you, which may be recorded;
  • when you provide your details to us either online or offline;
  • when you send an email; and
  • via cookies, which you can find out more about in the cookies policy on our website.

Depending on the nature of our relationship with you, we may also collect your personal information from a number of different sources including:

• through companies which validate identity for financial crime purposes using tools such as the electoral register (this is not a credit check, but a record of the search may be retained);
• from third party registers maintained by regulators such as the Financial Conduct Authority;
• through business interactions between your company and Link Group;
• from your financial advisor; and
• from family members if you become incapacitated or unable to provide information relevant to your investment.

If you are interested in attending our events, we may collect personal information such as your name, contact details and any dietary preferences as well as your consent to send you information about our products and services.

• Depending on our relationship with you, in certain limited circumstances we may request or receive sensitive personal information about you, such as details about your health if for example you require correspondence in braille, or your health or religion if you attend our events and have certain dietary preferences.

Where Link Group is the data controller of your personal information we may collect the following personal information about you:

• Contact details such as name, email address, postal address and telephone number;
• Details of any other persons included in the investment;
• Identification information such as your date of birth, national insurance number, passport, tax identification number and driving license or other personal identifiers recognised in the country where you reside;
• Financial information such as bank details;
• Information relevant to your investment;
• Information obtained through our use of cookies. You can find out more about this in our cookies policy below; and
• Your marketing preferences

4. Why do we collect your information?

This is dependent upon the nature of the relationship we have with you:

• If you are a client, we use your personal information to administer your investment product or provide a service to you in our capacity as a data controller;
• If you are a financial advisor or an employee of a financial advisory firm, we use your personal information to provide you with information about our products, services and events;
• If you are an employee of a firm that we have a business relationship with, we use your personal information as part of our normal course of business in our capacity as a data processor acting under contract to the firm that employs you;
• If you are a candidate for a job, we use your personal information as part of our recruitment process in our capacity as a data controller, more information is provided on our recruitment site;
• If you are viewing our website, we use your personal information contained in cookies.

We collect this information in order for you to use our website and to provide any services to you. Our use of your information is based on a legitimate business interest we have in being able to provide the services. 

5. What is the legal basis associated with the main purpose?

We may process your personal information for a number of different purposes. We also need a lawful reason to use and process your personal information which is called ‘lawfulness of processing’.

• Where we are assessing your application and setting you up as an investor, administering and managing your investment, providing all related services, handling any changes to your data, making payments to you and communicating with you, then the processing is necessary for the performance of a contract to which you are party.
• Where we are providing you with information about our products or events that we hold, the processing is necessary for our legitimate interest.
• Where we maintain a business relationship with you or your firm, the processing is necessary for our legitimate interest.

If you do not provide information, in the circumstances detailed above, we will be unable to offer you an investment, process your payment requests or interact with you for normal business purposes.

• Where a regulator such as the Financial Conduct Authority requires us to maintain certain records of any dealings with you, the processing is necessary for us to meet our legal and regulatory obligations.
• Where we need to use your personal information to establish, exercise or defend our legal rights. For example, when we need to consult a solicitor or manage any legal claims, or where we want to pursue any legal claims ourselves, the processing is necessary for us to meet our legal obligations.
• Where we need to use your personal information to carry out anti-money laundering checks or investigate fraud, the processing is necessary for reasons of public interest.

We will usually only ask for your consent in relation to processing your Special Category information (such as health data), or when providing marketing information to you (including information about other products and services) where we do not yet have a relationship with you. This will be made clear when you provide your personal information. If we ask for your consent we will explain why it is necessary.

In addition, we are required by law to obtain “know your client” information as detailed in our service contract, or other relevant information sources and this includes certain personal information.

6. How we use your personal information?

7. Who we share personal information with?

We will only disclose your personal information in accordance with applicable laws and regulations applicable to the countries in which our businesses operate. We will disclose your information to the following third parties:

• Any person with legal or regulatory power over us (such as the Financial Conduct Authority, the police or the Serious Fraud Office that may require disclosure on legal grounds, or other relevant Government departments where reasonably necessary for financial crime and sanction prevention purposes).
• Service providers engaged by us to help us run our business and perform the Services/our contract with you. Such service providers will include, for example, cloud storage providers (engaged by us to provide electronic storage facilities for our business data and your information). Other services providers such as IT system suppliers, auditors, lawyers, marketing agencies, document management providers and tax advisers.
• Your relatives, powers of attorney, guardians acting on your behalf or other people or organisations associated with you such as your financial advisor or your lawyer whenever you have given us permission to share your personal information with them.
• Our third party investment product and service administrators
• Identity and Verification agencies
  • Other parties in commercial relationships with Link Group, including financial organisations and advisors where necessary to enable us to fulfil our service to you.
• Any member of the Link Group which means; our subsidiaries, our ultimate holding company and its subsidiaries (from time to time) as necessary to perform our Services.

Some of these third parties (including Link Group subsidiaries and service providers) may be outside of the European Economic Area (EEA). We will ensure that any such subsidiary or service provider has put in place adequate safeguards to ensure that your information is held securely and in accordance with this Privacy Notice. Such steps will include placing the party we are transferring personal information to under contractual obligations to protect it to adequate standards. Transfers within the Link Group will be covered by an agreement entered into by members of the Link Group (an intra-group agreement) which contractually obliges each member to ensure that your Personal Data receives an adequate and consistent level of protection wherever it is transferred within the Group.

8. How do we keep your information secure? 

We store the information you provide about yourself in a secure database and take appropriate security measures to protect such information from unauthorised access.

We take protection of your personal information and our system security very seriously.  Any personal information which is collected, recorded or used in any way will have appropriate safeguards applied in line with our data protection obligations.

We implement Internal and external audits and regular, independent assurance exercises across our business to ascertain the effectiveness of our security control environment and our security strategy.

Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect your personal and confidential information whenever they are processing it and must undertake annual training on this.

Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.

All exchanges of information between you and our website go through encrypted channels in order to prevent interception of your information. Public access to your information via and our website / the portal / any web-hosted platform is protected by a login using your user ID and password. You should ensure that these are kept secret and not divulged to other people. You recognise that your use of our website is entirely at your own risk. Link Group websites operate on the internet, which is inherently insecure, Link Group cannot guarantee the information you supply will not be intercepted while being transmitted over the internet.  Accordingly, Link Group has no responsibility or liability for the security of personal information transmitted by you via our website.

9. How long will we store your information for? 

We generally hold your personal data on our systems for as long is necessary to provide services to you. The time period for which we keep your personal data will depend on the services we provide to you. Service-specific privacy notices are available on the right of this notice. Our website uses Google Analytics where a record of some of your personal data (e.g. IP address) will be retained for 38 months.

• The time period we retain your personal information for will differ depending on the nature of the personal information and what we do with it. How long we keep personal information is primarily determined by our regulatory obligations.
• We typically keep personal data used for your investment product for 7 years from the end of our relationship with you. In some cases where there may be a dispute or a legal action we may be required to keep personal information for longer.
• If we anonymise your personal information so that it can no longer be associated with you, it will no longer be considered personal information, and we can use it without further notice to you.

10. Your rights

You have the following rights in relation to how we use your information. If you’d like to exercise these rights please contact us using the contact details listed at section 14 “Who can you speak to at Link Group about this Privacy Policy?”

Right to lodge a complaint
You have a right to complain to the ICO at any time if you object to the way in which we use your personal information. More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/

Right of access
You have the right to know if we are using your information and, if so, the right to access it and information about how we are using it.  There will not usually be a charge for dealing with these requests. Your personal information will usually be provided to you in writing, unless otherwise requested. Where you have made the request by electronic means the information will be provided to you by electronic means where possible.

Right of rectification
We take reasonable steps to ensure that the personal information we hold about you is accurate and complete. However, if you do not believe this is the case you have the right to require us to rectify any errors in the information we hold about you. 

Right to erasure
You have the right to require us to delete your information if our continued use is not justified. However, this will need to be balanced against other factors, depending upon the type of personal information we hold about you and why we have collected it, there may be some legal and regulatory obligations which mean we cannot comply with your request.

Right to restrict processing
In some circumstances, although you may not be entitled to require us to erase your information, but may be entitled to limit the purposes for which we can use your information.

Right of data portability
You have the right to require us to provide you with a copy of the personal information that you have supplied to us in a commonly used machine-readable format or to transfer your information directly to another controller (e.g. a third party offering services competing with ours).  Once transferred, the other party will be responsible for looking after your personal information.

Right to object to direct marketing
You can ask us to stop sending you marketing messages at any time. Please see below.

Right not to be subject to automated-decision making
Link Group do not make decisions about you using automated decision making or profiling of your personal data.

Right to withdraw consent
For certain limited uses of your personal information, we may ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information.  If you withdraw your consent, we may not be able to provide certain products and services to you. If this is the case, we’ll tell you at the time you ask to withdraw your consent.

In some circumstances exercising some of these rights will mean we are unable to continue providing you with your investment or maintaining a business relationship with you.

You can make any of the requests set out above using the contact details in this Privacy Notice. Please note that in some cases we may not be able to comply with your request for reasons such as our own obligations to comply with other legal or regulatory requirements. We will always respond to any request you make and if we can't comply with your request, we will tell you why.

Marketing
You are in control of how we use your information for marketing and we will only contact you if you have purchased one of our products or expressed an interest in attending one of our events. In these circumstances, we may share information within the Link Group group to inform you of other similar products and services that may be of interest to you, unless you tell us that you do not wish to receive this information.

If you wish to unsubscribe from any emails sent by us, you may do so at any time by following the unsubscribe instructions that appear in the email. Otherwise you can always contact us using the details set out in this Privacy Notice to update your contact preferences. In such circumstances, we will continue to send you service related (non-marketing) communications where necessary.

11. How do Link Group websites use my Internet Protocol (IP) address and collect cookies?

Each time you use our websites, we will automatically collect certain technical information, including the type of browser you use, the Internet Protocol (IP) address used to connect your computer to the internet, and information about your visit, including the full Uniform Resource Locations (URL), clickstream to, through and from our sites, traffic data and other communication data, the resources that you access, and the information derived from the cookies we place on your mobile device and/or computer.

In order to improve the quality of our website and services, we may from time to time send your computer a "cookie". Cookies are text files that identify your computer to our server and are stored on your device. Cookies in themselves do not identify the individual user, just the computer used. Cookies enable us to improve your user experience by avoiding the need for you to enter the same information more than once. They also allow us to analyse user behaviour to improve the functionality and performance of our website.

We comply with the EU cookie regulations as introduced in the UK on 25 May 2011 through the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011. There are two types of cookies that can be stored on your device:

• "session cookies", which only last for the duration of your visit to our website and are automatically deleted from your device when you close your browser; and
• "persistent cookies", which remain on your device after you have visited our website and are not deleted when you close your browser. Persistent cookies are sent back to our server every time you visit our website.

We make use of session cookies, which are essential to maintain security throughout the site, and are not used for tracking purposes. Session cookies are used to help us remember your movements from page to page, avoiding the need for you re-enter the same information. Session cookies are held in memory and expire when you leave our website.

In addition, in order to develop our site in line with customers’ needs, Link Group use an analytics and optimization service provided by WT EMEA Acquisitions Ltd (WebTrends) to track and analyse how parts of the site are used. We use this information to help improve the site. The data collected by WebTrends will be stored exclusively for analytical purposes and does not result in any personally identifiable data being collected or stored. WebTrends will send your computer a persistent cookie in order to evaluate your use of this site. WebTrends store the information collected by the persistent cookie on servers in the United States, European Union Member States and other countries. WebTrends may also transfer this information to third parties where required to do so by law, or where such third parties process the information on WebTrends' behalf. WebTrends will use this information for the purpose of evaluating use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. WebTrends will not associate your IP address with any other data held by WebTrends. Link Group uses WebTrends to optimise this site and improve the service we provide to our visitors. This ensures that the website is fully functional and optimised to create the best possible user experience.

Our website uses Google Analytics, a web-based analytics tool that tracks and reports on the manner in which the website is used to help us to improve it. Google Analytics does this by placing small text files called ‘cookies’ on your device. The information that the cookies collect, such as the number of visitors to the site, the pages visited and the length of time spent on the site, is aggregated and therefore anonymous. The retention period for data that is associated with cookies, user identifiers or advertising identifiers is 38 Months.

We never gather other information from your disk or computer. We will collect a copy of the data held by the cookie from inclusion in any analysis. We use full SSL protocols when collecting visitor information on secure pages; this ensures that the site’s security is not compromised. We encrypt all transmitted visitor information (even from non-secure pages), so no-one else can read the information we gather. None of the cookies used on our websites collect, record or store personally identifiable information about you.

By continuing to use this website, you are consenting to us placing session cookies on your device for the purposes detailed above.  Most users will be able to adjust their internet settings to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these, of course, means that certain personalised services cannot then be provided to that user. Please note that the websites to which this site may be linked may also make use of their own cookies. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

12. Following links from our websites 

Our site may contain links to other sites. Such other sites may also make use of their own cookies and will have their own privacy policies. You should carefully review the privacy policies and practices of other sites, as we cannot control or be responsible for their privacy practices. We do not accept any liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

13. Changes to this Privacy Notice

Please note that this Notice will be reviewed and may be changed from time to time. Any changes we may make to our privacy policy in the future will be posted on this page.

14. Who can you speak to at Link Group about this Privacy Notice?

Questions, comments and the exercise of your rights regarding this Privacy Notice and your information are welcomed and should be addressed to the Data Protection Officer by email to data.protectionofficee@linkgroup.co.uk or by post at 65 Gresham Street, London EC2V 7NQ. 

If you wish to make a complaint on how we have handled your personal information, you can contact our Data Protection Officer. If you are not satisfied with our response or believe we are processing your personal information not in accordance with the law, you have the right to complain to the supervisory authority in the UK responsible for the implementation and enforcement of data protection law:

The UK Supervisory Authority is the Information Commissioner (the “ICO”). You can contact the ICO via their website: https://ico.org.uk/concerns/ or by calling their helpline: 0303 123 1113.

Updated: June 2019