Privacy Notice

Edinburgh Partners is committed to maintaining the privacy and security of personal information entrusted to us and has developed policies that are designed to protect this privacy and security, while allowing us to provide investment management or investment advisory services to our clients.

This notice describes how Edinburgh Partners, as “data controller”, may collect and use personal information provided to us in the course of operating our business and our website. This notice also sets out the rights available to you in connection with our use of your personal information.

References to “Edinburgh Partners” or “we”/“us”/“our” in this notice shall be construed as references to Edinburgh Partners Limited, Edinburgh Partners AIFM Limited and, to the extent that it collects or uses personal information from individuals based in the European Union, Edinburgh Partners North America Inc.

Whose personal information does this privacy notice apply to?

This notice describes our practices when collecting and processing personal information of individuals:

• connected with, or employed by, institutional investors or other clients to whom Edinburgh Partners provides investment management or investment advisory services;
• connected with, or employed by, financial intermediaries and other professional third parties, such as custodians, auditors, lawyers and other service providers, with whom Edinburgh Partners has a business relationship; and/or
• who visit the Edinburgh Partners website at www.edinburghpartners.com (“our website”).

This notice is not intended for individuals employed by Edinburgh Partners. If you are an employee of Edinburgh Partners, please refer to the Employee Privacy Notice included within the Edinburgh Partners Employee Handbook.

This notice is not intended for individual investors in any Investment Trust or Open Ended Investment Company (OEIC) / Undertaking for Collective Investment in Transferable Securities (UCITS) managed by Edinburgh Partners. If you are an investor in any such vehicle, please refer to the privacy notice issued by such investment vehicle and available on the website page specific to that investment vehicle.

What personal information do we collect and how do we collect it?

We may collect and process the following categories of personal information about you:

Information you provide to us during the ordinary course of our business relationship
• Contact details such as name, title, profession, job title, position, address, telephone number and email address.
• Identification details / documentation such as name, title, sex, age/date of birth, place of birth, nationality, address, telephone number, email address, passport information, national identification number, dealer number, dealer name, photograph and signature.
• Information which you provide to us when requesting information from us in person, via email, via telephone or via our website.

Information we collect or generate during the ordinary course of our business relationship
• Communications between you and Edinburgh Partners including emails, telephone calls and letters. Please note that, for regulatory purposes, we may be required to retain a record of certain communications, particularly email and telephone communications, in their entirety for periods of up to 10 years.
• CCTV footage if you visit us at our offices.

Information we collect or generate via our website (see note below)
• Information that you provide by filling in forms on our website such as name, title, profession, job title, position, address, telephone number and email address .
• Where we provide online access to your account via our website, log-in and similar credentials.
• Information about how you use our website such as device information (e.g. device brand and model, screen dimensions), unique identification numbers (e.g. IP address and device ID), and session information (e.g. URL, browser type, pages visited, search terms entered, date/time of access).
• Information captured by the cookies on our website (please refer to the Cookies Policy available via our website for further information).
• Information you provide when you subscribe to email newsletters or other periodic communications.
• Information you provide when you respond to a survey or marketing communication.

Note:

Please note that our website may contain links to websites or content operated and maintained by third parties. Please consult the privacy policies of those third parties, which should be available on their respective websites, for more information on how they process your data. We cannot control and accept no liability for how those third parties process your data. Please note that the decision to provide this information via our website is optional. However, if you decide not to provide such information, you may not be able to access certain content or features available on or through our website.

Information we receive from other sources
• Information provided by your employers or from other professional third parties with whom we share a relationship such as contact details and identification details / documentation.
• Information provided by third parties (e.g. fraud prevention agencies) when verifying your identity and when carrying out anti money laundering checks. Such information may include details about any criminal convictions and allegations, as well as details of your status as a politically exposed person. It may also include identification details / documentation.

It is our notice to collect only such personal information from business contacts as is necessary in order to provide our services, to ensure proper administration of our business including our website, or to meet legal, regulatory and compliance requirements.

Please note that if any of the personal information you provide to us does not relate to you (e.g. information about your colleagues or representatives), you should ensure that have obtained the necessary consent in order to disclose such information.

What do we do with your personal information?

We use the personal information collected from you for the following purposes:

• To verify the identity of our clients and other professional third parties (i.e. the entity you are connected with or employed by) for anti-money laundering purposes and to meet our regulatory obligations in the prevention of fraud, terrorist financing, bribery and corruption, and to ensure that we do not provide services to or receive services from persons who may be subject to economic or trade sanctions.
• To provide investment management or investment advisory services to our clients, to manage and administer our clients’ accounts on an on-going basis, to fulfil the terms of our agreements with our clients and other professional third parties.
• To facilitate our business relationships with clients and other professional third parties and to communicate with you about those relationships.
• To protect your interests and your data or, where applicable and only to the extent that your interests are not infringed by such use, the interests of our mutual clients or other professional third parties.
• To provide you with information about Edinburgh Partners and relevant performance information, thought pieces or other information produced by us, unless you have indicated to us that you do not wish to receive such information.
• To invite you to relevant events unless you have indicated to us that you do not wish to receive such information.
• To use it for our legitimate business interests, such as undertaking internal business research and analysis to help us improve our services, managing the operation of our websites (which may include analysis of usage and measurement of site performance).
• To establish, exercise or defend our legal rights or for the purpose of legal proceedings.
• To comply with our legal and regulatory obligations, including to retain certain records and to look into any complaints you may have in connection with our services.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

What are our grounds for using your personal information?

We use your personal information pursuant to the following legal bases:
• To comply with our legal and regulatory obligations.
• To perform our obligations under a contract with you, with our clients or with other professional third parties.
• To pursue our legitimate business interests where we consider that our interests are not overridden by your interests or rights which require protection of your personal information. Such legitimate business interests include:
– improving and managing the services we provide, including via our website;
– enforcing the terms and conditions of any agreement we have with our clients or other professional third parties;
– populating client relationship management systems to facilitate ongoing relationships with our clients or other professional third parties;
– conducting internal audits for the purposes of managing our business; and
– promoting Edinburgh Partners and the services we provide.

Who do we share your personal information with?

Personal information collected from you is generally processed by our staff in the United Kingdom. From time to time your personal information may need to be processed by Edinburgh Partners staff located outside the United Kingdom to enable us to provide our services, answer your query or fulfil your requests.

We may also need to share your personal information with:

• Other entities within the Edinburgh Partners group of companies, including Edinburgh Partners Limited, Edinburgh Partners AIFM Limited, Edinburgh Partners North America Inc. and our parent company, Franklin Resources Inc.
• Financial intermediaries and other professional third parties, such as custodians, auditors, lawyers and other service providers, with whom Edinburgh Partners has a business relationship.
• Competent authorities such as tax authorities, courts, regulators and security or police authorities where required or requested by law or where we consider it necessary.

Transfer of personal information outside the European Union (“EU”)

In accordance with the above, the personal information we collect from you may be transferred to, and stored, outside the EU and may also be processed by people operating outside the EEA who work for us or one of our professional third party service providers.

Countries outside the EU may have a lower standard of protection for personal information than the standard required by EU data protection laws. If we need to transfer your data outside the EU we will take steps to ensure your personal information is protected and safeguarded once it leaves the EU.
We have policies and processes in place to oversee the effective and secure transfer and processing of your personal information. Where we transfer your personal information outside the EEA, this may include implementation of EU Data Protection Model Clauses approved by the European Commission between Edinburgh Partners and the recipient of personal information. More information on how we protect your personal information can be provided when it is transferred outside the EU (including a copy of the relevant EU Data Protection Model Clauses) upon request to the contact details provided below.

How long do we retain personal information?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or regulatory requirements.

As a regulated business, we are subject to a number of legal and regulatory obligations, in the UK and overseas, which require us to keep records for certain specified periods. Although such periods will differ from country to country, in the majority of instances we will keep your personal information for the duration of our relationship and then for periods of up to 10 years following the end of our relationship, after which time it will be destroyed from its primary location. System back-ups and emailing archiving may be retained for longer periods.

How do we keep your personal information secure?

Edinburgh Partners has implemented data protection and information security policies and procedures designed to keep data, including your personal information, confidential and secure. All personal information retained by Edinburgh Partners is kept in secure locations with limited access. Our employees have been provided with training on responsibilities connected to information security, including the reporting of any information security incidents, and are required to follow Edinburgh Partners’ data protection and information security policies.

Our electronic systems are subject to security, including backups, virus protection and access controls. However, please note that sending information over the internet is not completely secure, and we cannot guarantee the security of your personal information while it is in transit. Any personal information you send over the internet is sent at your own risk. As outlined above, we have implemented reasonable technical and organisational measures designed to keep your personal information secure once we receive it.

What are your rights in connection with your personal information?

You have the following rights, under certain circumstances, in relation to your personal information:

Right to access personal information: You have the right to obtain confirmation that your data is being processed and to access to all of the personal information stored by Edinburgh Partners.

Right to rectify personal information: You have the right to request that inaccurate or incomplete personal information relating to you is rectified.

Right to request that personal information is erased: You have the right to request that personal information is erased if it is no longer needed for its original purpose. Please note that there may be circumstances where you ask us to erase your personal information but we are legally required and/or entitled to retain it.

Right to restrict processing: You have the right to request that personal information is processed for only limited purposes or that processing is suspended if you want us to establish the accuracy or reason for processing.

Right to data portability: In certain circumstances in relation to personal information which you have provided to us, you are entitled to receive personal information in a structured, commonly used and machine-readable format and/or requesting that we transmit that information to a third party where this is technically feasible.

Right to object: Where personal information is processed under the legal basis of public interest or legitimate interests of the controller individuals have the right to object to processing.

Right to withdraw consent: In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

You can exercise your rights by contacting us at: enquiries@edpam.com.

Where we receive a request to exercise one of these rights, we shall provide information on the action we take on the request without undue delay and in any event within one month of receipt of the request. We may ask for additional information to verify your identity before carrying out a request. Where requests are manifestly unfounded or excessive in nature, Edinburgh Partners may charge a reasonable fee or to refuse to carry out the request. Where we do not carry out a request, we will inform you without delay and within one month of receipt of the request, providing our reasons for not taking the action requested.

If you are not satisfied with our response to your request, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the supervisory authority for data protection matters in the United Kingdom or, as may be the case, to any other competent supervisory authority of an EU member state.

Changes to this notice

We keep this notice under review and may update it from time to time. Any changes to this notice will be posted on our website and, where appropriate, notified to you by e-mail. We recommend you regularly review our website to ensure that you are aware of our information practices and any updates to this notice.

Further information

If you have any concerns or require any further information, please do not hesitate to contact enquiries@edpam.com.