Privacy Policy

This notice describes how Levendi Investment Management Limited (Levendi) uses personal data. It outlines Levendi’s data protection obligations and your data protection rights under the regime introduced by the EU General Data Protection (Regulation 2016/679, the “General Data Protection Regulation”).

The GDPR applies to “personal data” meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.

Levendi needs to use your personal data to provide its services to you, so this notice outlines the following points about the processing of your personal data:

which data items are used, how they are used and who they are shared with;
why this is done and the lawful basis;
your rights and Levendi’s obligations.

Why Levendi needs to process personal data

Your Data are collected to effectively and properly manage your relationship with us. Data is stored for specific purposes and only data that is relevant to that purpose will be stored. We will use the Data for several different purposes, including;

to provide investment services and to carry out obligations arising from any agreements entered into between you and Levendi;
to provide you with information, products or services that you request from us (including through our website) or which we feel may interest you, where you have consented to be contacted for such purposes;
to make our procedures more efficient, to implement security measures and to combat fraud and other crimes;
to share with competent authorities (including tax authorities), courts and bodies as required by law or requested or to affiliates for internal investigations and reporting; and
to notify you about changes to our products and services and your investments.

If at any time you wish to be removed from marketing mailing lists or for any limits to be applied with respect to marketing materials received by you, please let us know. You can do this by e-mailing your Levendi relationship manager, data protection officer or any of the Levendi Team. Contact details are available on our contact page.

Data collection

Levendi may collect data:

when you or an agent of yours contacts Levendi in relation to business and services offered;
when you complete documents or forms during the course of business with Levendi;
from Service Providers and other third parties that assist us in conducting business;
when you telephone Levendi; and
when you use the Levendi website or online services.

Data storage

Levendi stores your data on physical and electronic media. Data is safeguarded by Levendi and its Service Providers by maintaining physical and electronic security controls that are designed to comply with applicable legal standards.

The Data that is collected or held in relation to you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who works for us or for one of our Service Providers. In some cases, the laws of the destination country may not provide the same level of data protection as countries within the EEA. However, all Data wherever they are held by Levendi will be afforded a high level of protection against any unauthorised or accidental disclosure, access or deletion. By submitting your Data you agree to this transfer, storing or processing.

Unfortunately, the transmission of information via the internet is not completely secure. Although Levendi will do its best to protect your Data, we cannot guarantee the security of your Data transmitted electronically. Any such transmission is at your own risk.

Types of data that might be collected

During Levendi’s relationship with you Levendi will collect and process Data about you, including:

information which individuals and entities provide when contacting us (including through using this website) such as their names, postal addresses, telephone numbers, identification documents and e-mail addresses;
corporate information;
details of services provided to you;
details of purchases and redemptions of financial instruments;
where permitted or required by regulators or the law, special categories of personal information such as health information or information relating to criminal convictions or offences;
detailed financial information, including investment portfolio details, income levels, taxation details, domicile and sources of income; and
information regarding relationships you have with banks and/or other financial institutions (including bank details).

Data sharing

Levendi uses Service Providers to conduct aspects of its business, so information may be disclosed to them and their affiliates including Data that you have provided in order to fulfil the purposes for which the Data is held. These Service Providers may disclose such Data to each other and to each other’s affiliates in order to achieve the same purposes.

Levendi and its Service Providers may also be required to disclose your Data to governmental agencies, self-regulatory organisations, industry associations and similar bodies in order to fulfil legal and regulatory requirements. In addition, the laws of certain countries and states give people involved in lawsuits and other legal proceedings the right under certain circumstances to obtain information from Levendi and its Service Providers, including your Data. Levendi and its Service Providers will comply with these laws to the extent required.

Levendi will not sell your Data to any third party. Wherever possible, Service Providers are required to enter into confidentiality agreements that prohibit them from selling or improperly using your Data.

Data retention

Levendi will retain your personal information for a period of up to seven years following the point where the business relationship has ceased.

It may be necessary to retain your personal information beyond this period depending on additional legal/regulatory obligations. Thereafter, Levendi will refrain from collecting any further personal information on you and shall take appropriate steps to dispose of any records containing your personal information to the extent this is operationally feasible and proportionate.

Lawful basis for processing

Levendi assesses all personal data that is collected or stored to ensure that there is a legal basis for each type of data under GDPR. Given that Levendi is an appointed representative of Thornbridge Investment Management Limited which is an FCA regulated firm, the predominantlawful bases for Levendi’s processing is to meet its obligations to Thornbridge and the FCA (legal obligation basis) and/or to fulfil its obligations to you under contract (contract basis).

Other lawful bases may be used where Levendi assesses this is necessary and appropriate.

Data subject rights

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

Right to access your personal information (in an easily readable form);
Right to rectify your personal information;
Right to restrict the use of your personal information (in certain specific circumstances);
Right to request that your personal information is erased (in certain specific circumstances). Please note that the right for your data to be erased (the “right to be forgotten”) that applies in some contexts under the General Data Protection Regulation is not likely to be applicable to most, if not all, of the personal information you provide to Levendi, given the specific nature of the purposes for which Levendi uses the data, as described above;
Right to object to processing of your personal information (in certain specific circumstances);
Right to data portability (in certain specific circumstances);
Right to withdraw consent (in certain specific circumstances); and
Right to receive information regarding any entities we disclose your data to.

Levendi shall notify you of any personal information breach affecting you that is likely to result in a high risk to your rights and freedoms.

Changes to this notice

Levendi will need to update its privacy notice in response to regulatory requirements or changes to its business. The latest notice will always be available on the Levendi website (www.levendi-im.com).

How to contact Levendi

Under the GDPR, data subjects can make a complaint to the supervisory authority including the Member State in which they reside or work or the place of the alleged infringement.

If you have any questions or concerns about personal data or this privacy policy or you wish to make a complaint about how Levendi has processed your personal data, please contact Levendi by writing to info@levendi-im.com or by post at the following address:

Data Protection Officer

Levendi Investment Management Limited

1 Heddon Street

London W1B 4BD

The contents of this website are communicated by, and the property of, Levendi Investment Management Limited. Levendi Investment Management Limited (FRN: 783607) is an appointed representative of Thornbridge Investment Management LLP (FRN: 713859) which is authorised and regulated by the Financial Conduct Authority (“FCA”).

Products and Services

The information contained herein is current at the date of publication, but is subject to change without notice. Levendi Investment Management Limited has expressed its own views and opinions on this website, and these may change without notice. This website is not directed at you if Levendi Investment Management Limited is prohibited by any law of any jurisdiction from making the information on this site available to you and is not intended for any use that would be contrary to local law or regulation. None of the information contained on this website is intended to constitute any offer to sell or an invitation or solicitation of an offer to buy any product or service by Levendi Investment Management Limited and must not be relied upon in connection with any investment decision. Products or services mentioned on this site are subject to legal and regulatory requirements in applicable jurisdictions and may not be available in all jurisdictions. Accordingly persons are required to inform themselves of and observe any such restrictions. Nothing in this website should be construed as investment, tax, legal or other advice.

Risk Warning

Past performance is not necessarily a guide to future performance. The value of investments and the income of any financial instruments mentioned in the website may fall as well as rise, and investors may get back less than the amount originally invested. Fluctuations in exchange rates may have a positive or an adverse effect on the value of foreign-currency denominated securities and financial instruments. Certain investments involve an above-average degree of risk and should be seen as long-term in nature. The investment products and services described in the website may have tax consequences. Any tax reliefs referred to are those currently available and their value depends on the circumstances of the individual investor. You acknowledge that levels and bases of taxation may change, and that Levendi Investment Management Limited does not provides tax advice. You should consult your own tax advisor in order to understand the tax consequences of the products and services described in the website.

Privacy and Data Protection

All information or data sent to Levendi Investment Management Limited via this site, by email or in any other way connected with consulting this site will be handled in accordance with statutory and regulatory requirements. As a visitor to, or person using, this site, you hereby agree Levendi Investment Management Limited and its relevant associated entities may record, retain and process any personal data that relates to you for the following purposes: the management of Levendi Investment Management Limited clients, including new business prospects, management of the contractual relationship, the prevention of irregularities, generating statistics and tests and for marketing purposes for relevant financial products and services. Levendi Investment Management Limited may ask you to provide your name and personal contact details if you wish to access tools and models via this site. Access to personal data gathered via this site is restricted to those persons who require this data in order to carry out their duties. You also agree that this data may be passed on to all entities associated with Levendi Investment Management Limited for the same purposes or to other persons in order to comply with any statutory obligation or in the event of legal interests. You also agree with such notification should the receiving person or entity be located outside the European Union, regardless of whether an adequate level of protection can be guaranteed for personal data in the country of receipt.

Copyright

The copyright and all other rights in all of the material on this website are owned by Levendi Investment Management Limited or the material is included with the permission of the rights owner. The information contained in this website is intended solely for the use of the person who has accessed this information and may not be reproduced, distributed or published to any other person. You may copy material on this website for your own private or domestic use only. All other copying is prohibited.

Links to other websites

On this website you may be offered automatic links to other non-Levendi Investment Management Limited websites. These links are provided only as convenience. Levendi Investment Management Limited does not accept any responsibility for the content of those websites or your use or inability to use such websites, the owners of which do not necessarily have any link, commercial or otherwise, with Levendi Investment Management Limited. The inclusion of any link does not imply affiliation, sponsorship, endorsement, verification or monitoring or approval by Levendi Investment Management Limited of any information contained in any non-Levendi Investment Management Limited website. You should also be aware that the terms and conditions of such website and the website’s statement relating to the collection and use of your personal information may be different from those applicable to your use of this website.

Disclaimer

It is the responsibility of the individual user to consider his or her legal and regulatory position in the relevant jurisdiction, the risks associated with trading such products and to ensure that the use of the content and the subsequent making of any investment does not contravene any such restrictions or applicable laws and regulations of any jurisdiction. Please seek the advice of professionals, as appropriate, regarding the evaluation of any specific security, index, report, opinion, advice or other content. This does not exclude or restrict any duty or liability that Levendi Investment Management Limited has to its clients under the Financial Services and Markets Act 2000 (as amended from time to time) or any other regulatory system under the laws of applicable jurisdictions.

Levendi Investment Management Limited, its subsidiaries, associated entities, directors, employees, representatives or suppliers will not be liable, on any grounds whatsoever, contractually or not, for any direct or indirect damage that may arise as the result of it being possible or impossible to gain access to this site, the accessing, visiting or use of this site and/or the information provided, the sending, or receiving of information via this site and/or the operation or non-operation of this site, except in the event of intentional or serious blame on its part. The information contained on this site, including any third party data is published in good faith and Levendi Investment Management Limited believes that the information is accurate at the time of publication but no representation or warranty, express or implied, is made by Levendi Investment Management Limited as to its accuracy or completeness and it should not be relied on as such.

Levendi Investment Management Limited shall therefore have no liability, save for any liability that Levendi Investment Management Limited may have under the UK Financial Services and Markets Act 2000, for any loss or damage arising out of the use or reliance on the information provided including without limitation, any loss of profit or any other damage, direct or consequential. Nor will Levendi Investment Management Limited, its subsidiaries, associated entities, directors, employees, representatives or suppliers be, under any circumstances, liable for any corruption of data that may occur as the result of technical problems (e.g. transmission errors, technical failures, breakdowns, intervention of third parties, etc.) and/or for any damage or loss relating to software or hardware that is the result of any virus, defect or malfunction in relation to access or use of the site.

I certify that I am not a US person. Levendi Investment Management Limited is not registered as an investment advisor with the SEC and therefore this website is neither directed at nor intended for US investors.

Privacy

The purpose of this privacy statement is to explain to you Levendi Investment Management Limited Limited policy with regards to the handling of personal data supplied by you to Levendi Investment Management Limited during the process of using this website.

Our data protection and privacy statement wording is required as a result of data protection laws arising pursuant to a European Union data protection directive. Businesses in European Union countries must comply with national laws enacted in light of their country’s interpretation of the European Union data protection legislation. The legislation seeks to ensure that all personal information held by businesses and organizations is both accurate and suitably protected in order to ensure there is no mis-use of personal data relating to an individual held by the business or organization. Levendi Investment Management Limited intends to process your data by complying with relevant legislation.

Levendi Investment Management Limited kindly requests that you read the privacy statement below which has been included with a view to protecting your personal data.

This website is provided by Levendi Investment Management Limited. When visiting this website and in the course of providing services to you, Levendi Investment Management Limited (“we”, “us” or “our”) may collect personal information about you (“personal data”) either (i) directly when you are asked to provide data (e.g., name, e-mail address and mailing address) or when you email, phone or otherwise contact us; or (ii) indirectly, e.g. via cookies and other technical means to monitor your use of the portal such as access logs, your internet protocol address or profiling to tailor the website to your preferences or to track your use of certain pages of the website, or from third parties who provide us with information about you.

“You” or “your”, in this privacy statement, means you as an individual, rather than any legal entity (such as your employer) which you may represent when you order a service from us via this website.

We may process personal data collected via this website or otherwise for the purposes of administering the website, responding to queries or provide services to you at your request, updating our records and databases, improving the personalization of our services to you, maintaining contact data about you or a third party (for example, your employer), informing you, or enabling third parties to inform you, of features, services, products, fund launches and related information from Levendi Investment Management Limited or third parties which may be of interest to you and otherwise to enable us to perform any agreement with you, your employer or any other relevant third party.

You may be able to update some of the data we hold about you or third parties directly yourself. If you are acting as an intermediary or otherwise on behalf of a third party or supply us with information regarding a third party (such as your employer or a client company), you undertake that you are an authorised representative or agent of such third party and that you have obtained all necessary consents from such third party to the collection, processing, use and disclosure by us of their personal data.

The data may, for these purposes, be disclosed to certain types of staff within Levendi Investment Management Limited’s organization (i.e., staff whose job it is to process your enquiries and orders or otherwise to administer the website, and those staff involved in the provision of Levendi Investment Management Limited services and products which may be of interest to you). Personal data may also be disclosed to a limited number of third parties, such as third party marketing companies to send you information which may be of interest, data processors, suppliers or providers of goods or services.

We have adopted generally accepted standards of technology and operational security in order to protect the confidentiality and security of personal data collected via this website but the nature of the internet is of course such that the data may flow over networks without appropriate security measures and may be accessed and used by unauthorised persons.

Please note that this privacy statement only covers this website and does not regulate the privacy practices of other websites which may be accessible through or linked to this website.

We do not generally seek to collect data about your racial or ethnic origin, political opinions, religious or other similar beliefs, trade union membership, physical or mental health, sexual life, criminal record or alleged criminal activity through the website (“sensitive personal data”). We may collect some sensitive personal data incidentally. By providing us with unsolicited sensitive personal data you consent to our using those data for the above purposes.

Cookies

About cookies

Our website uses cookies. You consent to our use of cookies in accordance with the terms of this policy.

Cookies consist of small files, often including unique identifiers, that are sent by web servers to web browsers, and which may then be sent back to the server each time the browser requests a page from the server.

Cookies can be used by web servers to identity and track users as they navigate different pages on a website and to identify users returning to a website.

Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies on this website

We use both session cookies and persistent cookies on this website.

How we use cookies

Cookies do not contain any information that personally identifies you, but personal information that we store about you may be linked, by us, to the information stored in and obtained from cookies.

We may use the information we obtain from your use of our cookies for the following purposes:

to recognise your computer when you visit our website;
to track you as you navigate our website, and to enable the use of the some of the features on our website;
to improve the website’s usability;
to analyse the use of our website;
in the administration of this website;
to personalise content on our website for you.

Third party cookies

When you use our website, you may also be sent third party cookies. We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google’s privacy policy is available at: http://www.google.com/privacypolicy.html.

Blocking cookies

Most browsers allow you to refuse to accept cookies. For example:

in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector;

in Firefox you can block all cookies by clicking “Tools”, “Options”, and un-checking “Accept cookies from sites” in the “Privacy” box.

Blocking all cookies will, however, have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use many of the features of this website.

Deleting cookies

You can also delete cookies already stored on your computer. The method of doing so will depend upon your web browser.

We will not be liable for any loss or damage arising out of or in connection with the use of this site.

(1) I HAVE READ UNDERSTOOD AND ACCEPT THIS DISCLAIMER AND

(2) I CONFIRM THAT I AM NOT A RESIDENT OF THE UNITED STATES AND UNDERSTAND (A) THAT THE INFORMATION THAT FOLLOWS IS ONLY BEING OFFERED TO AND IS ONLY INTENDED TO BE AVAILABLE TO PERSONS WHO ARE NOT RESIDENTS OF THE UNITED STATES AND (B) THAT CET AND ITS AFFILIATES WILL RELY ON THE ACCURACY OF THIS INFORMATION

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