1. BACKGROUND
This Privacy Policy explains how we use the personal information that Schroders (as defined below) collects or generates in relation to its Marketing Preference Centre at www.schroders.com/en/uk (the “Preference Centre”).
“Schroders”, “we or “us” means Schroders plc of 31 Gresham Street, London, EC2V 7QA (Company number 03909886) or any of its subsidiaries, affiliates, managed syndicates and other companies in the Schroders group (together the “Schroders Group”), details of which can be found on the Schroders website (www.schroders.com).
We collect and use certain personal data via the Preference Centre and we are responsible for ensuring that we use that personal data in compliance with data protection laws. This Privacy Policy governs the handling of personal data by Schroders in the course of operating the Preference Centre.
2. THE TYPES OF PERSONAL DATA WE COLLECT
When you visit the Preference Centre, we may collect and process the following personal data about you:
- Information that you provide to Schroders. Such information may include details of your marketing preferences (i.e. the marketing materials that you would like to receive from the Schroders Group and/or its third party business partners).
- Information that we collect or generate about you. When you submit information via the Preference Centre, we may use this information to help build a better picture of the topics and materials that interest you or may interest you, and the ways in which you would like to receive them.
- Cookies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. The Preference Centre uses “strictly necessary” cookies. These are cookies that are required for the operation of the Preference Centre. You can choose not to accept certain cookies by turning this feature off within your browser settings, however doing this may detract from your user experience and your ability to properly use the Preference Centre.
3. HOW WE USE YOUR INFORMATION
Your personal data may be stored and processed by us in the following ways and for the following purposes:
- to understand your marketing preferences and keep them up to date;
- to communicate with you in order to provide you with information about Schroders and the products and services offered by Schroders Group that might be of interest to you;
- for the administration and maintenance of databases storing your marketing preferences.
However we use personal data we make sure that the usage complies with law. The use of your personal data as described in this Privacy Policy is permitted because:
- it is necessary for our legitimate business interests, because it allows us to:
- keep a record of what our contacts are interested in hearing about and how they would like to hear about it;
- ensure that we only send our contacts marketing materials that they would like to receive and that may be of interest to them; and
- conduct more effective business development and marketing activities;
you may have consented for us to use your personal data to send you certain marketing materials when you submit your marketing preferences to us via the Preference Centre.
We will take steps to ensure that the personal data is accessed only by employees of Schroders that have a need to do so for the purposes described in this Privacy Policy.
4. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
We may share your personal data within the Schroders Group for the purposes described above.
We may also share your personal data outside of the Schroders Group as further described below:
- with our business partners whose products and services you have indicated that you would be interested in hearing about;
- with third party service providers for the purposes of providing services to us that enable or support our fulfilment of the purposes described in this Privacy Policy (for example, Schroders’ IT and communications providers). These third parties will be subject to appropriate data protection obligations;
- to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation, or to establish, exercise or defend our legal rights;
- if we sell our business or assets, in which case we may need to disclose your personal data to the prospective buyer for due diligence purposes; and
- if we are acquired by a third party, in which case the personal data held by us about you will be disclosed to the third party buyer.
5. INTERNATIONAL TRANSFERS OF PERSONAL DATA
Schroders is a global business. Our customers and our operations are spread around the world. As a result we collect and transfer personal data on a global basis. That means that we may transfer your personal data to locations outside of your country.
Where we transfer your personal data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of the EEA, for example, this may be done in one of the following ways:
- the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for personal data;
- the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data;
- where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
- in other circumstances the law may permit us to transfer your personal data outside Europe.
You can obtain more details of the protection given to your personal data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us as described in paragraph 12 below.
6. HOW LONG WE KEEP YOUR PERSONAL DATA
How long we will hold your personal data for will vary and will be determined by the following criteria:
- the purpose for which we are using it (as further described in this policy) – we will need to keep the data for as long as is necessary for that purpose; and
- legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data
7. YOUR RIGHTS
In all the above cases in which we collect, use or store your personal data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:
- the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
- the right to withdraw your consent to the processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so;
- in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided directly to Schroders;
- the right to request that we rectify your personal data if it is inaccurate or incomplete;
- the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
- the right to object to, or request that we restrict, our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to refuse that request; and
- the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
You can exercise your rights by contacting us using the details provided at clause 11 below.
8. OTHER WEBSITES
If you follow a link to another website (including a website operated by Schroders), different privacy policies may apply. You should read these policies before you submit any personal data to these websites and agree that use of your personal data by those websites will be subject to those privacy policies
9. CHANGES TO THIS PRIVACY POLICY
Any changes we make to our Privacy Policy in the future will be posted on this page and where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.
10. QUESTIONS AND CONCERNS
If you have any questions or concerns about Schroders’ handling of your personal data, or about this Privacy Policy, please contact us using the following contact information:
Address: Schroder Investment Management Limited.
31 Gresham Street, London, EC2V 7QA
Registered in England, Register Number 1893220.
Email Address: webmaster@schroders.com
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive, you may escalate concerns to the applicable data protection regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulator.
