Privacy Policy

Introduction

This Privacy Policy explains how we process your personal data, including how we collect, use and process your personal data, and how, in doing so, we comply with our legal and regulatory obligations. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

This Privacy Policy applies to the personal data of Investors or other Clients, Suppliers, website users and others whose personal data Montpelier Investment Management LLP (referred to as "Montpelier Investment Management LLP" or "us") may process. For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the "GDPR")), the entity responsible for your personal data is Montpelier Investment Management LLP at 243, Knightsbridge, London SW7 1DN, United Kingdom.

Please note that this Privacy Policy may be amended from time to time.

GDPR Principles

The following principles are complied with when processing personal data:

Data is processed fairly and lawfully
Data is processed only for specified and lawful purposes
Processed data is adequate, relevant and not excessive
Processed data is accurate and, where necessary, kept up to date
Data is not kept longer than necessary
Data is processed in accordance with an individual's consent and rights
Data is kept secure
Data is not transferred to countries outside of the European Economic Area (EEA) without adequate protection

Lawful Basis of Processing Data

The lawful basis of processing of data will always be determined prior to any data being processed. The applicable laws for processing personal data under the GDPR are as follows:

Consent – the individual has given their Consent to the processing of their personal data
Contractual – processing of personal data is necessary for the performance of a contract to which the individual is a party with Montpelier Investment Management LLP
Legal Obligation – processing of personal data is necessary for compliance with a legal or regulatory obligation to which Montpelier Investment Management LLP is subject
Legitimate Interests – processing of personal data is necessary under the Legitimate Interests of Montpelier Investment Management LLP or a Third Party, unless these interests are overridden by the individual’s interest or fundamental rights
Public Task – processing of personal data is necessary for the performance of a task carried out in the public interest or in the exercise of official authority
Vital Interests – processing of personal data is necessary to protect the vital interests of the individual or another individual

Montpelier Investment Management LLP processes personal data under one, or more, of the following Lawful Bases:

  • Consent
  • Contractual
  • Legal Obligation
  • Legitimate Interest

Type of Personal Data Being Processed

The type of personal data being processed will typically include:

Name
Address
Email Address
Job Title
Telephone Number
Business Name

How Personal Data is Collected

Personal data is obtained from one or more of the following:

Parties entering into agreements with Montpelier Investment Management LLP or the funds that it advises
Parties approaching Montpelier Investment Management LLP to enquire about potentially investing into the funds that it advises or other opportunities
Requests for information about products and services offered by Montpelier Investment Management LLP and Employment enquiries either at Montpelier Investment Management LLP itself or any of its affiliated companies including portfolio businesses

Why Personal Data is Collected

Personal data is collected to provide legitimate business services which include:

For Business purposes, for example investor reporting and fund administration
To meet statutory monitoring and reporting responsibilities
To improve Montpelier Investment Management LLP services and product offering

Where indicated, however, some of the information is optional and you can choose not to complete.

How Personal Data is Used

Personal data may be used to:

  • Process requests for further information, to maintain records and to provide ongoing service levels to investors and other stakeholders
  • Carry out our obligations arising from any contracts entered into by you and us
  • Comply with legal requirements including anti-money laundering checks
  • We may need to pass the information we collect to other companies within our Group for administrative purposes
  • We may use third parties to carry out certain activities, such as processing and sorting data, monitoring how customers use our site and issuing our emails for us
  • Notify you of changes to our services
  • Send you communications which you have requested or that may be of interest to you. These may include information about fund offerings and updates, newsletters and events
  • To inform you of various services that may be of interest to you. You may be contacted by post, email, telephone, SMS or such other means with carefully selected marketing communications we deem relevant to send to you in the legitimate interests of Montpelier Investment Management LLP.
  • Process a job application

Where Personal Data is Stored

Information collected is stored on the on the Company’s server.

As part of any services offered by Montpelier Investment Management LLP, information provided may be transferred to countries outside the European Economic Area (‘EEA’) i.e. our servers, or third-party servers that are used to provide Montpelier Investment Management LLP services located in a country outside the EEA. By submitting your data, you consent to the transfer, storage and/or processing of your data wherever it be stored. However, if your data is transferred outside the EEA, steps will be taken to ensure appropriate security measures are in place to ensure your privacy rights continue to be protected as outlined in this Policy.

Montpelier Investment Management LLP does not collect information about specific users of its website. It does however use Google analytics cookies which collect information in an anonymous form, including the number of visitors to the site, the IP address of the visitor, time zone, where visitors have come to the site from and the pages they visited. As with many websites, this information can be used to compile statistic reports of our users’ browsing patterns so that we can improve our website and enhance user experience of it. If you change your user settings so that Cookies are switched off then your previous browsing history will no longer be available to Montpelier Investment Management LLP.

How long Personal Data is Stored

We review our retention periods for personal data periodically. We are legally required to hold some types of information to fulfil our statutory obligations. We will hold personal data on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.

Who has Access to Personal Data

Only Montpelier Investment Management LLP employees are granted access to customer information. This is ensured by the use of strict operational processes and procedures.

Staff are trained on security systems and relevant processes and procedures which are reviewed regularly for ongoing effectiveness and suitability for purpose. All employees are kept up-to-date on the Montpelier Investment Management LLP security and privacy practices. Employees are notified and/or reminded about the importance we place on privacy, and what they can do to ensure that customer information is protected.

Non-sensitive details (your email address and other requested information) are transmitted normally over the Internet and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.

We will not sell or rent your information to third parties.

Third-Party Service Providers working on our behalf:

We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure.

Third-Party Product Providers we work in association with:

We work closely with various third-party service providers to ensure that the funds that we advise are professionally managed and administered. In some cases, they will be acting as a data controller of your information and, therefore, we advise you to read their Privacy Policy. These third-party product providers will share your information with us which we will use in accordance with this Privacy Policy.

We may also further transfer data if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to law enforcement. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

Individuals' Rights

Different rules apply depending on the type of Lawful Processing being undertaken. Many of the following individuals' rights apply, however, whatever the basis of processing:

The right to be informed how personal data is processed
The right of access to their personal data
The right to rectification
The right to erasure
The right to restrict processing
The right to data portability
The right to object
Rights in relation to automated decision making and profiling

The accuracy of personal data is imperative. We aim to keep it updated at all times. The personal data we hold on you is available upon request by contacting info@montpelier.com. You can request that your data is updated and/or deleted at any time, unless Montpelier Investment Management LLP can justify that it is retained for legitimate business or legal purpose. When updating your personal data, you may be asked to verify your identity before your request can be actioned.