At Aberdeen Asset Management PLC and all of its affiliates (hereinafter referred to as “Aberdeen”, “we” or “us”) aim to protect the privacy of every current, former and prospective client as far as possible. This Privacy and Cookies Policy (the “Policy”) describes the type of personal information we may collect, the purposes for which we use the information, the circumstances in which we may share the information and the steps we take to safeguard the information to protect your privacy.
1. The personal information we collect and how we use it
We may collect information about you and use it in the following ways:
- We may collect personal information about you from applications or forms you may complete, agreements you enter into with us or in the course of your establishing or maintaining a client relationship with us regarding an investment product or vehicle including your name, postal and email address, debit card details, ongoing statements and other related information. This is to allow us to complete your transaction and also to provide confirmation of the transaction to you.
- When you browse the website we will store information as to how you use the website in order to improve the quality of service provided to you. For example, it will allow us to decide the most appropriate site layout and navigation.
- We may collect information concerning the attachments you open with newsletters that are sent to you electronically.
- We also use the information we collect in order to inform you about changes to the website and, subject to any applicable local laws, other information that we think may be of interest and/or useful to you including our products and services.
Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in us not being able to provide services offered by Aberdeen to you.
2. Who we disclose the personal information to
Aberdeen does not disclose your personal information to third parties, except as described in this Policy.
Third party disclosures may include sharing such information with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to Aberdeen. These companies are required to ensure appropriate security measures are in place and maintain the confidentiality of such information to the extent they receive it, and to use your personal information only in the course of providing such services and only for the purposes that Aberdeen dictates.
These non-affiliated companies, however, may be based in countries where privacy laws do not exist or provide less protection than the laws in the EU.
We may also disclose your personal information to fulfil your instructions or pursuant to your express consent.
Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations, for instance, when responding to proceedings of a court of law or similar legal process, to protect against fraud, and to otherwise cooperate with law enforcement or regulatory authorities.
You should know that Aberdeen does not sell your personal information.
3. Accessing and updating your personal information
You have the right to access your personal information at any time to check whether it is accurate and up-to-date and should contact our Data Protection Officer on email@example.com. if you wish to do so.
4. Timely processing of the information
We will retain your personal information in accordance with applicable laws for so long as it is needed.
5. Cookies Policy
(a) What cookies Aberdeen use and why
Cookies are small text files, which often include a unique identifier that is sent by a web server to your computer, mobile phone or any other internet enabled device (“device”) when you visit a website. Cookies are widely used in order to make websites work efficiently and help provide us with business and marketing information to enable us to make informed decisions on the development of our websites.
We use three main types of cookies
These help us see how you use our website e.g. which pages you visit. These cookies don't collect any information that could identify you – all the information collected is anonymous and is only used to help us improve the performance of our website, understand what interests our users and measure how effective our advertising is.
We use performance cookies to:
- analyse the performance of our website
- help us improve the website by measuring any errors that occur
- see how effective our adverts are (this isn’t shared with 3rd parties).
Sometimes cookies are managed for us by third parties, but we don't allow the third party to use the cookies for any purpose other than those listed above.
By using our site you accept the use of 'Performance' cookies.
These are used to help us customise website content based upon your selections.
We use identification cookies to:
- remember choices you have made such as identifying yourself as an IFA or Adviser
- show you when you're logged in to the website.
- target you with adverts on other websites
You can control whether or not these cookies are used, but preventing them may mean you are unable to access certain features or services. Preventing these cookies may stop us remembering that you didn't want a specific feature or service.
By using our site you accept the use of 'Identification' cookies.
These are used to send you relevant information and see which content you use.
We use targeting cookies to:
- send you customised news content via email
- track which content you use.
- target you with adverts on other websites
By using our site you accept the use of 'Targeting' cookies.
(b) Third party cookies
The site also has Social Interaction links (such as Facebook or Youtube). Aberdeen do not control any cookies that may be sent when using these external websites. For more information on these it is advised to check their cookie policies.
(c) How to withdraw consent to, control and/or delete cookies
It is possible to remove cookies or block them from recording this information. This is generally found within the Options menu then Privacy section of your particular browser. Each browser is slightly different and constantly updating. For more information consult the Help menu for your browser.
This information has been provided to show our commitment to legislation regarding cookie awareness so that you can understand what cookies we use and why we use them. This ensures transparency in the data collected on you.
Information about cookies
Internet Advertising Bureau
A guide to behavioural advertising and online privacy
International Chamber of Commerce United Kingdom
Information on the ICC (UK) cookie guide
6. Privacy and the Internet
Aberdeen is committed to ensuring that your personal information is secure. In order to prevent unauthorised access or disclosure, we have in place appropriate physical, electronic and managerial procedures to protect and secure your personal information.
(a) How we secure information transferring to our web server
All forms containing sensitive personal information, such as payment or bank details, are transmitted, after we authenticate your details, to the web server using a 'secure form' in which your details are encrypted using the most secure encryption level available.
You should notify us immediately if you have any reason to suspect that someone else may be using your details.
An encryption certificate can be viewed by double clicking on the padlock icon displayed within the web browser window when you are on a secure page.
(b) How we hold your personal information on our web server
In most cases your personal information is passed immediately to our customer service centre without any personal information being stored on the web server at all.
Where it is necessary to store personal information temporarily, any sensitive personal information is securely encrypted and stored away from publicly-accessible areas of our web server.
(c) How we transmit your personal information to our customer service centre
Once we have received your personal information, the web server, located in a secure area of the network, immediately passes your personal information through an additional firewall into an application server and onto a server to allow us to execute your order within the customer service centre. The personal information is itself protected so that only authorised staff can access the personal information.
7. Personal information and marketing purposes
If you want Aberdeen to not use or cease using your personal information for marketing purposes, please contact our Data Protection Officer on firstname.lastname@example.org.
8. Changes to the Policy
Please be aware that this Policy may be updated at any time. As such, please ensure that you regularly read the latest version of this page.
If you have any questions or complaints relating to the Policy or how we use the personal information we have about you, please contact our Data Protection Officer on email@example.com. who will try to respond to you promptly.
A cookie is information that a web server stores on your hard disk so that it allows a web site to store your preferences on your machine and later retrieve it.
An IP address is a 32-binary digit number that identifies each sender or receiver of information that is sent in packets across the Internet.
A session is a series of interactions between two communication end points that occur during the span of a single connection and is related to a particular session number.