This is the privacy notice of Winton Group Limited and each of its group companies, including Winton Capital Management Limited, Winton Fund Management Ireland DAC, Winton Capital US LLC, Winton Capital Asia Limited, Winton Capital Australia PTY Limited and Winton Investment Management (Shanghai) Limited. In this notice, “we”, “us” and “our” refers to the Winton company or companies that use your personal information.

This notice applies to you if:

• You are an individual who is a client of ours or an investor in a fund or other investment product that we manage or advise (a “Fund”).
• Your information has been provided to us or obtained by us in connection with a client of ours or an investor in a Fund (e.g. you are an employee, agent, director, officer, partner, trustee or direct or indirect owner (a “Representative”) of a client of ours or an investor in a Fund).
• You are an individual who is a potential client of ours or a potential investor in a Fund, or a Representative of a potential client of ours or a potential investor in a Fund.
• You contact us or our affiliates by email, telephone or any other means.
• You are a visitor to any website operated by us or our affiliates (a “Winton Website”).
• You are a Representative of a supplier, service provider, professional adviser, consultant or business partner of ours or a Fund (“Service Providers”).
• You are a director, officer or senior manager of a listed company in which we or a Fund may invest.

If you are a job candidate, please read our candidate privacy notice here.

This notice and any applicable agreement entered into by you and us sets out the basis on which we use your personal information. This notice discloses information required under the privacy laws that apply to us, including the European Union General Data Protection Regulation and the US law under Title V of the Gramm-Leach-Bliley Act of 1999. We are a data controller of your personal information.

Sources of personal information

We may use personal information that is:

• Provided by you via email, telephone, at meetings or as part of an application for interests in a Fund.
• Collected or generated in relation to an investment in a Fund by you or the person or entity you represent.
• Collected or generated in relation to services provided by us to you or the person or entity you represent.
• Collected or generated in relation to services provided to us by the entity you represent.
• Received from third parties such as the person or entity you represent, administrators of Funds, background check providers, public agencies and database or directory providers.
• Collected using cookies and other technologies when visiting a Winton Website.
• Obtained from public sources such as websites and regulatory filings.

Categories of personal information

We may use the following personal information:

• Personal details such as name, title, addresses, telephone numbers, email addresses, date of birth, gender, citizenship, signature, photographs and details about your employment and education.

• Financial details such as details of your investments, income and assets, bank accounts, tax residency and tax identification information.
• Correspondence, call recordings, website usage data, IP addresses and location data.
• Information related to know-your-client procedures such as results of background screening checks which may include information about your political opinions.

How we use personal information

Winton may use personal information to:

• Communicate with you and/or the person or entity you represent, and retain records of such communication.
• Conduct business development and marketing activities such as providing information about Funds and our services, research and events.
• Assess suitability for Funds and our services and carry out know-your-client procedures.
• Process and administer investments in Funds and our appointment to provide services.
• Carry out due diligence on Service Providers and administer Service Provider relationships.
• Make decisions related to the Funds, our services and our business strategy.
• Enter into contracts and perform contractual obligations.
• Meet any legal, regulatory or self-regulatory requirement that applies to us or our affiliates.
• Administer the Winton Websites and ensure that they are effectively presented for you and for your computer or device.
• Respond to enquiries and complaints.
• With respect to information about directors, officers and senior managers of listed companies in which we or the Funds may invest, for research and investment purposes.

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 purpose which 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 for such use.

Lawful basis

We can only use your personal information when the law allows us to (i.e. there is a “lawful basis for processing”). The lawful basis will be one or more of the following:

• Where we need to perform a contract that we have entered into with you.
• Where we need to comply with EU or EU member state law.
• Where it is necessary for our legitimate interests (or those of our affiliates or Service Providers) and your interests and fundamental rights do not override those interests. Depending on the type of personal information, these legitimate interests are: running day-to-day business operations; mitigating operational, financial, legal, tax, reputational, strategic, economic and other risks; ensuring that we remain a viable and competitive business; and complying with non-EU or non-EU member state law.
• In respect of any use of sensitive personal information, such as the political opinions of a politically exposed person, the use will be necessary for reasons of substantial public interest.

Sharing personal information

As a global business, we may share your personal information with our affiliates for the purposes set out above.

We may also share your personal information with third parties including:

• Marketing providers that assist with the delivery of information to you or the person or entity you represent.
• Service Providers for the performance of any contract we have entered into with you, the person or entity you represent or the Service Providers.
• Analytics providers that assist in the improvement of the Winton Websites.
• Administrators, other service providers and directors of Funds in connection with investments in a Fund (or applications for interests in a Fund) by you or the person or entity you represent.

We may also share your personal information with third parties if:

• We sell or buy any business or assets, when it may be necessary to share your personal information with the prospective seller or buyer.
• We are acquired by a third party, when your personal information will be one of the transferred assets.
• It is necessary to meet any legal, regulatory or self-regulatory requirement that applies to us or our affiliates.

Security

Your personal information is stored on secure servers and access to it is limited in accordance with our information security policies and procedures.

International transfers

Our affiliates and other third parties that receive your personal information may be based anywhere in the world, including countries outside the UK or the EU such as Australia, Hong Kong, India, Japan, The People’s Republic of China and the United States of America. Such countries may not be subject to a decision by the UK government or the European Commission that their laws provide an adequate level of protection for personal information. In such cases, we seek to ensure that your personal information receives an adequate level of protection, for example, by seeking to ensure that such transfers are subject to UK government or European Commission-approved standard data protection provisions or the transfer is subject to appropriate safeguards such as standard contractual clauses or an inter-governmental arrangement.

Retaining your personal information

How long we hold your personal information will vary. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of the information, the purposes for which we use the information, and applicable legal requirements. We may retain your personal information indefinitely to keep a reasonable record of our dealings with you and to ensure that we do not duplicate communications with you or contact you when you no longer wish us to do so.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Your rights

You have the following rights in respect of your personal information that we hold:

1. Access – you may request details of your personal information that we hold and a copy of such information.
2. Rectification – you may request that we correct or complete any of your personal information that is inaccurate or incomplete.
3. Erasure – you may request that we delete your personal information, although in some circumstances we may be legally entitled to retain it.
4. Restriction – you may object to, and request that we restrict, our use of your personal information in some circumstances, although in some circumstances we may be legally entitled to continue to use it or to refuse such request.
5. Direct marketing – you may request that we do not use your personal information to directly market to you.
6. Portability – in respect of information you have provided to us, you may in some circumstances request that we provide it in a structured commonly used and machine-readable format and that we transfer it to a third party where this is technically feasible.

If you exercise your rights of erasure or restriction or if you refuse to provide certain personal information, we may not be able to provide services to you or the person or entity you represent and you or the person or entity you represent may not be able to invest or continue to invest in a Fund.

You will not have to pay a fee to exercise any of these rights except that we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Changes to this notice

We may update this notice at any time, and we will post updates on the relevant Winton Websites. We may also notify you in other ways from time to time about our use of your personal information.

Third-party Links

Winton Websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave a Winton Website, we encourage you to read the privacy policy of every website you visit.

Contact and complaints

If you have any questions about this Notice or how we use your personal information, or if you wish to exercise any of your rights, please email privacy@winton.com.

You have the right to make a complaint at any time to the Information Commissioner's Office, the UK supervisory authority for data protection issues.