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Wadhwani Asset Management LLP

Privacy

Privacy Notice

Wadhwani Asset Management LLP (“Wadhwani”, “we”, “us” and “our”) are committed to respecting your privacy.

We are registered in the UK and our registered address is at 9th Floor, Orion House, 5 Upper St Martin’s Lane, London WC2H 9EA and our company registration number is OC303168.

About this privacy notice

For the purposes of data protection law, we are a data controller in respect of your personal data. Wadhwani is responsible for ensuring that it uses your personal data in compliance with data protection law.

This privacy notice applies if you are a customer or client; supplier; professional advisers and consultants; a visitor to our website or an employee; or a director, officer or representative of another organisation with which we have a business relationship.

This privacy notice sets out the basis on which any personal data about you that you provide to us, that we create, or that we obtain about you from other sources, will be processed by us. Please take the time to read and understand this privacy notice.

Personal data that we collect about you

We will collect and process the following personal data about you:

  • Information that you provide to us or one of our affiliates. This includes information about you that you give us by filling in forms, registering on our website, completing surveys we use for research purposes or by communicating with us, whether face-to-face, by phone, e-mail or otherwise. This information may include (by way of a non-exhaustive list):
    • basic personal data (such as first name; family name; email address; phone number; address (including city postcode and country); occupation and job title;;
  • Information we collect or generate about you.This includes (by way of a non-exhaustive list):
    • information about your browsing actions and patterns on our website which may be collected through the use of “cookies”, “IP addresses” or other numeric codes used to identify your computer
    • files that we may produce as a record of our relationship with you, including contact history; and
    • any personal data that you provide during telephone and email communications with us which we may monitor and record in order to resolve complaints, improve our service and in order to comply with our legal and regulatory requirements.
  • Information we obtain from other sources. This includes (by way of a non-exhaustive list):
    • information from publicly available sources (including third party agencies such as credit reference agencies; fraud prevention agencies; law enforcement agencies; public databases, registers and records such as Companies House and the FCA Register; and other publicly accessible sources);
    • information obtained from professional advisers, product providers, events organisers, and other agents and/or representatives; and
    • information obtained from sanctions checking and background screening providers

Uses of your personal data

Your personal data may be stored and processed by using the following ways and for the following purposes:

  • for ongoing review and improvement of the information provided on our website, the services that we provide through it and the way that content is presented;
  • to determine your suitability to be granted access to the secure section of our website when you register to access it;
  • for research purposes and to identify opportunities and Wadhwani events that may be of interest to you;
  • to allow for use and access to our products and services to keep our records up to date;
  • to monitor IT systems in order to protect against cyber threats or malicious activity including abuse and misuse;
  • to administer or maintain IT systems in order to uphold standards of service;
  • to understand feedback on our products and services and to help provide more information on the use of those products and services quickly and easily;
  • to communicate with you in order to provide services or information about other Wadhwani products and services;
  • for the management and administration of our business;
  • in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or
  • for the administration and maintenance of databases storing your personal data.

When we use your personal data, we make sure that such usage complies with applicable law. The law allows or requires us to use your personal data for a variety of reasons. These include instances where:

  • we are performing our contractual obligations;
  • we have legal and regulatory obligations that we have to discharge;
  • we may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or
  • the use of your personal data as described is necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates), such as:
    •  allowing us to effectively and efficiently manage and administer the operation of our business;
    • maintaining compliance with internal policies and procedures;
    • enabling quick and easy access to information on Wadhwani’s products and services.

Disclosure of your information to third parties

We may disclose your personal data to our affiliates for the purposes described above. We will take steps to ensure that the personal data is accessed only by employees of such affiliates that have a need to do so for the purposes described in this notice.

We may also share your personal data outside of Wadhwani and our affiliates:

  • with our business partners who are contractually obliged to comply with appropriate data protection obligations
  • if we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes;
  • if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer;
  • to third party agents or contractors (for example, administrators, Wadhwani’s accountants, professional advisors, IT and communications providers, background screening providers, credit reference agencies and debt collectors) for the purposes of providing services to us. These third parties will be subject to confidentiality requirements and appropriate data protection obligations; and
  • 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, establish, exercise or defend our legal rights.

Transfers of personal data outside the European Economic Area

The personal data that we collect from 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 of the EEA who work for our affiliates or for one of our suppliers.

Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA. This can be done in a number of ways, for instance:

  • the country that we send the data to might be approved by the European Commission;
  • 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; or
  • where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme.

In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA. In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Contacting us” section below.

Retention of personal data

How long we hold your personal data for will vary. The retention period will be determined by various criteria including:

  • the purpose for which we are using it – 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.

Your rights

You have a number of legal rights in relation to the personal data that we hold about you. 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 our 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 (other than consent) 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 to us;
  • 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, and the right to 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 continue processing your personal data and / or to refuse that request; and
  • the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details set out in the “Contacting us” section below.

You can find out more information about your rights by contacting the Information Commissioner’s Office, or by searching their website at https://ico.org.uk/.

Contacting us

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions, comments and requests to:

Compliance Department
Wadhwani Asset Management
9th Floor Orion House
5 Upper St. Martins Lane
London WC2H 9EA

Authorised and Regulated by the Financial Conduct Authority