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Privacy Policy

Last updated: October 2022

TwentyFour Asset Management LLP (“TwentyFour”) respects your right to privacy. This Privacy Notice explains how we collect, share and use personal data about you, and how you can exercise your privacy rights.

The Privacy Notice applies to the processing of personal data when you visit our website at twentyfouram.com, when you sign up to an account, when you visit our offices, register for events, fill out surveys or other promotional activity, or when you correspondence with us or interact with us on social media platforms including not limited to Twitter and LinkedIn. You should read this Privacy Notice carefully so that you are fully aware of how and why we are using your personal information.

If you have any questions or concerns about our use of your personal data, then please contact us using the contact details provided at the bottom of this Privacy Notice.

What personal data does TwentyFour collect and why?

The personal data that we may collect about you generally falls into the following categories:

Information that you provide voluntarily

Purpose Data types Legal basis
Provide access to customer section of the website. 

Name, contact details (e.g. business mailing address, phone number, current and prospect e-mail address).

Employment details (e.g., your employer, job title), account details (e.g. login names, passwords), and public postings

Contractual necessity
To respond to any enquiries, provide product or service updates Name, contact details (e.g. mailing address, phone number, current and prospect e-mail address)

Contractual necessity

Legitimate interest

To provide promotional activities Name, contact details (e.g. mailing address, phone number, current and prospect e-mail address)

Consent

Legitimate interest

Liaise with you and maintain a correspondence record.

Name, contact details (e.g. mailing address, phone number, current and prospect e-mail address).

Employment details (e.g., your employer, job title)

Legitimate interest
Website activity information including how your device interacted with our website to provide customers with superior service and to provide all visitors a smooth, efficient, and personalized experience while using our website. We use this information for our internal analytics purposes and to improve the content of our website and to make our website easier to use. Language and geographic location, website visits, time and activity, browser-type information from your device through cookies (see our cookie notice

Legitimate interest

Consent

Ensure the security of our premises and website

Visitor logs for our premises

Device information as outlined above

Legitimate interest

Certain parts of our website may ask you to provide personal data voluntarily which include your name and contact details (e.g. mailing address, phone number, current and prospect e-mail address), employment details (e.g., your employer, job title), account details (e.g. login names, passwords), and public postings,. We may ask you provide personal data voluntarily when you subscribe for a product or service, subscribe for certain promotional activities, fill out surveys, and correspond with us.

From time to time, we may receive personal information about you from third party sources (including event sponsors or individuals who have asked us on your behalf) to provide information to you), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

Who does TwentyFour share my personal data with?

We may disclose your personal data to the following categories of recipients:

  • to our group companies (including Vontobel entities), third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our website), or who otherwise process personal data for purposes that are described in this Privacy Notice or notified to you when we collect your personal data;
  • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
  • to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Privacy Notice;
  • to any other person with your consent to the disclosure.

Where personal data is shared we will have appropriate contractual arrangements in place to protect any such data – in line with applicable data protection laws and regulation. We do not sell, trade, or rent to others the personal data we collect online.

Legal basis for processing personal data

Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it.

However, we will normally collect personal data from you only (i) where we need the personal data to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so.  In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another person.

If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data).

If we collect and use your personal data in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our platform and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform or undertaking marketing. We may have other legitimate interests and if appropriate, we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided under the “How to contact us” heading below.

Your data protection rights

You may have the following data protection rights:

  • If you wish to access, correct, update or request deletion of your personal data, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.

  • In addition, you can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.

  • You have the right to opt-out of marketing communications we send you at any time. In addition, you can manage your preferences at any time. You can exercise these right by clicking on the “unsubscribe” or “preferences” link in the marketing e-mails we send you or contact us using the contact details provided under the “How to contact us” heading below.

  • Similarly, if we have collected and process your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.

  • You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Cookies and similar tracking technology

A “cookie” is a small data file transferred by a website to your computer’s hard drive. We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal data about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice here.

How does TwentyFour keep my personal data secure?

We use appropriate technical and organisational measures to protect the personal data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data.

International data transfers

Your personal data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country. These countries may have data protection laws that are different to the laws of your country. If service providers in a third country are used, they are obligated to comply with the data protection levels in the UK and Europe in addition to written instructions by agreement to the EU standard contractual clauses.

The information you provide may be processed and stored on cloud servers operated by the service providers and located in data centres within the UK, Switzerland, the EU/EEA and the United States. This means that when we collect your personal data we may process it in any of these countries. The European Commission and the UK Secretary of State considers New Zealand to have an adequate level of protection for personal data [1] .

However, we have taken appropriate safeguards to require that your personal data will remain protected in accordance with this Privacy Notice.

Data retention

We retain personal data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

Links to other websites and third parties

The website may link you to third party website including Twitter and LinkedIn. These third party websites will have their own data protection practices. We recommend that you review their respective privacy notices before accessing the third party links.

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will post those changes here so that you will always know what information we collect online, how we use it, and what rights you have. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.  

You can see when this Privacy Notice was lasted updated by checking the "last updated" date displayed at the top of this Privacy Notice. 

How to contact us

If you have any questions or concerns about our use of your personal data, please contact us at privacy@twentyfouram.com .

The data controller of your personal data is TwentyFour Asset Management LLP, The Monument Building, 11 Monument Street, London EC3R 8AF.

Cookie Notice

Last updated: October 2022

This Cookie Notice explains how TwentyFour Asset Management ("TwentyFour") uses cookies and similar technologies on our website. It explains what these technologies are and why we use them as well as your rights to control the use of them.

Some cookies or similar technologies will collect personal information about you, or information that becomes personal information if we combine it with other data. Any personal information that we collect will be used in accordance with our Privacy Notice.

What are cookies?

A “cookie” is a small data file transferred by a website to your computer’s or device's hard drive. We send cookies when you surf our website, submit a form, or request information. The aggregate information collected permits us to analyse traffic patterns on our Site. This can enable us over time to provide you with a better experience on our website by improving the content and making it easier to use.  These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our website. Cookies may also be set by third parties. 

Our use of cookies

Our Website uses cookies for several reasons including to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our site. Some cookies are required for technical reasons that are strictly necessary for our Website to operate, and we refer to these as "essential" cookies. Other cookies also enable us to provide Website functionality, or to enhance visitors' experience on our Website by providing them with personalised content and advertising. This is described in more detail below.

The specific types of first and third party cookies served through our Website and the purposes they perform are described below.

Strictly necessary cookies

TwentyFour

SERVERID utag_main SERVERID

These cookies are used to identify the last page to the browser, and enforce any consent preferences. These cookies cannot be disabled as otherwise our website cannot be provided.

These cookies are essential in order to enable you to move around our website and use its feature. Without these cookies certain features could not be provided.

Performance cookies

The cookies we use are “analytical” cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. You can find more information about the individual analytical cookies we use and the purposes for which we use them in the list below:

Application Cookies Use Retention
TwentyFour

_gid

_ga

Web analysis  
Nr-data.net JSESSIONID Authentication & session handling  
Google Analytics

_utma

_utmb

_utmc

_utmz

These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Further information on Google Analytics and its cookies can be found

Targeting cookies

These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Application Cookies Use Retention
Pardot pardot, visitor_id, visitor_id#####, visitor_id#####-hash These cookies are used to collect information about how visitors use our site. 10 years
LinkedIn bscookie, lang, lidc, UserMatchHistory, AnalyticsSyncHistory, li_gc, _guid, li_mc, liap, lidc, lms_ads, lms_analytics Online advertising 1 month
ads.linkedin.com lang Online advertising End of session
Oktopost   Online advertising  
Nr-data.net JSESSIONID Authentication & session handling  
Doubleclick _gat Online advertising End of session

Functional cookies

These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages.  If you do not allow these cookies then some or all of these services may not function properly.

Application Cookies Use Retention
Website JSESSIONID, SSESS*, visitor_id*-hash Authentication & session handling End of session, up to two hours
Website unsafeSessionId Authentication & session handling 1 year
Website SERVERID This cookie is used to assign the user to a specific server, thus to provide a improved and faster server time. It remembers which server had delivered the last page on to the browser. It also helps in load balancing End of session, up to two hours
Website detected_lang Investor profile End of session, up to 90 days
Website investorType Investor profile 1 year
Website country, countryCurrency, disclosure_accepted_domain_id, disclosure_effective_date Investor profile 18 months
Website nr-data.net Used by sites written in JSP. General purpose platform session cookies that are used to maintain users' state across page requests. End of session, up to two hours
Tealium iQ utag_main Session handling 1 year
Tealium iQ CONSENTMGR GDPR consent management 90 days
Vimeo _cf_bm Video streaming 30 minutes
Vimeo _ga Video streaming 2 years
Vimeo language Video streaming 10 years
Vimeo player, vimeo_cart, vimeo, gdpr_optin Video streaming 1 year
Vimeo vuid Video streaming 2 years 10 months
Vimeo vimeo Video streaming 1 month
Buto   Video streaming  

Other tracking technologies

Cookies are not the only way to recognise or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called "tracking pixels" or "clear gifs"). These are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our website. This allows us, for example, to monitor the traffic patterns of users from one page within our website to another, to deliver or communicate with cookies, to understand whether you have come to our website from an online advertisement displayed on a third-party website, to improve site performance. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will often impair their functioning

How to control cookies

You have the right to decide whether to accept or reject any cookies which are not strictly necessary. You can accept or reject cookies directly through our cookie banner and you can manage your cookie preferences by following this link to our cookie preference centre.

You can also block cookies by using the settings on your browser. You can also delete cookies on your computer or mobile device using the feature for doing so in your browser.

To enable or disable cookies in your browser:

Check which web browser you are using and then select the relevant link below. On the page you are taken to, you will find instructions on how to enable or disable cookies in your web browser:

Google Chrome

Firefox

Internet Explorer

Safari

If you choose not to accept our cookies, you will not be able to see certain information on our website or use some features that improve your visit.

Parts of our webite may contain links to third-party websites for your convenience and information. If you use these links, you will leave the TwentyFour Asset Management website. When you access a non TwentyFour Asset Management website, please understand that we do not control the content and are not responsible for the privacy practices of that site. We suggest that you carefully review the privacy policies of each site you visit. This Cookie Notice does not cover the information practices of those websites linked to our site. These other sites may send their own cookies to users, collect data, or solicit personal information

You can find out more information on the use of cookies at the following website: www.allaboutcookies.org. [1] This information is available on the ICO website and European Commission’s data protection website.

Updating this Cookie Notice

We may update this Cookie Notice from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons.  Please therefore re-visit this Cookie Notice regularly to stay informed about our use of cookies and related technologies.  

The date at the top of this Cookie Notice indicates when it was last updated.  

Contact us

If you have any questions about our use of cookies or other technologies, please contact us at privacy@twentyfouram.com.