Who are we?

Edge Investments Limited and Edge Creative Capital Limited are registered under the data protection laws in the United Kingdom (and is subject to the European General Data Protection Regulation 2016/679).

Purpose of this policy

The privacy of every individual who visits our website is important to us and we have developed this privacy policy because we want you to feel confident about the privacy and security of your personal information. This policy explains what personal information we collect from you and how we process it in accordance with our regulatory obligations.

What is personal information?

Personal information means any information about you which is personally identifiable. This includes (but is not limited to) your name, age, telephone number, address, email address, genetic and biometric data, passport, location data, online identifies, such as your internet protocol (IP) address and any other information from which you can be either directly or indirectly identified.

What types of personal information about you do we collect from you?

We may collect the following information about you when you use our services:

Personal information: your name, date of birth, address, telephone number, email address, employment details, your representative’s personal information, IP address and unique device identifiers.

Sensitive/special categories of personal information: We may on occasion collect in the course of providing our service(s), sensitive or special category information, for example, information about your physical (e.g. hearing impairment) and mental health.

Financial information and work experience: information that may relate to your circumstances, for example, your bank account details, financial business plans, information about shareholders and curriculum vitae which may contain personal information.

Our basis for processing your personal information

We will process your personal information on the basis of our contract with you and for legitimate business purposes in order for us to provide you with the following:

1. investment management services in accordance with our obligations from any contracts entered into between you and us;
2.  to review your business plans;
3. to provide you with information about your portfolio;
4. for general administrative purposes, to notify you of important changes or updates to our services;
5. to allow you to complete forms to provide us with your personal information and communicate with us;
6. to comply with legal and regulatory obligations;
7. for the prevention and detection of fraud;
8. to protect your personal information through secure storage and backups;
9. for business analysis and research.

Content

We may be required to obtain your consent in order to:

• provide you with information about our products and services; through email or telephone;
• use your personal information for profiling;

In the event that we intend to process your personal information for any new purposes requiring your consent, we will contact you.

Who we may share your personal information with

The personal information we hold about you may be shared with the following having regard to any transfer, security and contractual safeguards as appropriate:

• our group affiliates; and
• third party relationships/agents.

The following categories of third party relationships/agents help us to provide our services and may only use your personal information to the extent necessary to provide their services:

• business partners;
• service providers: IT support services, archiving, auditing, product administration, business administration and support services;
• other companies in the event that we undergo a re-organisation or are sold to a third party;
• regulators and public authorities who have a legal right to requests and process your personal information;
• other companies in our group, where necessary, for management information purposes.

Furthermore, we may disclose your personal information if we are legally required to do, for example, by a court order or by law, if such action is necessary to prevent fraud or cybercrime.

Data retention and anonymisation

Where we have provided you with a service, we will retain your personal information for as long as is necessary for purposes described in this policy or in accordance our legal rights and obligations, for a maximum period of 7 years after the service has expired, after which your personal information will be deleted from our systems or anonymised in accordance with our data protection policy.

Once your personal information is anonymised, it will no longer be considered personal information since you will no longer be identified by it. We may continue to use anonymised information for business analysis, research and reporting purposes.

IP Address and Cookies

Our websites uses cookies to distinguish you from other users and to improve your experience on our website. When you visit our site we may collect additional information about you such as the type of internet browser or mobile device you use, any website from which you may have come from, your IP address and operating system, identified by our web server.

You can change your browser settings to prevent you from automatically accepting cookies or to notify you each time a cookie is set. Cookies may enable us to:

1. assess your usage pattern;
2. speed up your searches; and
3. recognise you when you return.

More information to explain the cookies we use and why can be found by clicking this link.

Safeguarding your personal information

We have security measures in place to protect against the loss, misuse and alteration of personal information we process. We will use strict procedures and security measures to try to prevent unauthorised access to your personal information. Whilst we cannot guarantee that loss, misuse or alteration will never occur, however, we use all reasonable efforts to prevent it.

Transfer of personal information outside the European Economic Area (EEA)

Your personal information is stored on secure servers located in the UK or countries located within the EEA. As a matter of policy, we do not transfer your personal information to organisations who may be outside the EEA in order to provide you with our products and services. In the event that we may have to transfer your personal information outside the EEA, we confirm that appropriate security measures will be in place to only share the minimum amount of personal information.

Your rights to your personal information

You have options and choices over how we use your personal information. You have the right to undertake the following:

• Request to see the personal information we hold on you.
• Request your personal information to be corrected or erased where appropriate.
• Restrict/object to the processing of your personal information whilst we investigate any concerns you may have.
• You may request to receive your personal information in a commonly used format or request that we send your personal information in that format to another data controller.
• Where we have obtained your consent, to withdraw it, to prevent us from processing certain activities at any time. For example, to send you marketing literature.
• Lodge a complaint to our Data Protection Supervisory Authority, the Information Commissioner’s Office: https://ico.org.uk/

Requests for your personal information shall be provided free of charge. However, where requests are repetitive, or manifestly unfounded or excessive, we may charge you a reasonable fee to cover the administrative costs of providing the information, or we may refuse to act on your requests.

If you have any questions or comments about this privacy policy, or you wish to make a request or exercise any of your rights, you can contact us:

• By telephone on: 020 7317 1300
• By email at: info@edge.uk.com
• By writing to us at:

Compliance Officer

Edge Investmenst Limited & Edge Creative Capital Limited
1 Marylebone High Street
London W1U 4LZ