Temple Bar Investment Trust plc (“Temple Bar”) is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. Temple Bar may utilise the services of service providers and/or administrators as data processors for the processing of your personal information described herein, including but not limited to RWC Partners Limited (“RWC”).

If you have any questions about this policy, please contact Huan Ke by email at: privacy@rwcpartners.com, or RWC Partners Limited, Verde, 10 Bressenden Place, London SW1E 5DH.

This Privacy policy explains the manner in which Temple Bar and RWC collects, utilises and maintains non-public personal information about individuals based in the European Union (“EU”) or the European Economic Area (“EEA”), as required under the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

Information you give us or we collect about you

In general, you can use this website without giving us any personal information. However, we may gather certain information such as records of your activity on the website and in this way process your personal information. For instance, if you sign up to receive our updates by email, or if you contact us, we will process your personal information because you will identify yourself when you do this.

We may collect and use the following information:

  • Your name and contact information (including e-mail address) and any other contact details you provide to us when you contact us;
  • The reason for your contact; for example, an enquiry or to provide a comment;
  • Information you provide if you report a problem with our website;
  • Records of any correspondence when you contact us;
  • Anonymous details of your visits to the Website including, but not limited to, traffic data, location data - and communication data and the resources that you access;
  • Details such as your mobile phone location data, IP address and MAC address; and
  • Information about how you use this website collected through cookies (see Cookie declaration).

What are ‘special categories of personal data’?

This is a more sensitive category of personal information which relates to a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning (mental or physical) health or data concerning a natural person’s sex life or sexual orientation. Please do not provide this type of data to us when you contact us or use our website. The same points apply to criminal convictions and offences data.

Countries having access to your personal information

Our servers, which store and keep your personal information, are located in the UK, however, these are accessible via RWC employees located outside of the EU and EEA, namely, the United States and Singapore.

We also have service providers and/or administrators whose personnel may have access to your personal information and that are located in other jurisdictions. These jurisdictions either (i) afford an adequate level of protection for your personal information (as declared by the European Commission) or, (ii) if they do not, then we have entered into an agreement with these service providers incorporating clauses the same or substantially similar to the standard contractual clauses, as well as other relevant provisions contained in the GDPR, and obligations no less onerous than those contained in this EU Privacy Policy.

Collecting your information legally

We are able to legally collect and use your personal information either because:

  1. you have consented to us doing so; and / or
  2. we have assessed that it is in our legitimate interests to process your personal data for limited marketing purposes in order to maintain, expand and develop our business;
  3. collecting and using your personal information is necessary for us to fulfil our contractual obligations to you by virtue of you being a client/investor;
  4. It is necessary to comply with any applicable regulatory, judicial or other legal obligation.

Retention of Your Personal Information

We and/or our service providers/administrators will retain Your Personal Information for the purposes described herein for as long as required for the purposes outlined.

Your rights

You have the right to:

  1. be informed about your personal information that we and / or our service providers / administrators collect from you, use, and retain;
  2. obtain confirmation from us that your personal information is being collected, used, and retained as described above and to access your personal information held by us;
  3. have your personal information corrected if it is inaccurate or incomplete at any time;
  4. erasure, or the right to be forgotten, which means you can request deletion or removal of any of your personal information we hold about you at any time, subject to our and/or our service providers/administrators rights to retain your personal information for legitimate business purposes;
  5. block or suppress our collecting and using your personal information, which means we can continue to store your personal information but cannot further collect or use it in any way;
  6. obtain and reuse any of your personal information that we hold about you for your own purposes across different services, which allows you to move, copy or transfer your personal information easily from us to another place identified by you in a safe and secure way without hindrance to the usability of your personal information;
  7. to us collecting, using or retaining your personal information where this is based on:
    1. your legitimate interest or the performance of a task in the public interest; or
    2. direct marketing even if otherwise legally permitted; and
  8. your consent to the use of your personal information at any time, as described below. To make any requests as listed above, please contact: privacy@rwcpartners.com.

Withdrawal of your consent

You may request that we stop collecting, using and retaining your personal information at any time by emailing us at privacy@rwcpartners.com. You should note that notwithstanding your withdrawal of consent, we may be legally required to retain and/or continue processing some or all of your personal information.

Protection of investor information

We maintain appropriate technical and organizational measures to ensure a level of security appropriate to potential risks, including physical, electronic and procedural safeguards that comply with the GDPR to protect customer information, including:

  1. the pseudonymisation and encryption of your personal information where appropriate;
  2. ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services;
  3. ensuring we can restore access to your personal information in a timely manner if a physical or technical incident occurs; and
  4. regular testing, assessment and evaluation of the effectiveness of its technical and organisational measures to attempt to ensure your personal information is secure.

We restrict access to the personal and account information to those employees who need to know that information in the course of their job responsibilities. We will destroy, erase or make unreadable data, computer files and documents containing your personal information that is non- public prior to disposal.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Making a complaint

If you would like to make a complaint about how your personal information has been collected, used or retained, please contact us at privacy@rwcpartners.com.

You have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence or place of work or in the place of the alleged infringement if you consider that the processing of personal data relating to you carried out by us or our service providers infringes the GDPR.

Contact Us

If you have any queries regarding this policy, please contact RWC at Investor privacy@rwcpartners.com.