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Insight Investment privacy notice
Effective from November 2023

This privacy notice applies to Insight Investment Management Limited and its
affiliates (collectively referred to as "Insight", "we", "us"). Insight is a
wholly-owned subsidiary of The Bank of New York Mellon Corporation (BNY Mellon.)

You can find out more about BNY Mellon entities at
https://www.bnymellon.com/emea/en/about-us/locations.html or by contacting us
using the information in the contact us section.

This privacy notice explains how Insight collects, uses and shares personal
information in the course of our business activities, including:

 * What Personal Information we collect and when and why we use it
 * Communication recording policy
 * How we share personal information within BNY Mellon and with our service
   providers, regulators and other third parties
 * How we use cookies and tracking technology on our websites
 * Transferring personal information globally
 * How we protect and store personal information
 * Legal rights available to help manage your privacy
 * How you can contact us for more support

This notice does not apply to personal information processed in respect of
prospective, current or former employees of Insight. Our employee privacy notice
is available here.

We may amend this notice from time to time to keep it up to date with legal
requirements and the way we operate our business. Please regularly check these
pages for the latest version of this notice. If we make significant changes to
this privacy notice, we will seek to inform you by notice on our website or
email ("Notice of Change").

 


SALE OF PERSONAL DATA

Insight does not sell personal data. Personal data is only transferred or used
in accordance with the terms of this notice.

 


WHAT PERSONAL INFORMATION WE COLLECT AND WHEN AND WHY WE USE IT

In this section you can find out more about:

 * the types of personal information we collect
 * the legal basis for processing personal information
 * how we use personal information
 * when we collect personal information
 * additional information on the use of artificial intelligence and machine
   learning

Insight Data Subjects

Insight collects personal information and will act as the data controller of
this information if you:

 * are a client or represent one of our clients or our prospective clients
 * are associated with an Insight client while we undertake Know Your Customer
   (KYC) due diligence
 * work or correspond with us from a regulator, vendor or service provider
 * register with or use one of our website or online services
 * visit an Insight office or register to attend an event that Insight sponsors
 * attend an event where the sponsor shares attendance information with
   exhibitors
 * are associated with a financial arrangement which is promoted to Insight or
   its clients

Personal Information We Collect

Personal Information we collect will fall within the following categories:

 * Your name and how to contact you - Basic contact information about you,
   including your signature.
 * Identification data including unique descriptors - Government issued
   identifiers, other unique identifiers such as date of birth, and personal
   descriptors including account details that identify you.
 * Relationship Information - Details about your work or profession,
   nationality, education and family status.
 * Technical information - Details about your devices and technology that you
   use to access our services, including IP address.
 * Location - Data we receive about where you are.
 * Communications and CCTV - Information we capture through your communications
   with us, e.g. voice recordings of on-line conversations and conferences,
   emails and instant messaging, and CCTV images if you visit our offices.
 * Publicly available data - Details about you that are in public records and
   information about you that is openly available on the internet.
 * Sensitive categories of data - Laws and other regulations treat some types of
   personal information, including personal information relating to health or
   criminal convictions and offences, as special and affords them additional
   protections. We will only collect and use these types of data if the law
   allows us to do so.

The legal basis for processing your personal information

We will only collect, use and share your personal information where we are
satisfied that we have an appropriate legal basis to do this. This is explained
in more detail in the section below which sets out the purposes for which we
collect personal information. For each purpose, we indicate that we will have
one or more of the following reasons for using your personal information:

 * our use of your personal information is in our legitimate interests as a
   commercial organisation.
 * our use of your personal information is necessary to comply with a legal or
   regulatory obligation that we have, for example where we are required to
   report to tax authorities;
 * our use of your personal information is necessary to fulfil a contract we
   have with you or to take steps to enter into a contract with you, for example
   when you ask us to provide you with a product or service;
 * our use of your personal information is required for regulatory reasons that
   are in the public interest, for example to prevent and detect financial
   crime;
 * you have provided your consent to us using the personal information, for
   example if you have agreed to receive communications about an Insight event;

Insight collects personal information to build, manage and understand
relationships with corporations: institutional customers and prospects, and
vendors and suppliers. The personal information required to do this comes from
employees, consultants, trustees and other people associated with the
corporations and the market for institutional investment services. These
activities, and the legal basis for the associated personal data processing are
described in more detail below.

Insight provides investment services to corporations through and to natural
people whose information must be processed to deliver the service. Personal
information of officers, trustees and others is required to identify and
research persons relevant to the “know your customer” process required by
regulators. This activity takes place on the legal basis of Insight’s compliance
with enactment in the form of law and financial regulation.

The specific requirements (reporting, instructions, authentication and others)
of customer service require contact and other information for a wide range of
people associated with the customer and other organisations including their
consultants, intermediaries, fiduciaries, auditors, regulators and suppliers.
This takes place on the basis of our legitimate interest in the delivery of the
contracted service in a way which is transparent and timely fulfilling all
requirements of the customer and their stakeholders.

To defend Insight and our customers and stakeholders, Insight may need to
process personal data to prevent or detect crime. This activity may take place
on the basis of our compliance with an enactment, or our legitimate interest in
protecting our customers and protecting our reputation.

If you are participating in an Insight event you may be asked to consent for our
processing of information to provide elements of the event such as a specific
menu choice. Where you have provided your consent for voluntary provision of
personal data, you have the right to withdraw your consent at any time. You can
do so by making a request to the team that collected your personal information,
by clicking ‘opt out’ or ‘unsubscribe’ on direct marketing communications, or by
contacting us.

Our relationships with vendors are carried out through contacts with team
members at the vendor and their agents. Our use of the personal data required to
maintain these contacts takes place on the basis of our legitimate interest

Where we rely on our legitimate interests, we will do so on the basis that the
activity:

 * is necessary for us to meet our business or commercial objectives and to
   provide services to our clients and cannot be achieved without reliance on
   our legitimate interests;
 * is proportionate and would not cause unjustified harm;
 * is aligned to, or would not conflict with, your reasonable expectations;
 * does not undermine your individual rights, interests or freedoms; and
 * on balance, does not outweigh your privacy rights.

The balance between our legitimate interests and the rights of those involved in
customer service has to consider the large sums of money being managed, the
views of regulators, and the interests of members and pensioners not directly
party to the relationship.

We consider that the information we provide in the form of direct marketing is
worthwhile and interesting. Anyone can opt out or tailor use of their contact
information for this this processing via the unsubscribe link in any marketing
email.

 


COMMUNICATIONS RECORDING PRIVACY

Insight records internal and external communications made on its platforms for
the following reasons:

 * With the purpose of complying with our record-keeping obligations under
   financial service regulations
 * With the purpose of recording commitments made by the firm on its own behalf
   or on behalf of others
 * Through automatic systems and colleagues not being able to distinguish
   whether these purposes are engaged and consequently recording to ensure that
   records are not lost.

When required by regulation, the legal basis for this recording is compliance
with that requirement. Other recording is legally based on Insight’s legitimate
interest in having good and complete records of governance, commercial and
market activities and choices, as balanced between relatively low risk to the
participants in business-to-business communications, against the importance of
these other commitments to Insight’s economic viability and contribution to
society.

Some Insight communication platforms will obligatorily record all communication,
while others record all communication made involving Insight parties who are
judged to be at greater risk of communication relevant to our regulatory
record-keeping requirements. In addition, some Insight parties can elect to
record communication that would otherwise not have been recorded. Insight is
controller of all these recordings.

Insight recorded communications channels are:

 * Bloomberg and Symphony messaging
 * The content of Insight-controlled on-line calls and conferences including
   calls on telephone numbers, where one or more parties is an Insight colleague
   identified as being at elevated risk of certain investment communications, or
   any Insight party has elected to record. All text content on external
   conferencing services controlled by Insight is recorded.
 * All email to or from InsightInvestment.com addresses

Insight retains these records for as long as necessary to fulfil the relevant
purposes, which may include compliance with MIFID regulation and its successors
which require five year retention, or with Insight’s requirement to be
accountable for activities in relations to clients or colleagues during and
after the end of the relationship.

Non-Insight participants in communications involving Insight parties may make
other records. Even when the call has been set up by Insight colleagues or uses
Insight accounts, Insight does not control processing of personal information in
such records, nor is it responsible for giving any notices that may be required.

 


SHARING PERSONAL INFORMATION WITHIN INSIGHT AND BNY MELLON, WITH THIRD PARTIES,
WITH OUR REGULATORS

In this section you can find out more about how we share personal information:

 * within Insight and our corporate parent BNY Mellon
 * with third parties that help us provide our products and services
 * our regulators

We share your information in the manner and for the purposes described below:

 * within Insight and BNY Mellon, where such disclosure is necessary to provide
   you with our services or to manage our business;
 * with third parties who help manage our business and deliver services. These
   third parties have agreed to confidentiality restrictions and use any
   personal information we share with them or which they collect on our behalf
   solely for the purpose of providing the contracted service to us. These
   include IT service providers who help manage our IT and back-office systems;
 * with agencies and organizations working to prevent fraud in financial
   services;
 * with our regulators;
 * to comply with applicable laws, regulations and rules, and requests of law
   enforcement, regulatory and other governmental agencies;
 * we may share in aggregate, statistical form, non-personal information
   regarding the visitors to our website, traffic patterns, and website usage
   with our business partners, affiliates or advertisers;
 * BNY Mellon may, in the future, sell or otherwise transfer some or all of its
   assets to a third party. Your personal information, technical information
   about your device or browser and/or other anonymous information we obtain
   from you via the websites may be disclosed to any potential or actual third
   party purchasers of such assets and/or may be among those assets transferred.

 


USING COOKIES AND OTHER TECHNOLOGIES

In this section you can find out more about:

 * types of cookies used on our websites
 * third party advertisers
 * third party sites
 * control your cookie settings

Types of Cookies Used on Our Websites

We use cookies, web beacons and similar technologies ("Cookies") to track
information provided to us by your browser and by our software application when
you use our websites. A cookie is a small piece of information that a website
stores on the web browser on your device and can later retrieve. "Session"
cookies are temporary and will expire at the end of a browser session; that is,
when you leave a website. Session cookies allow a website to recognize you and
carry information as you navigate between pages during a single browser session
and allow you to use the website most efficiently. "Persistent” cookies, in
contrast, remain in the cookie file of your browser even after you leave a
website and after the browser is closed. They enable a website to recognize you
upon your return, remember your preferences and provide tailored services to
you. A cookie will not contain information that will enable us to contact you
via telephone, e-mail, or other means.

We, and third party service providers acting on our behalf, use session and
persistent cookies to:

 * remember preferences that you submit as well as those generated from your
   usage data and your responses to polls and surveys on our websites;
 * measure your use of our websites in an effort to improve its quality and
   enhance your overall experience, including tracking page views, time and date
   of website access, and other usage data, and identifying your operating
   system and browser type (but not other information about your computer or the
   programs on it) and your general geographic location; and
 * allow you to share certain information on our websites via social media
   bookmarking buttons, email or on social networking sites.

The third party service providers mentioned above use any personal information
they collect on our behalf solely for the purpose of providing the contracted
service to us. They have also agreed to confidentiality restrictions.

We may use aggregated usage data to track trends and analyse patterns on our
websites. If you register to enter an area of our websites, the website will
recognize who you are and collect all information that you submit (including
subscription to emails, etc.). Information collected about you from this website
may be associated with other identifying information that we have about you.

Third Party Advertisers

We may use third party advertising companies to serve ads on our behalf on other
websites across the Internet. To measure and track the effectiveness of such
ads, these companies typically use cookies; so a cookie may be set in the cookie
file of your browser when you click on one of our ads or visit a webpage
associated with our ad campaigns. These companies may also use and measure
information about your visits to our Site as part of this same process. The
information provided to us by these companies about you will be de-identified.

Third Party Websites

Our websites contain links to third party sites (including social media
bookmarking buttons that enable you to share certain content to our websites).
Although some of the entities controlling these websites are under contract with
us, not all of them are, so we advise you to familiarise yourself with the
individual privacy and cookie notice and other terms for each linked website
prior to submitting your personal information. We are not responsible for and do
not have control over their terms of use or privacy notices, have not reviewed
them and we do not accept any liability with respect to the content of these
websites or how they use cookies and handle your personal information. This
privacy notice does not apply to your use of a third party website.

Control Your Cookie Settings

Most browsers are initially set to accept cookies. However, you have the ability
to change your browser settings. It may also be possible to configure your
browser settings to enable acceptance of specific cookies or to notify you each
time a new cookie is about to be stored on your device enabling you to decide
whether to accept or reject the cookie. You can also disable cookies by
configuring your browser setting to reject cookies. Please refer to the help
section of your browser for instructions on disabling cookies. For more
information about cookies, how they work, why they are so useful and how to
disable them, you can visit http://www.allaboutcookies.org/.

If you do not wish to accept cookies from our website, please either disable
them or refrain from using our website. If cookies are disabled, it may mean
that you experience reduced functionality or will be prevented from using all or
part of our website.

For information about the cookies used on a specific application, please refer
to that application’s cookie notice. For more information about how
bnymellon.com collects information using cookies and tracking technologies you
can read the Cookie Notice on the Insight website.

 


TRANSFERRING PERSONAL INFORMATION GLOBALLY

In this section you can find out more about:

 * how we operate as a global business and transfer data internationally
 * the arrangements we have in place to protect your personal information if we
   transfer it overseas

Insight operates on a global basis. Accordingly, your personal information may
be processed in countries that are subject to different standards of data
protection, including the United States and India. Insight takes appropriate
steps to ensure that transfers of personal information are in accordance with
applicable law and carefully managed to protect your privacy rights and
interests, and that transfers are limited to countries which are recognized as
providing an adequate level of legal protection or where we can be satisfied
that alternative arrangements are in place to protect your privacy rights. To
this end:

 * transfers within Insight and BNY Mellon are covered by an agreement entered
   into by members of BNY Mellon (an intra-group agreement) which contractually
   obliges each member to ensure that personal information receives an adequate
   and consistent level of protection wherever it is transferred within BNY
   Mellon;
 * where we transfer your personal information outside BNY Mellon, or to third
   parties who help provide our products and services, we obtain contractual
   commitments from them to protect your personal information; or
 * where we receive requests for information from law enforcement or regulators,
   we carefully validate these requests before personal information is
   disclosed.

You have a right to contact us for more information about the safeguards we have
put in place (including a copy of relevant contractual commitments) to ensure
the adequate protection of your personal information when this is transferred as
mentioned above.

 


HOW WE PROTECT AND STORE YOUR INFORMATION

Security

Insight has implemented and maintains a comprehensive information security
security management system (ISMS) which is certified compliant with the relevant
international standard, ISO 27001. The standard requires written policies and
procedures designed to protect the confidentiality and integrity of personal
information. The ISMS contains administrative, technical and physical
safeguards, appropriate to the type of information concerned, designed to: (i)
maintain the security and confidentiality of such information; (ii) protect
against any anticipated threats or hazards to the security or integrity of such
information; (iii) protect against unauthorized access to or use of such
information that could result in substantial harm, and (iv) ensure appropriate
disposal of such information. The security of your personal information also
depends in part on the security of the devices you use to communicate with us,
the security you use to protect user IDs and passwords, and the security
provided by your internet service providers.

Storing and Retaining your personal information

BNY Mellon will retain your personal information:

 * for as long as required for the purposes for which it was collected, as
   explained in this notice
 * where we are required to do so in accordance with legal, regulatory, tax,
   accounting, or necessary technical requirements
 * for longer periods of time in specific circumstances so that we have an
   accurate record of your dealings with us in the event of any complaints or
   challenges, or if we reasonably believe that it may be required in defence of
   a legal claim.

In these circumstances your personal information will be subject to a corporate
retention plan which incorporates the factors above. For more information on the
retention of your personal information, you can contact us.

 


LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY

Subject to certain exemptions, and in some cases dependent upon the processing
activity we are undertaking, you have certain rights in relation to your
personal information. Please note that depending on your location your rights
may vary.

Your may have rights:

 * to access personal information
 * to rectify / erase personal information
 * to restrict the processing of your personal information
 * to transfer your personal information
 * to object to the processing of personal information
 * to object to how we use your personal information for direct marketing
   purposes
 * to obtain a copy of personal information safeguards used for transfers
   outside your jurisdiction
 * to lodge a complaint with your local supervisory authority

We may ask you for additional information to confirm your identity and for
security purposes, before disclosing the personal information requested to you.
We may charge a fee where permitted by law, for instance if your request is
manifestly unfounded or excessive

You can exercise your rights by contacting us. Subject to legal and other
permissible considerations, we will use reasonable efforts to honour your
request promptly or inform you if we require further information in order to
fulfil your request.

We may not always be able to fully address your request, for example if it would
impact the duty of confidentiality we owe to others, or if we are legally
entitled to deal with the request in a different way.

Right to Access Personal Information

You have a right to request that we provide you with a copy of your personal
information that we hold and you have the right to be informed of: (a) the
source of your personal information; (b) the purposes, legal basis and methods
of processing; (c) the data controller’s identity; and (d) the entities or
categories of entities to whom your personal information may be transferred.

Right to Rectify or Erase Personal Information

You have a right to request that we rectify inaccurate personal information. We
may seek to verify the accuracy of the personal information before rectifying
it.

You can also request that we erase your personal information in limited
circumstances where:

 * it is no longer needed for the purposes for which it was collected; or
 * you have withdrawn your consent (where the data processing was based on
   consent); or
 * following a successful right to object (see right to object); or
 * it has been processed unlawfully; or
 * to comply with a legal obligation to which BNY Mellon is subject.

We are not required to comply with your request to erase personal information if
the processing of your personal information is necessary:

 * for compliance with a legal obligation; or
 * for the establishment, exercise or defence of legal claims.

Right to Restrict the Processing of Your Personal Information

You can ask us to restrict your personal information, but only where:

 * its accuracy is contested, to allow us to verify its accuracy; or
 * the processing is unlawful, but you do not want it erased; or
 * it is no longer needed for the purposes for which it was collected, but we
   still need it to establish, exercise or defend legal claims; or
 * you have exercised the right to object and we are considering your request.

We can continue to use your personal information following a request for
restriction:

 * where we have your consent; or
 * to establish, exercise or defend legal claims; or
 * to protect the rights of another natural or legal person.

Right to Transfer Your Personal Information

You can ask us to provide your personal information to you in a structured,
commonly used, machine-readable format, or you can ask to have it transferred
directly to another data controller, but in each case only where: the processing
is based on your consent or on the performance of a contract with you; and the
processing is carried out by automated means.

Right to Object to the Processing of Your Personal Information

You can object to any processing of your personal information which has our
legitimate interests as its legal basis, if you believe your fundamental rights
and freedoms outweigh our legitimate interests.

If you raise an objection, we have an opportunity to demonstrate that we have
compelling legitimate interests which override your rights and freedoms.

Right to Object to How We Use Your Personal Information for Direct Marketing
Purposes

You can request that we change the manner in which we contact you for marketing
purposes.

You can request that we not transfer your personal information to unaffiliated
third parties for the purposes of direct marketing or any other purposes

Right to Obtain a Copy of Personal Information Safeguards Used for Transfers
Outside Your Jurisdiction

You can ask to obtain a copy of, or reference to, the safeguards under which
your personal information is transferred to countries not providing an adequate
level of data protection.

We may redact data agreements to protect commercial terms.

Right to Lodge a Complaint With Your Local Supervisory Authority

You have a right to lodge a complaint with your local data protection
supervisory authority if you have concerns about how we are processing your
personal information. We ask that you please attempt to resolve any issues with
us first, although you have a right to contact your supervisory authority at any
time.

 


CONTACT US

Please use the email address: privacy@insightinvestment.com for all enquiries in
relation to this notice and your rights.

If you have any questions, concerns or complaints regarding our compliance with
this notice and the data protection laws, or if you wish to exercise your
rights, we encourage you to first make contact as described above. We will
investigate and attempt to resolve complaints and disputes and will make every
reasonable effort to honour your wish to exercise your rights as quickly as
possible and in any event within the timescales provided by data protection
laws.

To Contact Your Data Protection Supervisory Authority

You have a right to lodge a complaint with your local data protection
supervisory authority (i.e. your place of habitual residence, place of work or
place of alleged infringement) at any time. We ask that you please attempt to
resolve any issues with us before lodging a complaint with your local
supervisory authority

Employee Privacy Notices

There is a separate privacy notice relating to the processing of data for
employees here.


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