Aberdeen Standard Investments is committed to protecting your personal information.
Our Privacy Policy contains important information about what personal information we collect, what we use it for, with whom and why we may share it, and the options and rights you have regarding the personal information you provide.
We may need to make changes to our privacy policy. Therefore, please check our website from time to time for the current status of the policy. If there are any important changes regarding the way we handle your personal information, we may contact you to let you know.
Our cookie policy is part of our privacy policy. When you visit our websites, we use cookies to store information about how you use these websites in order to improve the quality of the services we provide to you. For more information about the types of cookies we use and how they work when you visit our websites, please see our Cookie Policy on our website www.aberdeenstandard.com/cookie-policy..
Who we are
We are Aberdeen Standard Investments and part of Standard Life Aberdeen plc, one of the world's largest investment companies.
This Privacy Policy applies to companies in the Aberdeen Standard Investments group (the legal trading companies that manage the products and services we provide to our customers and clients). A list of these group companies can be found on our website at www.aberdeenstandard.com/legal-and-regulatory.
How to contact us
If you have any questions about our privacy practices or the information we collect or use, please contact us:
FAO Privacy Officer
Aberdeen Standard Investments
1 George Street
Edinburgh
EH2 2LL
SLA_dpoffice@aberdeenstandard.com
What data we collect and use
We collect and use the following information about you, among other things:
- Information about you, such as your name, date of birth, and contact information
- Information related to the product or service you use, e.g. your bank details
- Information relating to your contact with us, e.g. meetings, telephone calls, email/letter correspondence
- Information collected automatically, e.g. by cookies, when you visit one of our websites
- Information collected when you visit one of our offices, e.g., surveillance camera images
- Personal information classified as "confidential," e.g., information about your health
- Children are not permitted to purchase our products and services. However, a child may be named as a beneficiary under some funds and trusts at the direction of a parent or guardian. In these cases, we collect limited personal information (such as name, age and gender) to identify the child.
If we collect and use sensitive personal data, it will only be collected and used to provide the product/service you have requested or to comply with our legal obligations, and only if we have received your explicit consent to process that data.
How we collect and use your information
We may collect your personal information directly from you through various sources, including:
- Application forms for products or services
- Telephone calls to us
- Emails or letters to us
- Conversations with our business development managers or customer service representatives
- Registration for one of our events
- Participating in opinion surveys designed to better understand you and improve our products and services
- Participation in sweepstakes where you can win tickets to sporting events sponsored by us, for example
- Our online services such as websites, social media and mobile device applications ("Apps"). We may also collect your personal information through business directories or other commercial or public sources, for example, to verify or correct information we have (such as your address) or to obtain accurate contact information if we cannot contact you directly.
- If you have a financial advisor, the information we collect and use was likely submitted by him or her on your behalf.
Why we collect and use data
Protecting your privacy is important to us, and we collect and use personal data only when necessary, appropriate and lawful. We will only collect and use your data when we can comply with lawful processing conditions set out in data protection legislation. This is the case when:
- it is necessary for the provision of the product or service you want; for example, if you want to invest in one of our funds or products, we will need some personal information such as your name, address, date of birth and bank details.
- it is necessary for us to comply with our legal or regulatory obligations, for example, to send you financial statements, to inform you of changes to our terms and conditions, or to detect or prevent fraud
- it is in Aberdeen Standard Investments' legitimate interests, i.e. to provide you with the right information and advice so that you know the options that will give your product or investment the best results; where we need to process your data to better understand you and your needs and to send you more relevant communications about your products and to enable us to develop new products and services. Where the processing is in our legitimate interests, we will always carry out an assessment to ensure that this use of your personal data is not excessive or dispensable or otherwise unnecessarily intrusive.
- You have given us your consent [your agreement] to use your data in this way. For example, we collect and use your sensitive personal information for certain types of direct marketing
If you do not want us to collect and use your personal information in this way, it may result in your inability to take advantage of our products or services.
Marketing and Analytics
Where you have given us your consent to do so (or you did not object when given the opportunity), we will send you information from Aberdeen Standard Investments about products and services from Aberdeen Standard Investments and other parts of Standard Life Aberdeen plc and/or our partners with whom we have sponsorship or similar partnership arrangements. Although the material may relate to third parties, we (and not the third party) will send you the information about these events and sponsorship activities. We have chosen to work with these third parties because we believe their products or services may be of interest and use to you.
To withdraw your consent or manage your preferences, please contact us (see the "How to Contact Us" section for more information).
We occasionally use systems to make automated decisions based on personal information that we have about you or that others are permitted to collect and use. These automated decisions may affect the products, services or features we offer you now or in the future. We use automated decisions in the following ways:
- To match products and services, for example, by assigning you to groups of similar customers to make decisions about the products and services we may offer you to better meet your needs
- In developing and improving our online services to meet your needs for ongoing advice and support
Who we share your information with and why We may share your information internally and with third parties. Please see the "Why we collect and use data" section for the reasons.
We share your information with:
- Other parts of the Aberdeen Standard Investments group and Standard Life Aberdeen plc who assist us in providing you with products and services
- Credit reference agencies to carry out a credit and identity check
- Your adviser, trustee, business partner, professional adviser, where this is necessary for the product or service you have agreed to provide to us
- Companies we have engaged to assist us in providing products and services we offer to you and other customers. This includes, for example, research, consulting or technology companies that we use to improve the services we provide to you
- Companies to help us contact you, such as internet service providers
- Our regulators, such as the Financial Conduct Authority (FCA) and the Information Commissioner's Office (ICO) in the U.K.
- Law enforcement and other delegated authorities who assist us in preventing and investigating crime (or request data) and, where appropriate, HM Revenue & Customs (HMRC) for tax return purposes.
Where your data is processed
Your data is largely processed in the UK and the European Economic Area (EEA).
However, some of your data may be processed by us or by third party service providers we work with outside the EEA, including in countries such as the US, Hong Kong, Singapore and India.
Where your data is processed outside the EEA, we take additional measures to ensure that the level of data protection applied to your data is at least equivalent to the level of data protection laws applicable in the UK/EEA. This means that we enter into legal agreements with our third party providers and conduct regular audits to ensure compliance.
How we protect your data We take information and system security very seriously and strive to comply with our obligations at all times. Appropriate safeguards are applied to any personal information collected, gathered or used in any way, whether on paper, online or through other media, in accordance with our privacy commitments.
Your information is protected by controls designed to minimize accidental, negligent or intentional loss or damage. Further, our employees protect sensitive or confidential information when storing or transmitting data electronically and complete mandatory annual training to do so.
Our security controls are consistent with industry standard and best practices. They provide a control environment to effectively manage risks to the confidentiality, integrity, and availability of your data.
How long we store your data
In order to provide your product or facility and to comply with our legal and regulatory obligations, we retain your personal data and copies of records we create (e.g., telephone calls) for as long as you are a client or customer with us.
Even after the client relationship has ended, we are required to retain data for various legal and regulatory reasons. The duration varies, and we regularly review our retention periods to ensure compliance with all laws and regulations.
Your rights
You have a number of rights under data protection laws which you can exercise in certain circumstances. These are:
- the right to be informed about how and why we process your personal data
- the right to access personal data relating to you
- the right to have inaccurate or incomplete personal data corrected
- the right to have personal data deleted
- the right to restrict the processing of personal data
- the right to data portability
- the right to object to the processing of personal data (e.g. profiling or direct marketing)
- the right not to be subject to an automated decision (including profiling) which significantly or lawfully affects you
If you would like to know more about your rights and how to exercise them, please contact us (see the "How to contact us" section).
How to file a complaint
We always strive to collect, use and protect your personal information in accordance with data protection laws. If you believe that we have not handled your information as set forth in our Privacy Policy, please notify us immediately (see the "How to Contact Us" section). We will do our best to correct the error.
We hope that we can resolve your complaints. However, you also have the option to complain to your local data protection authority (e.g., the ICO in the UK). This is possible whether or not you have exhausted our complaints procedure.
You can find your local data protection authority on the EU website:
www.ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
