Polar Capital (“we”, “us”, “our”) is committed to protecting data it receives about its customers and consumers (“you”, “your”) and complying with the Gramm Leach Bliley Act (‘GLBA’), the California Consumer Privacy Act (‘CCPA’) and any other applicable personal data protection regulations (together with the GLBA and the CCPA, the ‘Applicable Data Protection Regulations’).
If you have any questions about the information that is contained in this Privacy Policy, please contact Polar Capital through one of the following methods:
Physical address: 16 Palace Street, London SW1E 5JD, United Kingdom
Email: data.protection@polarcapital.co.uk
Telephone Number: +44 (0)207 227 2700
Contact: Boura Kym Tomlinson Cann – Global Chief Legal and Compliance Officer
Personal Information
Personal Information includes information that identifies, relates to, describes or is capable of being associated with or reasonably linked to a consumer, customer or, in the case of the Personal Information collected and used under the CCPA, the Californian Resident or their household.
Examples of Personal Information include names, signatures, identifiers such as social security numbers, financial account information, employment and education history, biometric information and audiovisual information, such as call and video recordings.
The Polar Capital Group will use the Personal Information it collects on you to fulfil its role as an investment manager to its strategies and to facilitate data to day business communications.
The table below sets out the categories of Personal Information that the Polar Capital Group collects, the sources of the Personal Information, the purposes that it will use that Personal Information for and who it will disclose the Personal Information to:
| Categories of Personal Information We Collect | Business/Commercial Purpose of Collection | Sources of Personal Information | Disclosure of Personal Information |
|---|---|---|---|
| Identifiers including real name, date of birth, passport, social security number, driving licence | Directories – For the purpose of building a client database. Client Servicing – To help you to administer your investment in our strategies, to provide you with information, such as factsheets and presentations, on Polar Capital Group strategies that you are invested in and to invite you to events and webinars held by the Polar Capital Group. Marketing – To provide you with information on the Polar Capital Group strategies you may be interested in, to invite you to events and webinars held by the Polar Capital Group and to keep you up to date with developments at the Polar Capital Group. Legal Obligations – To meet legal obligations such as carrying out know your customer and money laundering checks prior to you investing in our strategies and complying with anti-bribery laws. Management Information – To analyse investor activity in our strategies. |
Identifiers are, or may be, provided to us by the following parties: - You - Affiliated Entities - Administrators - Website Providers - Event Organisers - Marketing Providers |
Identifiers are, or may be, disclosed by the Polar Capital Group to the following third parties: - Affiliated Entities - Regulators and Authorities - Administrators - Event Organisers - Website Providers - Marketing Providers - Software or Database Providers |
| Contact Information including home address, telephone number, private email, work email | Directories – For the purpose of building a client database.
Client Servicing – To help you to administer your investment in our strategies, to provide you with information, such as factsheets and presentations, on the Polar Capital Group strategies that you are invested in and to invite you to events and webinars held by the Polar Capital Group. Marketing – To provide you with information on the Polar Capital Group strategies you may be interested in, to invite you to events and webinars held by the Polar Capital Group and to keep you up to date with developments at the Polar Capital Group. Legal Obligations – To meet legal obligations such as carrying out know your customer and money laundering checks prior to you investing in our strategies and complying with anti-bribery laws. Management Information – To analyse investor activity in our strategies. |
Contact information is provided to us by the following parties: - You - Affiliated Entities - Administrators - Website Providers - Event Organisers - Marketing Providers |
Contact Information is, or may be, disclosed by the Polar Capital Group to the following third parties: - Affiliated Entities - Regulators and Authorities - Administrators - Event Organisers - Marketing Providers - Software or Database Providers |
| Financial Information including source of funds, source of wealth, approximate net worth, bank account details, strategy holdings, trading history, tax residency status | Client Servicing – To help you to administer your investment in our strategies, to provide you with information, such as factsheets and presentations, on the Polar Capital Group strategies that you are invested in and to invite you to events and webinars held the by Polar Capital Group.
Legal Obligations – To meet legal obligations such as carrying out know your customer and money laundering checks prior to you investing in our strategies, complying with anti-bribery laws and reporting information to tax authorities. Management Information – To analyse investor activity in our strategies. |
Financial Information is provided to us by the following parties: - You - Affiliated Entities - Administrators |
Financial Information is, or may be, disclosed by the Polar Capital Group to the following third parties: - Affiliated Entities - Regulators and Authorities - Administrators - Software or Database Providers |
| Employment/Professional Information including job title, current employer, former employers, work address, work contact details, industry experience, qualifications | Client Servicing – To provide you with information, such as factsheets and presentations, on the Polar Capital Group strategies that you are invested in and to invite you to events and webinars held by the Polar Capital Group.
Marketing – To provide you with information on the Polar Capital Group strategies you may be interested in, to invite you to events and webinars held by the Polar Capital Group and to keep you up to date with developments at the Polar Capital Group. Correspondence – This information may be collected from you in the course of our correspondence and may be kept for the purpose of maintaining this correspondence. Legal Obligations – To meet legal obligations such as carrying out know your customer and money laundering checks prior to you investing in our strategies and complying with anti-bribery laws. |
Employment Information is provided to us by the following parties: - You - Affiliated Entities - Website Providers - Event Organisers - Marketing Providers |
Employment Information is, or may be, disclosed by the Polar Capital Group to the following parties: - Affiliated Entities - Event Organisers - Software or Database Providers |
| Characteristics including marital status, nationality, preferred language, dietary requirements | Service Optimisation – This information may be used to ensure that we provide our service in the best way possible.
Correspondence – This information may be collected from you in the course of our correspondence and may be kept for the purpose of maintaining this correspondence. |
Characteristics are provided to us by the following parties: - You - Affiliated Entities - Event Organisers |
Characteristics are, or may be, disclosed by the Polar Capital Group to the following parties: - Affiliated Entities - Event Organisers - Software or Database Providers |
| Audiovisual Information including photographs (from passports and driving licenses), telephone and videophone recordings | Service Optimisation – This information may be used to ensure that we provide our service in the best way possible.
Legal Obligations – We are required to keep recordings of phone conversations under legislation applicable to us and we are also required to meet anti-money laundering requirements. |
Audiovisual information is provided to us by the following parties: - You - Affiliated Entities - Communications Software Providers |
Audiovisual information is, or may be, disclosed by the Polar Capital Group to the following parties: - Regulators and Authorities - Administrators |
| Internet/other electronic information including device and IP addresses, online behaviour and logs of your actions on Polar Capital Group websites | Service Optimisation – This information may be used to ensure that we provide our service in the best way possible.
Marketing – To provide you with information on the Polar Capital Group strategies you may be interested in, to invite you to events and webinars held by the Polar Capital Group and to keep you up to date with developments at the Polar Capital Group. |
Internet/other electronic information is provided to us by the following parties: - Affiliated Entities - Website Providers |
Internet/other electronic information is, or may be, disclosed by the Polar Capital Group to the following parties: - Affiliated Entities - Website Providers |
| Inferences including those drawn from the Personal Information described above to create a profile of you or summary about you | Marketing – To provide you with information on the Polar Capital Group strategies you may be interested in, to invite you to events and webinars held by the Polar Capital Group and to keep you up to date with developments at the Polar Capital Group.
Service Optimisation – This information may be used to ensure that we provide our service in the best way possible. | Inferences are drawn by us from the Personal Information that we already hold on you |
Inferences are, or may be disclosed, by the Polar Capital Group to: - Software or Database Providers |
How do we protect your personal information?
We have security arrangements in place to guard against unauthorised access, improper use, alteration, destruction or accidental loss of your personal information. You are required to help with this by ensuring that your own personal information and that of your colleagues and third parties are kept secure. You should not share your (or anybody else’s) personal information unless there is a genuine business reason for doing so.
We take appropriate organisational and technical security measures and have rules and procedures in place to ensure that any personal information we hold on computer systems is not accessed by anyone it shouldn’t be.
When we use third party organisations to process information on our behalf we ask them to demonstrate their compliance with our security requirements, and any instructions we may give them and their compliance with relevant data protection legislation throughout the time they work for Polar. These organisations take their instructions from us and their obligations with regard to what information they process and what they can do with it are agreed in the contracts we have with them.
Californian Residents Rights under the CCPA
Under the CCPA, Californian Residents have the following rights with respect to their Personal Information:
The Right to Know
Californian Residents may request that the Polar Capital Group discloses to them what Personal Information it has collected, where it has collected this Personal Information from, what purposes it has been used for and to whom it has been disclosed. The request may be made in relation to categories of information or in relation to specific pieces of information.
Please be aware that in accordance with the CCPA regulations, the Polar Capital Group will never provide account social security numbers, driving license numbers, financial account numbers, passwords, security questions or their answers or financial account numbers in response to a request made by a Californian Resident to know a specific piece of Personal Information.
The Right to Delete Personal Information
Californian Residents may request that the Polar Capital Group erases the records of part or all of the Personal Information that the Polar Capital Group holds on that Californian Resident. Where a Californian Resident requests that part or all of their Personal Information is deleted, the Polar Capital Group will reach out to third parties to whom it has disclosed that Personal Information to ensure that it is also deleted on their systems.
Please be aware that the Polar Capital Group may not be able to comply with a request made by Californian Residents to delete their Personal Information in certain circumstances. These circumstances include:
- Where it is necessary for the Polar Capital Group to fulfil a transaction which the Personal Information was collected for or to provide a good or service reasonably expected by you; and
- Where the Polar Capital Group is required to keep your information for the purpose of meeting is legal and compliance obligations
The Polar Capital Group will also not be obliged to delete Californian Residents Personal Information where the Personal Information is held on our archived or back-up systems.
The Right to Opt-Out of the Sale of Personal Information
The Polar Capital Group does not sell the Personal Information of any California Resident, regardless of whether they are an adult or a minor (under 16). Therefore, the Polar Capital Group does not provide an option to opt out of the sale of a Californian Resident’s information on its website.
The Right not to be discriminated against as a result of exercising a Right under the CCPA
Californian Residents have the right not to be discriminated against in terms of services offered, services levels provided or fees offered or charged as a result of exercising one or more of their rights under the CCPA.
How to Exercise Your CCPA Rights
Request to know what Personal Information has been collected, used or disclosed by Polar Capital Group
Californian Residents may exercise their right to know what Personal Information is held by using the following contact details:
Toll-free Telephone Number: +001 833 794 0433
Email: data.protection@polarcapital.co.uk
When exercising a right to know what Personal Information has been collected, used or disclosed, Californian Residents must provide the Polar Capital Group with the information required to verify them, outlined in the ‘Verification of Request to Exercise Rights under the CCPA’ section below, whether they are enquiring about categories of information or about specific pieces of information that the Polar Capital Group holds and whether they would like to know about the collection, use and/or disclosure of that Personal Information.
Request to delete Personal Information held by the Polar Capital Group
Californian Residents may exercise their right to delete Personal Information held by the Polar Capital Group by using the following contact details:
Toll-free Telephone Number: +001 833 794 0433
Email: data.protection@polarcapital.co.uk
When exercising the right to delete the Personal Information collected by the Polar Capital Group, Californian Residents must provide the Polar Capital Group with the information required to verify them, outlined in the ‘Verification of Request to Exercise Rights under the CCPA’ section below, whether they would like to delete all of their information or only part of their information and, if they would like to delete only part of their Personal Information, which Personal Information you would like to be deleted.
Where a Californian Resident’s Personal Information is deleted as a result of their request, the Polar Capital Group will keep a copy of their request and the Personal Information supplied in accordance with that request pursuant to its obligation to keep records of Californian Residents requests under the CCPA.
Verification of Requests to Exercise Rights under the CCPA
Where Californian Residents make a request to the Polar Capital Group to exercise one of their rights under the CCPA, the Polar Capital Group is required to verify that this request has come from the Californian Resident. This is to prevent their Personal Information from being accessed or deleted as a result of a fraudulent request.
When exercising a request to know what Personal Information is held, used or disclosed by the Polar Capital Group or to delete the Personal Information that is held by the Polar Capital Group, Californian Residents will be required to provide Personal Information to us to match the Personal Information that we hold on them.
Where the Personal Information that is subject to the Californian Resident’s request is more sensitive, we will follow up with the Californian Resident after the request is made to ask that they provide a higher amount of Personal Information to ensure that we have verified them correctly.
Verification will be handled in accordance with the table below:
| Type of CCPA Request | Personal Information Required to Verify your Request |
|---|---|
| Request to know/delete for a category of Personal Information – No password protected account |
Name Email address |
| Request to know/delete for a specific piece of Personal Information – No password protected account |
Name Email address One additional piece of Personal Information at the Polar Capital Group’s request dependent on the nature of your relationship with the Polar Capital Group |
If a Californian Resident does not provide the Polar Capital Group with the information required to verify a request from them, then the Polar Capital Group is permitted to deny the request until the Californian Resident provides the information.
Authorised Agents
Californian Residents may appoint an Authorised Agent to exercise their rights under the CCPA. Authorised Agents may make requests to know or delete Personal Information on behalf of a Californian Resident in accordance with the methods outlined above.
The Authorised Agent must identify the Californian Resident it is submitting the request on behalf of when the Agent makes its request and must, at the time it submits the request or within 5 business days of doing so if it makes its request over the phone, provide proof of its authority to make the request on behalf of the Californian Resident and must provide the information required to verify the Californian Resident in accordance with the requirements above.
Where a Californian Resident appoints an Authorised Agent to make requests on their behalf under the CCPA, the Polar Capital Group is entitled to contact the Californian Resident to request that they provide us with the authorisation they have given to the Authorised Agent, to verify their own identity and/or to confirm that they have authorised the Agent to make that particular request.
Responding to Requests under the CCPA
The Polar Capital Group will acknowledge a request made by a Californian Resident to exercise their rights under the CCPA within 10 business days of receiving the request. If the Polar Capital Group cannot verify the Californian Resident from the details they provided in their request, the Polar Capital Group will provide the Californian Resident with details on how we will verify their request and will notify the Californian Resident of the timelines in which a response will be provided.
The Polar Capital Group will respond to requests made by Californian Residents under the CCPA within 45 days of receiving the request unless the request is complex. In these instances, the Polar Capital Group is entitled to extend the time in which it must provide a response by a further 45 days. Where the Polar Capital Group determines that it needs extra time to respond to a Californian Resident’s request, it will inform the Californian Resident as soon as reasonably practicable but in any event within 45 days of receiving their request.
Date of last review – 15 November 2022
