Policy Category: Terms of Use

PLEASE READ THESE TERMS OF USE CAREFULLY BEFORE USING THIS SITEAS THEY SET OUT THE TERMS ONWHICH YOU MAY USE THE SITE

1. WHO WE ARE

www.hottinger.co.ukor www.hottinger.ie(“our site”) is a site operated by Hottinger Private Office (“We”). Hottinger Private OfficeLimited is a company registered in England and Wales with Reg. No. 07078765.The company is authorised and regulated by the Financial Conduct Authority, Reg. No. 521246

2. TERMS OF WEBSITE USE

This document (together with the documents referred to in it) (the “Terms of Use”) informyou of the terms on which you may make use of our site, whether as a guest or as a registered user. Use of our site includes accessing, browsing, or registering to use our site. Please read these Terms of Usecarefully before you start to use our site, as these will apply to your use of our site. We recommend that you print a copy of this for future reference. By using our site, you confirm that you accept these terms of use and that you agree to comply with them. If you do not agree to these terms of use, you must not use our site.

3. WHO OUR SITE IS DIRECTED AT

The information given and services referred to on our site are directed at residents of countries where companies in the Hottinger Group may lawfully conductbusiness. This site is not aimed at any other country or area and if you choose to access our site from outside the areas listed above you do so at your own risk. The content of this site has been approved for countries of the EEA by Hottinger Private Office and Hottinger Investment Management Limited, authorised and regulated by the UK Financial Conduct Authority. Our site is not directed at any person in any jurisdiction where (by
2reason of that person’s nationality, residence or otherwise) the publication or availability of our site is prohibited. Persons in respect of whom such prohibitions applymust not access our site.

4. OTHER APPLICABLE TERMS

These Terms of Use refer to the following additional terms,which also apply to your use of our site:

• The Disclaimer which sets out the extent of our liability to you. In the event of any conflict orinconsistency between these Terms of Use and the Disclaimer, the terms of the Disclaimer will prevail over these Terms of Use;
• The Privacy Statementwhich sets out the terms by which we process any personal data wecollect from you, or that you provide to us. By using our site, you consentto such processingand you warrant that all data provided by you is accurate;
• The Cookie Policywhich sets out information about the cookies on our site; and
• The Acceptable Use Policywhich outlines what is and is not acceptable regarding usage of oursite.

5. WE MAY MAKE CHANGES TO THESE TERMS

We may revise these Terms of Use at any time by amending this page without notifying you. By continuing to use and access our site you agree to be bound by any variation made by us. You are expected to check this page from time to time to take notice of any changes we have made, as they are binding on you. Some of the provisions contained in these Terms of Use may also be superseded by provisions or notices published elsewhere on our site.

6. WE MAY MAKE CHANGES TO OUR SITE

We may, at any time, update and change our site from time to time to reflect changes to our products, our users’ needs and our business priorities. We shall not be liable to you or to any third party for any such modification of our site. Furthermore, we accept no liability in respect of losses or damages arising out of changes made to the content of our site by unauthorised third parties.

7. WE MAY SUSPEND OR WITHDRAW OUR SITE

Our site is made available free of charge.

We do not guarantee that our site, or any content on it, will always be available or be uninterrupted. We may, at any time, suspend, withdraw, discontinue or restrict the availability of all or any part of our site for business and operational reasons. We shall not be liable to you or to any third party for any such modification, suspension or discontinuance of our site.

You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these Terms of Useand other applicable terms and conditions, and that they comply with them.

8. DO NOT RELY ON INFORMATION ON THIS SITE

The content on our site is provided “as is” and has been compiled in good faith, to provide general information only about our products and services. It is not intended to amount to financial, investment, legal or other advice and is not to be relied on in making any financial, investment or other decision. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our site.

We do not represent, warrant or promise (whether express or implied) that any information on our site is or remains accurate, complete and up to date, or fit or suitable for any purpose. We therefore disclaim all liability and responsibility arising from reliance placed on any such materials by any visitor to our site, or by anyone who may be informed of its contents.

9. YOU MUST KEEP YOUR ACCOUNT DETAILS SAFE

If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures, you must treat such information as confidential. You must not disclose it to any third party. You are responsible for all activities that occur using your account. You should take all necessary steps to ensure that your username and password are kept secret and secure and should change your password by using the appropriate function within our site.

You must ensure that the details you provide us with are correct, complete and not inappropriate in any way. You must not impersonate any other person or entity or use a false name or a name that you are not authorised to use. You agree to inform us immediately of any changes to the information that you provided when registering. You can access and update the information you provide to us within the appropriate area of our site.

We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our reasonable opinion you have failed to comply with any of the provisions of these Terms of Use.

If you know or suspect that anyone other than you knows your user identification code or password, you must promptly notify us at info@hottinger.co.uk.

10. WE ARE NOT RESPONSIBLE FOR WEBSITES WE LINK TO

Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked websites or information you may obtain from them.

We have no control over the contents of those sites or resources. You use such links entirely at your own risk and we accept no responsibility or liability for the content, use, or availability of such websites or for any loss or damage, however arising, as a result of their use.

11. RULES ABOUT LINKING TO OUR SITE

You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it.

You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.

You must not establish a link to our site in any website that is not owned by you.Our site must not be framed on any other site, nor may you create a link to any part of our site other than the home page.

We reserve the right to withdraw linking permission without notice.

The website in which you are linking must comply in all respectswith the content standards set out in our Acceptable Use Policy

If you wish to link to or make any use of content on our site other than that set out above, please contact info@hottinger.co.uk

12. HOW YOU MAY USE MATERIAL ON OUR SITE

We are the owner or the licensee of all intellectual property rights in our site, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved. Our site is for your personal and non-commercial use. You must not modify, copy, distribute, transmit, revise, perform, reproduce, publish, license, deep-link, create derivative works from, transfer, or sell any information or content obtained from any part of the materials on our site without obtaining a licence to do so from us or our licensors.

You may print off one copy, and may download extracts, of any page(s) from our site for your personal use and you may draw the attention of others within your organisation to content posted on our site.

You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, andyou must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.

Our status (and that of any identified contributors) as the authors of content on our site must always be acknowledged.You must not use any part of the content on our site for commercial purposes without obtaining a licence to do so from us or our licensors.

If you print off, copy or download any part of our site in breach of these Terms of Use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

13. OUR RESPONSIBILITY FOR LOSS OR DAMAGE SUFFERED BY YOU

Whether you are a consumer or a business user:

• We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors and for fraud or fraudulent misrepresentation.
• There is no exclusion of duties or liabilities under the Financial Services and Markets Act 2000, or any conduct of business rules which we are bound to comply with.

If you are a business user:

We exclude all implied conditions, warranties, representations or other terms that may apply to our site or any content on it.

We will not be liable to you for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:

• use of, or inability to use, our site; or
• use of or reliance on any content displayed on our site.

In particular, we will not be liable for:

• loss of profits, sales, business, or revenue;
• business interruption;
• loss of anticipated savings;
• loss of business opportunity, goodwill or reputation; or
• any indirect or consequential loss or damage.

If you are a consumer user:

Please note that we only provide our site for domestic and private use. You agree not to use our site for any commercial or business purposes, and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.

14. YOUR RESPONSIBILITY TO US

If you are in breach of any of these Terms of Use, you agree to indemnify and hold us harmless in respect of any costs, expenses, claims, proceedings, actions, losses, damages or liabilities incurred by us in relation to or arising from such a breach. This means you will be responsible for any loss or damage we suffer as a result of your breach of these Terms of Use

15. WE ARE NOT RESPONSIBLE FOR VIRUSES AND YOU MUST NOT INTRODUCE THEM

You access our site and download material from it at your own risk and we will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material.

You are responsible for configuring your information technology, computer programmes and platform to access our site. You should use your own virus protection software.

You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material that is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.

16. NO OFFER

Nothing on our site should be construed as a solicitation or offer, or recommendation, to buy or sell securities or any other investment or banking product, or to provide any investment advice or service.

17. JURISDICTION AND GOVERNING LAW

If you are a consumer, please note that these Terms of Use, their subject matter and their formation, are governed by English law. You and we both agree that the courts of England and Wales will have exclusive jurisdiction except that if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland.

If you are a business, these Terms of Use, their subject matter and their formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.

18. YOUR CONCERNS

To contact us about any concerns you may have, please email info@hottinger.co.uk or telephone our customer service line on +44 207 227 3400.

Our website (“site”) uses cookies to distinguish you from other users of our site. A cookie is a small file of letters and numbers that a website can store on the browser or hard drive of your computer.

Some cookies are deleted when you close down your browser. These are known as “session cookies”. Others remain on your device until they expire or you delete them from your cache. These are known as “persistent cookies” and enable us to remember things about you as a returning visitor. For further information about how to control and disable cookies in your browser please visit: www.aboutcookies.org.uk. Alternatively, you can search the internet for other independent information on cookies.

Cookies may be required to allow you to access and participate in certain areas of our site. The cookies we store on your computer do not contain any personally identifiable information.

There are different types of cookies used for different purposes. The cookies our site uses are listed below under the cookie categories recommended by the International Chamber of Commerce.

1. STRICTLY NECESSARY COOKIES

These are cookies that are required for the operation of our site. They include, for example cookies that enable you to log into secure areas of our website or to fulfil an action requested by you when you are logged on. Without these cookies we are unable to provide some products or services that you might request. Other strictly necessary cookies keep our website secure. Even if you say no to cookies on this website, we will continue to use these essential cookies.

2. PERFORMANCE OR ANALYTICAL COOKIES

These cookies allow us to improve our website by recognising and counting the number of visitors to our site and to see how visitors move around our site while they are using it. These analytics will help us improve the way our website works, for example by letting us know how we need to adapt our site to ensure users can easily find what they are looking for.

If you disable these cookies you will still be able to use most of our online services, but some might not work as you expect if you do not allow us to store and access cookies on your device.

We use cookies in the following ways:

 

Cookie Name	Type	Purpose	More Information
rememberMe520	Strictly Necessary Cookies	This cookie remembers that a user on this particular browser has agreed to the Terms & Conditions upon entry of the website. This cookie is held for 28 days.
“_utma”,“_utmb”,“_utmc”,“_utmz”	Performance/Analytical Cookies	These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.	Google’s Privacy Policy

3. MANAGING AND BLOCKING COOKIES

If you want to remove any cookies already set, you can do so from your browser. You can find out how to do this by going to the help menu in your browser or by visiting www.aboutcookies.org.uk or by searching the internet for other independent information on cookies.

You can also block cookies from your browser. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

SUMMARY: This document represents the Hottinger Group’s Privacy Statement

OWNER: Hottinger Group’s Board of Directors and Compliance Officer (CO)

EFFECTIVE DATE: April 2018

STATUS: Live

APPROVED BY: The CO of the Hottinger Group on 26 April 2018.The Board of Directors of the Hottinger Group on 26 April 2018

MODIFICATION HISTORY:

Version: 2016.01
Date: 19/09/2016
Reviewed By: Compliance
Changes: New Policy, which replaces version dated August 2011

Version: 2018.01
Date: 22/01/2018
Reviewed By: Compliance
Changes: NewPolicy, which replaces version dated September 2016

Version: 2018.03
Date: 26/04/2018
Reviewed By: Compliance
Changes: New Policy, which replaces version dated January 2018

WHO ARE WE?

Archco Limited and all its subsidiary companies, (together referred to as the Hottinger Group (“the Group”) (“we” or “us”) are committed to maintaining, protecting and respecting your privacy. You can visit our website without telling us who you are or revealing any information about yourself. However, if you do give us any personal information about yourself or others, we promise to treat it securely, fairly and lawfully.

THE DATA CONTROLLER:

For the purpose of the “Data Protection Laws and Regulations”, which means all laws and regulations, including laws and regulations of the European Union, the European Economic Area and their member states, Switzerland and the United Kingdom, including the General Data Protection Regulation (“GDPR”) (Regulation (EU) 2016/679) and the Data Protection Act 1998 (“the DPA”) or their successors, applicable to the Processing of Personal Data under the Terms of Use of this site, the data controller of the personal data you submit to this site is the Hottinger Private Office Limited together with Hottinger Investment Management Limited (i.e. we are responsible for, and control the processing of, your personal information).

Further information can be obtained by contacting us. (See the “How to Contact Us” section below.) Details of other companies that are part of the Group can be obtained by contacting us. (See the “Contact” section.)

WHAT THIS POLICY COVERS:

This policy covers without limitation, the home page, splash page and all other pages under the domain name www.hottinger.co.uk (“our site”) and all content contained on those pages. This policy (together with our Terms of Use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. If you do not agree with the terms of this policy, please do not use www.hottinger.co.uk.

1. INFORMATION WE MAY COLLECT FROM YOU

Information you give us.

You may give us information about you by filling in forms on our site or forms that we have given to you to fill in (which may be part of your agreement with us) by corresponding with us via phone, email, facsimile or otherwise. This includes information you provide when you register to use our site, log in to a service, subscribe to a service by us and when you report an issue with our site. The information you give us may include:

• your name
• email address
• phone number
• date of birth
• plan number
• gender
• financial information
• information about your investment strategies and objectives
• credit card information
• medical information; and
• any further personal information required as part of a product or service application or which you share through the website.

Information we collect about you.

Each time you visit our site we may automatically collect the following information:

• technical information including the internet protocol (IP) address used to connect your computer to the internet, your log-in information, browser type and version, browser plug-in types and versions, time zone setting, operating system and platform; and
• information about your visit, including the Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); items you searched for; page response times; download errors, length of time spent on pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page and any phone number used to call us.

Information we receive from other sources.

We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, criminal records check agencies). We receive personal data from these third parties from time to time. We may combine this information with information you give to us and information we collect about you. We may use this information and combined information for the purposes set out above (depending on the types of information we receive).

Monitoring and recording communications.

We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance with our obligations under applicable legislation.

Personal information about other individuals

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

• give consent on his/her behalf to the processing of his/her personal data;
• receive on his/her behalf any data protection notices; and
• give consent to the processing of his/her personal data which may include all of the information listed above.

2.COOKIES

Our site uses cookies to distinguish you from other users of our site and to make the site work more efficiently. For detailed information on the cookies we use and the purposes for which we use them please refer to our Cookie Policy on the Terms & Conditions page on the website.

3. HOW WE USE YOUR INFORMATION

We use information which you have given to us and we have collected and hold about you in the following ways:

• to carry out our obligations arising from any contracts entered into between you and the Group and to provide you with the information, products and services that you request from us;
• to comply with our legal obligations to carry out identity and anti-money laundering checks;
• to provide you with information about other products and services that we offer that are similar to those that you have already purchased or enquired about;
• to provide you, or permit selected third parties to provide you with information about products or services we feel may interest you;
• to notify you about changes to our service; and
• to ensure that content from our site is presented in the most effective manner for you and for your computer.
• to administer our site and for internal operations including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and your computer;
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.

4.MARKETING

We would like to send you information by post, email, telephone, text message (SMS) or automated call about our products and services which may be of interest to you.

Other businesses within our Group may also send you similar marketing messages, depending on what you agree with us. We will only ask whether you would like us to send you marketing messages when you tick the relevant boxes when you signed up for a product or a service with us or filled out aform on our website.

If you have consented to such receive marketing and/or other electronic or telephone communications from us, or other companies in our Group, you can opt out at any time. See the “Your Rights” section below for further information.

5. IDENTITY AND ANTI-MONEY LAUNDERING CHECKING

We may do an identity and/or credit check on you:

• so that we and other companies in our Group can verify your identity,
• make credit decisions about you and members of your household, and
• to prevent and detect fraud and money laundering

Our search will be recorded on the files of the credit reference agency.

We may also disclose information about how you conduct your account to credit reference agencies and your information may be linked to records relating to other people living at the same address with whom you are financially linked.

Other credit businesses may use your information to:

• make credit decisions about you and the people with whom you are financially associated
• trace debtors, and
• prevent and detect fraud and money laundering.

If you provide false or inaccurate information to us and we suspect fraud, we will record this.

If you want to see your identity check and/or credit file, please contact us using the contact Information in Section 12 below and we will provide you with the details of the agencies which we use so that you can contact them directly to obtain the relevant information.

6. DISCLOSURE OF YOUR INFORMATION

We may share your personal information with:

• other companies within our Group;
• our agents and service providers (including custodians);
• credit reference agents—see “Credit Checking” section above;
• our business partners in accordance with the “Marketing and opting out” section above; and
• suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• analytics and search engine providers that assist us in the improvement and optimisation of our site;
• in the event that we buy or sell any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• law enforcement agencies in connection with any investigation to help prevent unlawful activity;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, where requested by regulatory agencies, or in order to enforce or apply our Terms of Use and other agreements or to protect the rights, property or safety of the Group. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
• financial institutions and other similar organisations that we deal with in the course of the services we offer; and
• auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes, in any jurisdiction where we operate.

When we share your information with third parties they will process your information either as a data controller or as our data processor and this will depend on the purpose of our sharing the personal data. We will only share your personal data in compliance with the applicable data protection legislation.

A list of our selected third parties with whom we may share your information is available by you the data subject contacting us in writing to the Data Protection Officer, The Hottinger Group, 4 Carlton Gardens, St. James’s, London SW1Y 5AA, United Kingdom.

7. WHERE WE STORE YOUR PERSONAL DATA

All information you provide to us is stored on our secure servers located in the United Kingdom and the Republic of Ireland. Where you have a password, which enables you to access certain parts of our site, you are responsible for keeping this password confidential

8. TRANSFERS OF YOUR INFORMATION OUT OF THE EEA

When you signed up for our Services and entered into the agreement with us in respect of those Services you agreed that we may transfer your personal data to countries located outside the European Economic Area, for the purposes as set out in your agreement with us. Rest assured that we will always ensure any transfer is subject to appropriate security measures to safeguard your personal data including entering into European Commission approved contracts that that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.

Details of any third parties located outside of the EEA to which your personal data is transferred will be communicated to you in accordance with the terms of the agreement with you. We do not transfer your information outside of the EEA other than in accordance with an agreement you have with us.

9. SECURITY

What we do.

We will use technical and organisational measures to safeguard your personal data, for example:

• access to your account is controlled by a password and user name that are unique to you;
• we store your personal data on secure servers; and
• payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology).

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us (see “How to Contact US” section below).

What you can do.

You are responsible for keeping your password, user name and other log-in identity details secure and confidential. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

10. YOUR RIGHTS

Right to ask us to stop contacting you with direct marketing.

Even if you have accepted the processing of your personal data for marketing purposes (by ticking the relevant box), you have the right to ask us to stop processing your personal data for such purposes. Let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone). You can exercise this right at any time by contacting the Data Protection Officer at info@hottinger.co.uk or in writing to the Data Protection Officer, The Hottinger Group, 4 Carlton Gardens, St. James’s, London SW1Y 5AA, United Kingdom.

Right to request a copy of your information.

You can request a copy of your information which we hold (this is known as a subject access request). If you would like a copy of some or it, please contact the Data Protection Officer at info@hottinger.co.uk or in writing to the Data Protection Officer, The Hottinger Group, 4 Carlton Gardens, St. James’s, London SW1Y 5AA, United Kingdom and let us know the information you want a copy of, including any account or reference numbers, if you have them. Any subject access request may be subject to a reasonable fee to cover the cost of providing you with details of the information we hold about you.

Right to correct any mistakes in your information.

You can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please contact the Data Protection Officer at info@hottinger.co.uk or in writing to the Data Protection Officer, The Hottinger Group, 4 Carlton Gardens, St. James’s, London SW1Y 5AA, United Kingdom and let us know the information that is incorrect and the information you want it replaced with.

Right to request we cease processing your information.

You may request that we cease processing your personal data. If you make such a request, we shall retain only the amount of personal data pertaining you that is necessary to ensure that no further processing of your personal data takes place.

Right to request deletion of your information.

You can ask us to erase all your personal data (also known as the “right to be forgotten”) in the following circumstances:

• it is no longer necessary for us to hold that Personal Data with respect to the purpose for which it was originally collected or processed;
• you wish to withdraw your consent to us holding and processing your personal data;
• you object to us holding and processing your personal data (and there is no overriding legitimate interest to allow us to continue doing so);
• the personal data has been processed unlawfully; or
• the personal data needs to be erased in order for us to comply with a particular legal obligation.

Unless we have reasonable grounds to refuse to erase your personal data, all requests for erasure shall be complied with.

11. FOR HOW LONG DO WE KEEP YOUR DATA

We only keep your information for so long as it is necessary to fulfil the purpose for which it was collected which in most circumstances would be for so long as you have a valid account with us. There are regulatory and legislative requirements which oblige us to keep certain data for longer, and in order to comply with those regulatory requirements we keep that data for seven years. In very limited circumstances, we may be required to keep some specific information for longer, for example, pension transfer information, but we regularly review our retention obligations to ensure we don’t keep personal information longer that we’re legally obliged to.

Once we have completed the service requested and contracted by you, you or we have closed your account, and where applicable the regulatory or legislative retention period has expired, we will delete the information.

12. CHANGES TO OUR PRIVACY POLICY

We may change this privacy policy from time to time. Any changes to our privacy policy in the future will be posted on this page and where appropriate notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

13. HOW TO CONTACT US

If you have any questions about this privacy policy or the information we hold about you please send an email to the Data Protection Officer at info@hottinger.co.uk or write to us at the Data Protection Officer, The Hottinger Group, 4 Carlton Gardens, St. James’s, London SW1Y 5AA, United Kingdom; or call us on +44 20 7227 3400.

14. OTHER WEBSITES

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability forthese policies. Please check these policies before you submit any personal data to these websites.

15.COMPLAINTS

If you have any complaints about the way in which we collect, store and use your information, and these have not been addressed by contacting us first, you can contact the supervisory authority in the United Kingdom, the Information Commissioner’s Office: https://ico.org.uk/concerns.

This acceptable use policy sets out the terms between you and us under which you may access our website www.hottinger.co.uk(“our site”). This acceptable use policy applies to all users of, and visitors to, our site.

This acceptable use policy supplementsour Terms of Use. Please see the Terms of Usepolicy in the Legal and Regulatory section of the website. We have designed this Acceptable Use Policy so you can interact with us in a safe and appropriate way. If you do not accept this Acceptable Use Policy, please do not use our site.

www.hottinger.co.ukis a site operated by Hottinger Private OfficeLimited (“we” or “us”). We are registered in England and Wales under company number 07078765 and we have our registered office at 4 Carlton Gardens, St. James’s, London SW1Y 5AA.

We areauthorised andregulated in the UK by the Financial Conduct Authority(the “FCA”) and are registered with the FCA under registration number 521246.

1. PROHIBITED USES

You may use our site only for lawful purposes. You may not use our site:

• in any way that breaches any applicable local, national or international law or regulation; -in any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect;
• to send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards;
• to transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam); and/or
• to knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

You also agree:

• not to reproduce, duplicate, copy or re-sell any part of our site in contravention of the provisions of our terms of use;
• not to access without authority, interfere with, damage or disrupt: any part of our site; any equipment or network on which our site is stored; any software used in the provision of our site; and/or any equipment or network or software owned or used byany third party.

2. INTERACTIVE SERVICES

We may from time to time provide interactive services on our site, including (but not limited to) bulletin boards, social media feeds and webinars (“interactive services”). Where we do provide any interactive service, we will provide clear information to you about the kind of service offered, if it is moderated and what form of moderation is used (including whether it is human or technical).

We will do our best to assess any possible risks for users (and in particular, for children) from third parties when they use any interactive service provided on our site, and we will decide in each case whether it isappropriate to use moderation of the relevant service (including what kind of moderation to use) in the light of those risks. However, we are under no obligation to oversee, monitor or moderate any interactive service we provide on our site, and we expressly exclude our liability for any loss or damage arising from the use of any interactive service by a user in contravention of our content standards, whether the service is moderated or not.

The use of any of our interactive services by a minor is subject to the consent of their parent or guardian. We advise parents who permit their children to use an interactive service that it is important that they communicate with their children about their safety online, as moderation is not fool proof. Minors who are using any interactive service should be made aware of the potential risks to them.

Where we do moderate an interactive service, we will normally provide you with a means of contacting the moderator, should a concern or difficulty arise.

3. CONTENT STANDARDS

These content standards apply to any and all material which you contribute to our site (“contributions”), and to any interactive services associated with it.

You must comply with the spirit and the letter of the following standards. The standards apply to each part of any contribution as well as to its whole.

Contributions must:

• be accurate (where they state facts);
• be genuinely held (where they state opinions); and
• comply with applicable law in the England & Wales and in any country from which they are posted.

Contributions must not:

• contain any material which is defamatory of any person;
• contain any material which is obscene, offensive, hateful or inflammatory;
• promote sexually explicit material;
• promote violence;
• promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age;
• infringe any copyright, database right or trade mark of any other person;
• be likely to deceive any person;
• be made in breach of any legal duty owed to a third party, such as a contractual duty or a duty of confidence;
• promote any illegal activity;
• be threatening, abuseor invade another’s privacy, or cause annoyance, inconvenience or needless anxiety;
• be likely to harass, upset, embarrass, alarm or annoy any other person;
• be used to impersonate any person, or to misrepresent your identity or affiliation with any person;
• give the impression that they emanate from us, if this is not the case; and/or
• advocate, promote or assist any unlawful act such as (by way of example only) copyright infringement or computer misuse.

4. SUSPENSION AND TERMINATION

We will determine, in our discretion, whether there has been a breach of this acceptable use policy through your use of our site. When a breach of this policy has occurred, we may take such action as we deem appropriate.

Failure to comply with this acceptable use policy constitutes a material breach of the Terms of Use upon which you are permitted to use our site, and may result in our taking all or any of the following actions:

• immediate, temporary or permanent withdrawal of your right to use our site;
• immediate, temporary or permanent removal of any posting or material uploaded by you to our site;
• issue of a warning to you;
• legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach;
• further legal action against you; and/or
• disclosure of such information to law enforcement authorities as we reasonably feel is necessary.

We exclude liabilityfor actions taken in response to breaches of this acceptable use policy. The responses described in this policy are not limited, and we may take any other action we reasonably deem appropriate.

5. CHANGES TO THE ACCEPTABLE USE POLICY

We may revise this acceptable use policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are legally binding on you. Some of the provisions contained in this acceptable use policy may also be superseded by provisions or notices published elsewhere on our site.

6. COMPLAINTS

If you would like to make a formal complaint about the use of the site by another user, please contact us at info@hottinger.co.uk.