Where we have a legal basis to use your personal data without consent (as we have described above), this Privacy and Cookies Policy fulfils our duty to process personal data fairly and lawfully and in a manner that you would expect given the nature of our relationship with you, by giving you appropriate notice and explanation of the way in which your personal data will be used.

Where consent is required for our use of your personal data as described above, we will request your consent. Typically, we would collect your consent by you performing an action such as ticking the appropriate consent box or otherwise communicating your consent to us (for example, by email or by you providing us with non mandatory information), you consent to our use of that personal data as set out in this policy.

You can always change your mind about our processing of your personal data. If you change your mind you can contact us by email at info@woodfordfunds.com, or in respect of marketing messages you can unsubscribe by using the unsubscribe link at the bottom of our marketing messages.

Cookie policy

Like most other websites, our website uses cookies. Cookies are small text files stored on your computer or mobile device by your browser. Cookies can be used to store certain preferences on a website or track if you have visited that site before.

No cookies used by Woodford store personally identifiable data such as:

Names

Phone numbers

Email addresses

Mailing addresses

Financial data

If you would like to limit or block the usage of cookies, you can do so in your browser settings. These settings differ between browsers.

By clicking “I Agree” on the cookie consent banner when you first access the Website and by using this site without changing your cookie settings, you are consenting to our use of cookies.

Adjust your privacy preferences

If you choose not to allow cookies, the quality of your browsing experience may be reduced and you may not be able to access all or parts of the Website. You can opt out of some individual cookies as described below.

If you have any questions on our use of cookies, please email info@woodfordfunds.com.

For more detailed information about cookies and how they can be managed and deleted, please visit www.allaboutcookies.org.

Retaining personal data

We will retain the personal data we receive or collect about you for the period reasonably required for us to use it in accordance with this Privacy and Cookies Policy or in accordance with our legal rights and obligations. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your rights

You have the following rights with regard to your personal data:

Access : You have the right to access data we hold about you. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

: You have the right to access data we hold about you. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Rectification or erasure : You have the right to request that we rectify or delete any personal data that we hold about you (unless we have the legal right to retain it). If you request that we erase any personal data that we require in order to provide our products and services to you, you may no longer be able to use it. This right does not extend to non-personal data. It is likely to be necessary for us to retain your personal data to enable us to carry out a contract with you, and your rights under applicable law to request erasure may be limited accordingly. This means your rights under applicable law to request erasure may be limited accordingly.

: You have the right to request that we rectify or delete any personal data that we hold about you (unless we have the legal right to retain it). If you request that we erase any personal data that we require in order to provide our products and services to you, you may no longer be able to use it. This right does not extend to non-personal data. It is likely to be necessary for us to retain your personal data to enable us to carry out a contract with you, and your rights under applicable law to request erasure may be limited accordingly. This means your rights under applicable law to request erasure may be limited accordingly. Data portability : You have the right to obtain personal data we hold about you, in a structured, electronic format, and to transmit such data to another data controller if the legal basis for processing such personal data is consent or on the basis of performance of a contract.

: You have the right to obtain personal data we hold about you, in a structured, electronic format, and to transmit such data to another data controller if the legal basis for processing such personal data is consent or on the basis of performance of a contract. Restriction : You also have the right to restrict us from processing your personal data if the data is inaccurate, the processing is unlawful or we no longer need to your personal data for the purposes for which we hold it.

: You also have the right to restrict us from processing your personal data if the data is inaccurate, the processing is unlawful or we no longer need to your personal data for the purposes for which we hold it. Object / Change of preferences : You have a right to request that we stop processing your personal data where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your personal information for direct marketing purposes. For example, if you have given your consent to receive updates from us about new products or services, but have changed your mind, you have the ability to opt out from receiving such communications going forward by contacting us using the details provided below or clicking the relevant link in any communications you receive. Please note, if you submit a request for us to stop processing your personal data in a certain way and this type of processing is required in order to provide you with our products and services, you will no longer be able to use our products and services following your request for us to stop the relevant processing.

: You have a right to request that we stop processing your personal data where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your personal information for direct marketing purposes. For example, if you have given your consent to receive updates from us about new products or services, but have changed your mind, you have the ability to opt out from receiving such communications going forward by contacting us using the details provided below or clicking the relevant link in any communications you receive. Please note, if you submit a request for us to stop processing your personal data in a certain way and this type of processing is required in order to provide you with our products and services, you will no longer be able to use our products and services following your request for us to stop the relevant processing. Complaints: If for any reason you are not happy with the way that we have handled your personal data, please contact us. If you are still not happy, you have the right to make a complaint to the Information Commissioner’s Office.

Please note that if you ask us to stop processing your personal data in a certain way or erase your personal data, and this type of processing or data is needed to facilitate your use of any of our products or services you may not be able to use them as you did before. This does not include your right to object to direct marketing, which can be exercised at any time without restriction. Please allow at least 5 working days for your request to be actioned.

Please note that the rights mentioned above do not extend to non-personal data. Please also note that it is likely to be necessary to retain your personal data for the purposes of assessing and verifying data that is submitted by you and to manage our products and services, so therefore your rights under applicable law to request erasure may be limited accordingly.

If you would like to exercise any of the rights mentioned above, please contact us at info@woodfordfunds.com.

Disclosure of your personal data

investment funds/trust or companies (including their agents or service providers) discretionary managed by us, such as the LF Woodford Equity Investment Fund;

other companies in the Woodford Group and their agents;

service providers (for example, IT services), business partners, suppliers and sub-contractors for the performance of any contract we enter into with you, and for processing of our data on the basis of our legitimate interest (as we have explained in this policy) including providing you with marketing communications or developing and tailoring products. Such service providers may help us to update your records, carry out marketing fulfilment services (such as distributing our materials and reports) and help us analyse data for our own internal purposes;

analytics, market researchers, data partners and search engine providers that assist us in the improvement and optimisation of the Website, our services, our products and their distribution;

government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons (this may include your location information);

in the event that we sell any business or assets or receive investment into our business, in which case we may disclose your personal data to the prospective buyer or investor;

if we or substantially all of our assets are acquired by a third party, in which case personal data held by us, including your personal data, will be one of the transferred assets; and

if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the Terms and Conditions for our website or any other contract between you and us;

or to protect the rights, property or safety of Woodford, our users, and others.

Storing your personal data and transferring data outside of the EEA

In operating our website and our services it may become necessary to transfer data that we collect from you to locations outside of the European Economic Area (EEA), such as the US and Australia, for processing and storing. By providing your personal data to us, you agree to this transfer, processing or storing. This may involve the transfer of data by electronic media, including the internet.

There is no adequacy decision by the European Commission in respect of the US or Australia which means that the laws of these countries are not deemed to provide an adequate level of protection to your personal data. However, to ensure that your personal data receives an adequate level of protection we may implement any mechanism that is approved under data protection laws to ensure that your personal data is treated by those third parties in a way that is consistent with EU and UK laws on data protection. These measures could include the following:

EU-US Privacy Shield; and/ or

EU standard contractual clauses.

If you would like to find out more about this or obtain a copy of the relevant standard contractual clauses, please contact us at info@woodfordfunds.com.

Our Website can also be accessed and used worldwide, which means your data may be processed outside the EEA. Please note that the country from which you are accessing personal data may not provide an adequate level of protection for your personal data.

Security

All information you provide to us is stored on secure severs. We will use appropriate technical and organisational measures to safeguard your personal data.

Where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

We maintain (and ensure that anyone we share your personal data with maintains) appropriate technical and organisational measures to ensure that an appropriate level of security in respect of all personal data we process. Unfortunately the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via the website or any of our services; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access or inadvertent disclosure.

Third party links

On occasion we include links to third parties on this website. Where we provide a link, we are not responsible for the collection or use of your personal data from these third party websites. You should review their privacy policy before sending them any personal data.

Letting us know if your information is incorrect

If any of the information which we hold about you is incorrect, please tell us and we will amend it. You can write to us at Woodford Investment Management Ltd, 27 Old Gloucester Street, London, WC1N 3AX or email us at info@woodfordfunds.com.

How to complain

This section tells you how you can contact us to complain about our data privacy processes and how you can contact appropriate government regulators.

Please let us know if you are unhappy with how we have used your personal data. You can contact us using info@woodfordfunds.com.

You also have the right to complain to the regulator, and to lodge an appeal if you are not happy with the outcome of a complaint.

In the UK this is the Information Commissioner’s Office. Find out on their website how to report a concern.

How to withdraw your consent and implication of not providing personal data

This section explains what to do if you no longer want us to hold or use your personal data. This section also explains the effects of not choosing to provide personal data.

Withdraw consent

You can withdraw your consent at any time. Please contact us at info@woodfordfunds.com if you want to do so.

This will only affect the way we use information when our reason for doing so is that we have your consent.

If you withdraw your consent or do not provide minimum personal data (like contact details), we may not be able to

provide information on certain products or services to you;

keep you informed on our business developments;

contact you regarding your desire to post on our website; or

report back to you on the status of any complaints you have made.

Contacting us

Please contact us if you have any questions relating to this Privacy and Cookies Policy at info@woodfordfunds.com.