ECM Investment Management Ltd recognises the importance of protecting your personal and financial information when you visit our website (ěwebsiteî) located at www.ecminvestment.com. We are committed to preserving the privacy of all visitors to the Website. Please read the following privacy policy to understand how we use and protect the information that you provide to us.
BY ACCESSING THIS WEBSITE, YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR INFORMATION UNDER THE TERMS OF THIS PRIVACY POLICY AND THE TERMS OF USE OF THIS WEBSITE.
When you visit our Website, you may be asked to provide certain information about yourself including your name and contact details. We may also collect information about your usage of this Website as well as information about you from e-mails, letters or any other correspondence between you and us.
ECM Investment Management Ltd does not undertake any obligations of non-disclosure or non-use of material received. Accordingly, please do not send any confidential or proprietary material to ECM Investment Management Ltd.
USE OF YOUR INFORMATION
Your information may be used for marketing and internal analysis purposes by
ECM Investment Management Ltd, its investment manager and their respective affiliates
and officers. We may also use and analyse the information we collect so that
we can improve and develop our Website. In particular, we may use your information
to contact you for your views on our Website and notify you occasionally about
important changes or developments to the Website. Further, where you have consented,
we might also use your information to let you know about products and services
which we offer which may be of interest to you.
ECM Investment Management Ltd does not sell its customers' e-mail addresses,
nor will we provide your personal information to third parties for their marketing
purposes. ECM Investment Management Ltd will not send you e-mail messages without
first receiving your permission, unless it relates to servicing your account
or unless you have consented to receiving electronic delivery of fund documents.
It is our policy to include instructions for unsubscribing from these permission-based
programmes. We recommend that you do not send us any individual personal information
via nonsecure methods of correspondence, including via public electronic communication
channels, such as Internet e-mail, which are generally not secure.
DISCLOSURE OF YOUR INFORMATION
The information you provide to us may be accessed by or given to our staff working
outside the UK and third parties who act for us for the purposes set out in this
policy and Terms of Use or for other purposes approved by you. Those parties
process information and provide support services on our behalf. Otherwise, ECM
Investment Management Ltd will not disclose your personal data to third parties,
except where you have given your consent or where ECM Investment Management Ltd
is under legal or regulatory obligation to do so.
COOKIES & AGGREGATE INFORMATION
We generally record certain usage information, such as the number and frequency
of visitors to our Website. This information may include the websites that you
access immediately before and after your visit to our Website, the Internet browser
you are using and your IP address. If we use such data at all it will be on an
aggregate basis, and we will not disclose to third parties any information that
could be used to identify you personally.
Additionally, if this Website is a password protected site, then (a) once you submit your password and enter, this Website will recognize who you are and will collect all information that you submit, including all electronic instructions (including all transaction information), and (b) any information collected about you from this Website may be associated with other identifying information that we have about you.
ECM Investment Management Ltd may use “cookies” to process and record information concerning your visit to and use of the Website and identify you when you visit the Website and to enhance your experience of the Website. “Cookies” are small pieces of information that your internet browser places on your computer’s hard drive. “Cookies” may be used for remembering user names and preferences, tracking click streams and in the future for presenting users with personalised versions of the Website. You have the option of setting your browser to block “cookies”. Please refer to the "help" function of your internet browser for instructions. In some cases blocking “cookies” may reduce the functionality of the Website or prevent access to it depending on your chosen internet browser options. If this is a password-protected site, then this Website may use cookies or other technology to help us authenticate you, store and recognize your configuration and user attributes, facilitate your navigation and entitlements throughout the Website and customize its content so that the information made available is more likely to be of interest to you. Additionally, you may encounter cookies or other similar devices on our Website that are placed by third parties. We do not control the use of cookies by third parties.
To safeguard the confidentiality of your personal data and information contained in this Website, ECM Investment Management Ltd implements security measures in line with industry standard practices. ECM Investment Management Ltd protects your personal information when you transact business on our Website by requiring the use of a browser software program that supports industry standard SSL encryption with 128-bit key lengths. The "128-bit" designation refers to the length of the key used to encrypt the data being transmitted, with a longer key representing a higher level of security. The web servers are housed behind a secure firewall that prevents access to databases from unauthorised users. All of the servers are housed in a secure environment that is protected by physical security, with limited access to authorised staff only. We will retain your information for a reasonable period or as long as the law requires.
THIRD PARTY WEBSITES
ECM Investment Management Ltd disclaims responsibility for the privacy policies
and customer information practices of third party internet websites hyperlinked
from our Website.
ACCESSING AND UPDATING
You are entitled to see the information held about you and you may ask us to
make any necessary changes to ensure that it is accurate and kept up to date.
If you wish to do this, please contact us.
CHANGES TO OUR PRIVACY POLICY
ECM Investment Management Ltd reserves the right to change, modify, add, or
remove portions of this Privacy Policy at any time for any reason. Changes
to our privacy policy will be posted on this Website. We suggest that you
review this policy periodically for changes. The current version of this
Privacy Policy can be accessed from the link on our homepage, or at the bottom
of our other Website pages. You acknowledge that by accessing our Website
after we have posted changes to this Privacy Policy, you are agreeing to
the terms of the Privacy Policy as modified.
CONTACT
If you have any comments, queries and requests relating to this Privacy Policy
or our use of your information please contact us at:
or by mail at:
ECM Investment
Management Ltd
Level 33, 25 Canada Square,
Canary Wharf,
London E14 5LQ
Tel: +44 (0) 207 038 8218
Updated and effective as of
1 December 2007