The Association of Investment Companies

Privacy Policy

This privacy policy gives you information on how the Association of Investment Companies (AIC) collects and processes personal data belonging to you or your personnel through your use of this website, in the context of the services we provide you or your business, and through any of the other ways we interact.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy notices and is not intended to override them.

We keep our privacy policy under regular review. This version was last updated on 6 June 2023.

Our website and our products/services are not intended for children and we do not knowingly collect data relating to children.

1. Controller & contact details

AIC is the controller and responsible for your personal data (we, us or our).

If you have any questions about this privacy policy or our privacy practices, including any requests to exercise your legal rights, please contact us at [email protected].

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer the following types of personal data about you:

Type of personal data

What this might include

Identity Data

First name, last name, pronouns.

Contact Data

Email address, telephone number, postal address.

Professional/ Employment-Related Data

Occupation, employer, business address, business e-mail address, business telephone number.

Account Data

Account holder login details, including username or other account identifier (usually email address), type of member classification, account settings.

Financial Data

Bank account and payment card details or, where relevant, your business’s bank account and payment details (this includes for payment or receipt of payment as a supplier).

Technical Data

Details on the devices and technology you use, including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

Usage Data

Length of visit, page views, website navigation paths, timing, frequency and pattern of your website use, and any other information about how you use our website.

Email Engagement Data

Information about how you interact with the emails we send you, including whether our emails have been delivered/received, how often our adverts/website pages have been accessed by the email receiver.

Preference Data

Your preferences in receiving marketing and other communications from us or third parties, including our updates, e-newsletters, announcements etc, including:

  • Watch lists
  • Income finder
  • Alerts (including exchange announcements)
  • RNS announcements
  • Compass e-newsletter
  • Spotlight e-newsletter
  • Perspective e-newsletter
  • Technical notes

(E-newsletters)

 

Communication Data

Information contained in or relating to any communication that you send to us or that we send to you (for example, email content, responses to quizzes/competitions etc), including the communication content and metadata associated with the communication.

We also collect, use and share aggregated data, such as statistical or demographic data, for any purpose. Aggregated data may be derived from your personal data but, as long as it is not combined with other data to identify you, is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you and is therefore no longer personal data) for research or statistical purposes. In which case we may use this information indefinitely without further notice to you.

We do not collect any special categories of personal data about you. Special categories of personal data are personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Nor do we collect any information about criminal convictions and offences.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, create an account for you).

3. How we lawfully use your personal data (the lawful bases)

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you. For example, to create an account for you when you register with us.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  • Where we need to comply with a legal or regulatory obligation.

We do not rely on consent as a legal basis for processing your personal data, except where you choose to register (and therefore give consent) to receive our E-newsletters or Pathway communications. You have the right to withdraw consent to marketing at any time by contacting us or by following the link to unsubscribe at the bottom of any marketing emails we send you.

4. The activities and purposes for which we will use your personal data, how we collect the data, and their corresponding lawful basis

We have set out below, in a table format, a description of all the ways we plan to collect and use your personal data, and which of the legal bases (and, where relevant, our legitimate interest) we rely on to do so.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.


Direct interactions – information we collect directly from you.

Processing activity / purpose for processing

Categories of personal data

Lawful basis for processing

If you contact us via phone, email, post or the ‘Ask a question’ or ‘Contact us’ or any other feedback forms on our website. We will process your information when we receive these communications, to be able to respond to you and provide you with information related to our services and otherwise answer any questions you have (we do not record phone calls)

  • Identity Data
  • Contact Data
  • Professional / Employment – Related Data
  • Communication Data

Necessary for our legitimate interests (to provide you with good customer service and information you request from us)

Performance of a contract with you (where you are enquiring about a membership)

If you attend an event we organise, such as a conference, roundtable or training session, or a committee/forum meeting

  • Identity Data
  • Contact Data
  • Professional / Employment – Related Data
  • Dietary requirements (where necessary for the event)

Necessary for our legitimate interests (to run our events and facilitate your participation in them)

If you respond to a quiz or competition (or other marketing campaign) we run (for example, in an industry magazine or on our website)

  • Identity Data
  • Contact Data
  • Professional / Employment – Related Data
  • Communication Data

Performance of a contract with you

Necessary for our legitimate interests (to study how people use our services and what they expect from the AIC, in order to develop our offerings and grow)

If you register and create an account on the website (as an individual investor; as an adviser for the adviser area; or as a representative of an investment company for the member centre)
  • Identity Data
  • Contact Data
  • Professional / Employment – Related Data
  • Account Data
  • Financial Data (where the membership is subject to a fee)
  • Technical Data
Performance of a contract with you
If you sign up to any of our E-newsletters
  • Identity Data
  • Contact Data
  • Professional / Employment – Related Data
  • Account Data
  • Preference Data
  • Email Engagement Data

Consent (when you sign up to receive our E-newsletters, you are giving your consent)

 

Legitimate interests (to carry out direct marketing to our members)

If you sign up to Pathway and/or if you sign up to receive Pathway updates/information on Pathway events
  • Identity Data
  • Contact Data
  • Preference Data
Consent (when you sign up to Pathway, you are giving your consent)


Automated technologies or interactions – information we automatically collect about your equipment, browsing actions and patterns, as you interact with our website or our emails.

Processing activity / purpose for processing

Categories of personal data

Lawful basis for processing

To ensure network and IT security and so that the server and website remain uncompromised (including analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity).

 

Unless investigating suspicious criminal activity, the information used is not identifiable information (i.e. it is anonymised / aggregated)

Technical Data

Usage Data

Necessary for our legitimate interests (for running the AIC’s business, provision of administration and IT services, network security and to prevent fraud)

 

Necessary to comply with a legal obligation (where we are investigating suspicious activity)

To analyse how users interact with our website and its features so that we can improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.

 

Technical Data

Usage Data

Necessary for our legitimate interests (to keep our website updated and relevant, to develop the AIC’s business and inform our marketing strategy)

We use cookies and similar technologies on our website, including essential, functional, analytical and targeting cookies and web beacons in our marketing emails to better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. (Please see our Cookie Policy for more information on cookies).

 

Information stored in pseudonymised user profile.

Technical Data

Usage Data

Necessary for our legitimate interests (to keep our website updated and relevant, to develop the AIC’s business and inform our marketing strategy)

Collect and use information via web beacons in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. (Please see our Cookie Policy for more information on web beacons).

Technical Data

Usage Data

Email Engagement Data

Necessary for our legitimate interests (to keep our website updated and relevant, to develop the AIC’s business and inform our marketing strategy)


Third parties or publicly available sources – information we may receive about you from various lawful sources.

What are you doing with the data and why?

What data are you using?

Lawful basis for processing

Where you are a representative of a company/organisation which has joined our adviser area or member centre, the company/organisation you represent may provide us with your business details so we can communicate with them via you

 

Identity Data

Professional / Employment – Related Data

 

Necessary for our legitimate interests (to allow us to communicate with the company you represent and fulfil any obligations we have with them)

Where you represent a company/organisation (e.g. wealth management group or financial adviser company), and one of our partners (such as RD:IR) thinks you will be interested in an event we are running, they may provide us with your business email

Identity Data

Contact Data

Professional / Employment – Related Data

 

Necessary for our legitimate interests (to market our events to interested parties in a B2B context)

 

To verify/complete the information we already hold about you. For example, if you are a director of an AIC member company, but we do not have your business email address, we may obtain this from a third party (e.g. publicly accessible sources such as Companies House, business directories, media publications, social media, websites, private data providers such as Boardex)

 

Identity Data

Professional / Employment – Related Data

 

Necessary for our legitimate interests (to fulfil our obligations / rights with the company you represent, to include a complete profile on the website or to be able to contact the organisation you represent)

Where you represent a company/organisation (e.g. adviser/investment company/journalist/industry stakeholder) and we think that the company/organisation you represent would be interested in joining us (if an investment company) or attending our events (e.g. publicly accessible sources such as Companies House, business directories, media publications, social media, websites such as management groups or a member company’s, private data providers such as Boardex and Roxhills if you are a journalist)

Identity Data

Professional / Employment – Related Data

 

Necessary for our legitimate interests (to market our events to interested parties in a B2B context)

 


5. Marketing

We provide you with options regarding our use of your personal data for marketing and communications – you can make these selections by going into ‘My account’ or by following ‘Update your preferences’ on the emails we send you.

We may use your Identity, Contact and/or Professional/Employment-Related Data to form a profile on what we think you may want or need, or what may be of interest to you and contact you about these (such as which services, events and offers).

If you are a Member director, we automatically sign you up to receive the E-Newsletter, ‘Perspective’ and topical AIC member emails. If you are a Member company secretary, we will automatically sign you up (using your business email) to receive the E-Newsletters: Technical Notes, Perspective, Compass, Spotlight and topical AIC member emails. Otherwise, we will only send you E-Newsletters if you have signed up to receive them (and have not opted-out).

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you E-Newsletters and other communications/marketing messages at any time by going into ‘My account’ or by following ‘Update your preferences’ on the emails we send you.

6. Cookies & pixels

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies and pixels we use, please see our Cookie Policy.

7. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • Service providers acting as processors who provide IT and system administration services such as: our website host (UK), email server (UK), telephone service provider (UK), email marketing service (Mailchimp, US), email marketing agency (Pivot Growth, UK), CRM database (Maximizer, Canada), managed IT support (Utilize, UK), and cloud workplace tools.
  • For events, we may additionally share information with our caterers, our digital engagement platform (ON24, US), Zoom/Microsoft Teams, and other attendees of the event.
  • Analytics providers – Google Analytics (US) and Hotjar (EEA).
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom, who require reporting of processing activities in certain circumstances.

If you represent an adviser or investment company, we may ask for your consent to share your Identity and Professional/Employment-Related Data with another adviser/investment company to facilitate communication between you. We will only do this with your consent.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8. International transfers

As noted above, some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. For the list of adequate countries and further details, see the ICO’s website.
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. If you would like further information on the contracts we have in place, please contact us.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

9. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

11. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are set out below.

  • Server log information: our website host retains information on our server logs for up to a year for security reasons.
  • Correspondence and enquiries: when you make an enquiry, or correspond with us for any reason, whether by email or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 3 further months after this.
  • E-Newsletter: we retain the information you used to sign up for our E-Newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our E-Newsletter service, whichever comes earlier. Information stored on our website servers in relation to newsletter sign ups is deleted after 12 months.
  • User account information: users’ accounts are deleted after 2 years of inactivity.

12. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

Further information on exercising these rights:

  • No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
  • What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
  • Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.