Findlay Park Partners LLP
Almack House, 4th Floor
28 King Street
London
SW1Y 6QW
________________________________________
PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY BEFORE USING THIS SITE
Who we are and how to contact us
www.findlaypark.com is a site operated by Findlay Park Partners LLP (“We”). We are authorised and regulated by the Financial Conduct Authority (“FCA”). We are a limited liability partnership registered in England and Wales (Reg. No. OC303640) and have our registered office at 4th Floor Almack House, 28 King Street, London, SW1Y 6QW. This is also our main trading address. As an entity which is regulated by the FCA, we are subject to regulatory requirements which can be found at www.fca.org.uk
To contact us, please either email our Investor Relations team (info@findlaypark.com) or call them on +44 20 7968 4900.
By using our site you accept these terms
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, you must not use our site.
We recommend that you print a copy of these terms for future reference.
There are other terms that may apply to you
These terms of use refer to the following additional terms, which also apply to your use of our site:
The website content is for information only and expresses no views as to the suitability of investments to the individual circumstances of the recipient. No information, comment or stated opinion within this website constitutes an offer to sell investments in any jurisdiction and may not be used to make such an offer. Therefore, no person in any jurisdiction may treat the website content as constituting an offer or invitation to buy investments. If, however, an offer to sell investments is made in the future it will be subject to information circulated by us at the time set out in the formal prospectus or equivalent document and not on the basis of the information contained in this website. It is the responsibility of every visitor to this website to satisfy themselves as to the full observance of the laws of any relevant country, including obtaining any government or other consent which may be required or observing any other formality which needs to be observed in that country.
The Prospectus of Findlay Park Funds ICAV (the “Fund”) prohibits the selling of any shares in the Fund to US Persons (as defined in the Prospectus).
Pursuant to Swiss law and regulations only, this website is an advertising document. The state of the origin of the fund is Ireland. In Switzerland, the representative is ACOLIN Fund Services AG, Leutschenbachstrasse 50, CH-8050 Zurich, whilst the paying agent is Helvetische Bank AG, Seefeldstrasse 215, CH-8008 Zürich. The prospectus, the key information documents or the key investor information documents, the articles of association as well as the annual and semi-annual reports may be obtained free of charge from the representative. Past performance is no indication of current or future performance. The performance data do not take account of the commissions and costs incurred on the issue and redemption of units.
The investments and investment services to which this website relates are only intended for Investment Professionals. The website content is not directed to anyone who does not have professional experience in investing in equities. Any person who does not have professional experience investing in equities must not rely upon information available on this website as the basis of an investment decision and should seek professional advice.
The value of investments may go down as well as up and are likely to be affected by fluctuations in exchange rates, therefore returns are not guaranteed. As result of this and with the effect of transaction charges, investors may not get back the amount they invested.
Past performance is not a reliable indicator of future performance.
We may make changes to these terms
We may amend these terms from time to time. Every time you wish to use our site, please check these terms to ensure you understand the terms that apply at that time.
We may make changes to our site
We may update and change our site from time to time to reflect changes to our products, our users’ needs and our business priorities or our regulatory obligations. We will try to give you reasonable notice of any major changes.
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 suspend or withdraw or restrict the availability of all or any part of our site for business and operational reasons. We will try to give you reasonable notice of any suspension or withdrawal.
You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these terms of use and other applicable terms and conditions, and that they comply with them.
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.
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@findlaypark.com.
How you may use material on our site
Unless indicated otherwise, 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.
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, and you 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. These rights are in addition to any other rights we may have relating to such breach.
Prohibited uses
You may use our site only for lawful purposes. You may not use our site:
You also agree:
The provisions in this clause should be treated as an express reservation of our rights in this regard, including for the purposes of Article 4(3) of Digital Copyright Directive ((EU) 2019/790).
This clause shall not apply insofar as (but only to the extent that) we are unable to exclude or limit text or data mining or web scraping activity by contract under the laws which are applicable to us.
Do not rely on information on this site
The content on our site is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our site.
Although we make reasonable efforts to update the information on our site, we make no representations, warranties or guarantees, whether express or implied, that the content on our site is accurate, complete or up to date.
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.
User-generated content is not approved by us
This website may include information and materials uploaded by other users of the site, including to bulletin boards and chat rooms. This information and these materials have not been verified or approved by us. The views expressed by other users on our site do not represent our views or values.
If you wish to complain about information and materials uploaded by other users please contact us on info@findlaypark.com.
Our responsibility for loss or damage suffered by you
Indemnity
As a condition of using our website, you agree to indemnify us from and against all costs, charges, liabilities and expenses incurred by us pursuant to or in connection with your use of our website or from your act or omission to act which is a breach of these terms of use.
We are not responsible for viruses and you must not introduce them
We do not guarantee that our site will be secure or free from bugs or viruses.
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.
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.
If you wish to link to or make any use of content on our site other than that set out above, please contact info@findlaypark.com.
Which country’s laws apply to any disputes?
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.
PRIVACY POLICY
At Findlay Park Partners LLP we are committed to protecting your privacy and ensuring your personal data is collected and used appropriately, lawfully and transparently. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Please see the Glossary to understand the meaning of some of the terms used in this privacy policy.
Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Findlay Park Partners LLP collects and processes your personal data, including any data you may provide through our website.
Our website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 the other notices and is not intended to override them.
Controller
Findlay Park Partners LLP is the controller and responsible for your personal data (“Findlay Park”, “we”, “us” or “our” in this privacy policy).
We have appointed a Data Protection Manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Data Protection Manager using the details set out below.
Contact details
Our full details are:
Full name of legal entity: Findlay Park Partners LLP
Name or title of Data Protection Manager: Rashid Adam
Email address: DPM@findlaypark.com
Postal address: 28 King Street, London, SW1Y 6QW
Telephone number: 020 7968 4900
If you wish to raise a complaint about how we have handled your personal data, you have the right to contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk or 0303 123 1113). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We reserve the right, at our discretion, to change, modify, add to, or remove portions from this privacy policy. We will notify you of any material changes where we are required to do so. Any such notifications may be made by way of our website.
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.
Third-party links
Our 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.
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 different kinds of personal data about you which we have grouped together follows:
We may 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 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. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We make use of CCTV at our offices and may retain recordings.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you or any third party 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, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including:
Please note that we may record telephone (both mobile and landline) conversations and keep copies of electronic communications. We may retain copies of these recordings and electronic communications for a period of at least five years (or longer if required for legal and regulatory purposes).
We will only use your personal data in accordance with applicable laws. Most commonly, we will use your personal data in the following circumstances:
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new client or contact | (a) Identity
(b) Contact |
Performance of a contract with you or the provision of services to you. |
| To manage our relationship with you which will include:
(a) Sending you newsletters, factsheets, podcasts and other communications relating to the investment funds we manage or advise (b) Notifying you about changes to our terms or privacy policy (c) Asking you to leave a review or take a survey (d) Responding to your questions |
(a) Identity
(b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you or the provision of services to you.
(b) Necessary to comply with a legal or regulatory obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To administer and protect our business and any website (including troubleshooting, data analysis, testing, development system maintenance, support, reporting and hosting of data) | (a) Identity
(b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal or regulatory obligation |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity
(b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of product/service experience or other transactions.
Cookies
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 our website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy (set out below).
Change of purpose
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only allow our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
Some of our external third parties may have operations based outside the UK so their processing of your personal data may involve a transfer of data outside the UK. We currently transfer data to the following countries outside of the UK:
United States of America
South Africa
Canada
Ireland
We may update this list from time to time and any changes will be communicated to you via an update to this privacy policy.
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:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
We have put in place appropriate technical and organisational 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.
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, 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 of 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 requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
If you wish to exercise any of the rights set out above, please contact us.
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 may 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 may 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.
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). 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.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
Internal Third Parties
Findlay Park Investment Management Limited (based in the United Kingdom) which provides IT and system administration services.
External Third Parties
FINDLAY PARK USE OF COOKIES
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide management information to the owners of the site.
The table below explains the cookies we use and why.
| Cookie | Name | Purpose | More information |
| Google Analytics | _utma _utmb _utmc _utmz |
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. | Click here for an overview of privacy at Google |
Findlay Park Partners LLP is governed under the laws of England and Wales. The contents of www.findlaypark.com is owned and operated by Findlay Park Partners LLP.
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