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 tells 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 and other interactions with us.

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

Email address: DPM@findlaypark.com

Postal address: Second Floor, 16 New Burlington Place, London, W1S 2HX

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 via our website, email communications, or through relevant client interactions.

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.

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 different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title and details about your organisation/employer, such as shareholders, officers and authorised signatories.
  • Contact Data includes business address, email address and telephone numbers.
  • Technical Data includes 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 our website.
  • Profile Data includes your username and password, preferences, feedback, professional interests, business-related interactions, survey responses and information used to manage our professional relationship with you (such as hobbies, interests and significant life events). This may include records of meetings, events attended, and relevant professional connections where they pertain to our business engagement.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us, your communication preferences, CRM interaction history and data received from telephone conversations, emails and instant messaging.

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. If you voluntarily provide such data (e.g., during a meeting or email exchange), we will not record it in our systems unless explicitly necessary and permitted by law.

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, to meet regulatory obligations, 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 such cases, we may have to cancel or limit the services we provide to you, and we will notify you if this applies.

How is your personal data collected?

We use different methods to collect data from and about you including:

  • Direct interactions. You may give us your Identity, Contact and Profile Data by filling in forms or by corresponding with us by post, phone, email, instant messaging or otherwise. This includes personal data you provide when you:
    • apply for our products or services directly or on behalf of a third party;
    • create an account on our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • give us some feedback; or
    • provide information during interactions that help us manage our professional relationship with you.
  • Automated technologies or interactions. If you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • your financial adviser;
    • any platform through which you invest;
    • from service providers or agents appointed by us or Findlay Park Funds ICAV; and
    • professional networking platforms (e.g. LinkedIn), event organisers, and publicly available industry sources where relevant to our business relationship with you.

Identity and Contact Data from publicly available sources such as the Financial Conduct Authority’s financial services register, LinkedIn, company websites, Companies House and the Electoral Register based inside the EU.

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 seven years (or longer if required for legal and regulatory purposes).

How we use your personal data

We will only use your personal data in accordance with applicable laws. 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 or your clients or in relation to the provision of products or services to you or your clients in relation to an existing or proposed investment you, your clients or your organisation may have in Findlay Park Funds ICAV.
  • Monitoring or recording telephone calls with you to resolve any queries or issues.
  • 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, such as our processing of information used to manage our professional relationship with you.
  • Where we need to comply with a legal or regulatory obligation, for example, confirming your identity for regulatory purposes or detecting and preventing fraud, money laundering, terrorist financing or bribery.

Generally we do not rely on consent as a legal basis for processing your personal data, however, you have the right to object 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

(e) Recording relevant professional interactions (e.g., meetings, investor events, preferences) in our CRM system to personalise our engagement with you.

 (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, improve customer experience, and tailor communications based on professional interactions)
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 use data analytics to improve our website, products/services, marketing, customer relationships and experiences and to measure the effectiveness of our website, communications and marketing

 

 (a) Technical

(b) Usage

 

 Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
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 marketing messages, we will continue to send you regulatory communications and/or other essential service-related communications.

Cookies and Similar Technologies

Our website uses cookies and similar tracking technologies to enhance user experience, analyse site traffic, and support marketing activities. Some cookies are essential for website functionality, while others help us improve our services.

You can manage your cookie preferences through your browser settings or by visiting our full Cookie Policy for detailed information on the types of cookies we use, their purposes, and how you can control them.

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 that is compatible with the original purpose. If you wish to understand how a new processing activity is compatible with the original purpose, please contact us.

If we need to use your personal data for a materially different, unrelated purpose, we will notify you in advance and explain the legal basis which allows us to do so.

Where permitted by law, we may process your personal data without your knowledge or consent.

To stay update with how we process your personal data, please refer back to this privacy notice.

Disclosures of your personal data

We may share your personal data with internal and external third parties as set out in the Glossary. These include service providers, regulators, business partners, and other relevant entities where necessary for business operations, regulatory compliance, or the provision of our services.

We require all third parties to respect the security of your personal data and to process it in accordance with applicable data protection laws. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

In the event of a business restructuring, merger, or acquisition, we may share your personal data with potential buyers or business partners, subject to confidentiality and legal safeguards. If a change in ownership occurs, the new entity may process your personal data in accordance with this privacy notice.

International transfers

Some of our third parties operate outside the UK, which may involve transferring personal data internationally. Where we do so, we ensure that appropriate safeguards are in place, such as:

  • Transfers to countries with an adequacy decision under UK GDPR.
  • Standard contractual clauses (SCCs) or the UK International Data Transfer Agreement (IDTA).
  • Other legally recognised mechanisms to ensure adequate protection of your personal data.

Further details on how we protect international transfers can be obtained by contacting us.

Data security

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. These measures include:

  • Access controls – Personal data is restricted to authorised personnel on a need-to-know basis, with role-based access permissions.
  • Encryption and secure storage – We use encryption and other security technologies to protect sensitive data, both in transit and at rest.
  • Network and system security – Our IT infrastructure is protected using firewalls, intrusion detection systems, and endpoint protection solutions.
  • Monitoring and audit logs – We maintain security logs and conduct regular security audits to detect and respond to potential threats.
  • Training and awareness – Employees receive regular training on data protection and cybersecurity best practices.

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.

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 and to satisfy any legal, regulatory, and business obligations. 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 ‘Your legal rights’ for further information.

Where retention is no longer necessary, we will securely delete or anonymise your personal data. If we anonymise data (so that it can no longer be linked to an individual), we may retain it indefinitely for research or statistical purposes.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You can exercise these rights at any time by contacting us using the details in this privacy notice.

You have the right to:

  • Access your personal data You can request a copy of the personal data we hold about you and details of how we process it.
  • Request correction You can ask us to correct or update inaccurate or incomplete personal data.
  • Request erasure (“right to be forgotten”) You can ask us to delete your personal data where:
    • It is no longer necessary for the purposes we collected it for.
    • You withdraw your consent (where consent was required).
    • You successfully object to our processing of the data.
    • We have processed your data unlawfully.
    • We must comply with a legal obligation to erase it.

    We may not always be able to comply with your request for legal or regulatory reasons, which we will explain at the time.

  • Object to processing– You can object to our processing of your personal data if we rely on “legitimate interests” as our legal basis. You can always object to processing for direct marketing purposes, and we will stop immediately.
  • Request restriction of processing– You can ask us to limit how we process your data in certain circumstances, such as when you contest its accuracy or object to processing.
  • Request data portability– Where applicable, you can request that we transfer your personal data to you or another provider in a structured, machine-readable format.
  • Withdraw consent– If we rely on your consent to process your data, you can withdraw it at any time. This will not affect the lawfulness of any processing before your withdrawal.

We may ask you to provide proof of identity before fulfilling your request. We aim to respond to all valid requests within one month, but this may take longer if your request is complex.

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.

If you have concerns about how we handle your data, you also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO) at www.ico.org.uk.

Glossary

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

    • Professional advisers and service providers acting as processors, joint controllers or independent controllers. This includes third parties who provide consultancy, banking, trading, legal, insurance, administration and accounting services, including lawyers, bankers, brokers, auditors, insurers and IT specialists based inside or outside the UK.
    • HM Revenue & Customs, regulators and other authorities.
    • Agencies and organisations working to prevent fraud in financial services.
    • Analytics and website optimisation tools. See our cookie policy for more information. For example, we use Hotjar to better understand our website users’ needs and to optimise this service and experience. Hotjar is a technology service that helps us 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. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s website (www.hotjar.com).

    Important Information

    This document has been prepared by Findlay Park Partners LLP (“FPP”), the investment manager of Findlay Park American Fund, a sub-fund of Findlay Park Funds ICAV (“Fund”).

    Nothing contained in this document constitutes investment, accounting, tax or legal advice or an offer to sell, or a solicitation of any offer to buy, any interests or shares in any investment, including the Fund. Any subscription in the Fund will be subject to the terms, including a list of risk factors and conflicts of interest, set out in the Fund’s Prospectus, Key Investor Information Document and Supplementary Information Document.

    The material included herein is confidential and is intended solely for the use of the recipient and should not be redistributed in any way without FPP’s prior written consent.
    The information contained in this document is believed to be accurate at the date of publication. No representation or warranty is made as to its continued accuracy after such date and the information is subject to change without notification. The document may include information derived from third parties. All rights for third party data is reserved. Whilst FPP believes such sources to be reliable and accurate, no assurance is given in this regard. FPP does not warrant the accuracy, adequacy or completeness of the information and data contained herein and expressly disclaims liability for errors or omissions in the information or data. No warranty of any kind, implied, expressed or statutory, is given in connection with the information and data.

    Copyright © Findlay Park Partners LLP 2025. All rights reserved. No part of this work may be reproduced, stored in a retrieval system of any nature, or transmitted, in any form or by any means including photocopying and recording, without the prior written permission of Findlay Park Partners LLP.