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Privacy and Cookies Policy

September 2020

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As a visitor to this website, City of London Investment Management Company Limited is committed to protecting your privacy and maintaining the confidentiality and security of your information. This Privacy and Cookies Policy will help you understand how we safeguard the personal information we collect and how we use it to service you and your account.

City of London Investment Management Company Limited (“CLIM”) has adopted this Notice for all of its subsidiaries and related entities (collectively, “CLIM”, “we”, “our” or “us”) pursuant to articles 13 and 14 of the EU Regulation 2016/679, the California Consumer Privacy Act of 2018 and other applicable data protection and privacy laws (hereinafter the "Regulation") concerning the processing of personal data of users and registered users of its website www.citlon.co.uk and www.citlon.com (hereinafter referred to as the “Website”).

  1. Who is the controller of my data?

    The controller of your personal data is City of London Investment Management Company Limited, with its registered office at 77 Gracechurch Street, London EC3V 0AS, United Kingdom registered in England and Wales under no. 2851236.

  2. If I am a visitor of the Website, what types of data are processed and for what purposes?

    If you are a visitor of the Website (registered or unregistered), the following types of personal data will be processed and for the following purpose:

    Navigation data: the information systems and software procedures relied upon to operate this Website acquire personal data as part of their standard functioning; the transmission of such data is an inherent feature of Internet communication protocols. Such information is not collected to relate it to identified data subjects, however it might allow user identification per se after being processed and matched with data held by third parties. This data category includes IP addresses, and/or the domain names of the computers used by any user connecting with this Website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), and other parameters related to the user's operating system and computer environment. Except as provided in the following paragraph 8 in relation to the use of cookies on the Website, this data is only used to extract anonymous statistical information on Website use as well as to check functionality and is erased immediately after being processed. However, such data might be used to establish liability in case computer crimes are committed against the Website. Navigation data processing is necessary for our legitimate interests to guarantee the Website security.

    Data provided voluntarily by the User: spontaneous e-mail transmitted to us: please note that sending e-mail messages to the addresses mentioned on the Website, which is done based on a freely chosen, explicit, and voluntary option, entails acquisition of the sender's personal data, which is necessary to reply to any request on services or products. Providing such personal data is optional but failure to provide them would imply the impossibility to obtain the requested information.

    CLIM does not and will not sell your personal information.

  3. If I am a registered user of the Website, what are the purposes of the processing?

    If you are a registered user of the Website, your personal data will also be processed to allow you to access the services of the restricted area of the Website, as well as to implement pre-contractual measures adopted at your request, such as in case you should ask for information in relation to our products or services and/or in relation to the Website, and to provide any assistance requested by you.

  4. Is the provision of the data mandatory or optional?

    Providing your personal data is optional but failure to provide such would imply the impossibility to register to the Website and be provided with the requested services.

  5. Do you process my data also for other marketing purposes?

    CLIM does not process your data for other marketing purposes.

  6. How is my data processed and for how long will my data be stored and processed?

    Your personal data will be processed both by electronic and non-electronic means, for the intended purpose in a manner that ensures appropriate security and confidentiality of the personal data.

    If you have contacted us via e-mail to obtain pre-contractual information on our products and/or services, your personal data will be retained and stored until the requested information is processed, unless the further storage of data is required to comply with legal obligations.

    When you consent to the processing of your personal data for marketing purposes, your personal data will be retained until you have withdrawn consent to the processing of your data for marketing purposes for all or some contact methods.

    Personal data of registered users will be retained and stored for as long as your account is active or for the further period necessary to comply with legal obligations.

  7. Will my data be transferred outside the European Economic Area?

    Your personal data (full name and e-mail address) will be transmitted outside the European Economic Area as some of our client servicing team and network servers are located in the US.  Your data will also be available to subsidiaries and related entities of CLIM as well as our holding company, City of London Investment Group plc (“CLIG”).

  8. Does your Website use cookies?

    Yes, it does. Please read our Cookie Policy described below.

  9. Who may have access to the data?

    The following subjects may have access to your personal data as data processor: our employees and collaborators which are responsible for maintaining and operating the Website, assisting clients and prospective clients, and/or carrying out the marketing activities, as well as external service providers which, acting as external data processors, provide services for the management of the IT systems and communications network, advisors, auditors, companies providing marketing services, and other support and management services providers.

  10. Will my data be communicated to third parties or disseminated?

    CLIM does not disclose client information to anyone, except as permitted by law and as is deemed necessary by CLIM to provide our services to your account.

  11. What are my rights?

    You will be able to exercise the rights set forth in the Regulation, including the following rights: the right to request the access to personal data (i.e. the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, to obtain access to the personal data, by obtaining a copy, and the information set forth in the Regulation) and the rectification (i.e. the right to obtain the rectification of inaccurate personal data concerning you or the integration of incomplete data) or the erasure (i.e. the right to obtain the erasure of personal data concerning you, where one of the grounds listed in the Regulation applies) or the restriction of processing concerning you (i.e. the right to obtain that the data are marked in a way to limit the processing in the future), as well as the right to data portability (i.e. the right to receive from us the personal data concerning you, in a structured, commonly used and machine-readable format and the right to transmit such data to another controller without hindrance). You have the right to withdraw your consent at any time. The consent withdrawal will not affect the validity of the processing based on your consent before the withdrawal. You also have the right to file a complaint with the Data Protection Authority (https://ico.org.uk) or with the Data Protection Authority of the EU Member State where you have your residence or work, or with your resident state authority.

  12. Do I have the right to object to the processing under the Regulation?

    Yes, you have the right to object, on grounds relating to your situation, at any time to the processing of personal data concerning you pursuant to the Regulation, including profiling based on these provisions. Should your personal data be processed for direct marketing purposes, you have the right to object to the processing of personal data concerning you at any time, including the profiling to the extent that it is linked to such direct marketing.

  13. How can I exercise my rights?

    The above-mentioned rights can be exercised by mail sent to City of London Investment Management Company Limited at the address “77 Gracechurch Street, London EC3V 0AS, United Kingdom” or via email.

  14. Cookie Policy

    September 2020

    As our Website uses some of the so called "cookies", this Cookie Policy explains what the cookies are and how they are used on the Website.

    A. What are cookies and what are they used for?

    Cookies are small text files that the websites visited by the user send directly to his/her terminal (usually to the browser). Such cookies are stored on the user's terminal in order to be retransmitted to the same websites when the user accesses them again (so called first-party cookies). During the browsing on a website, the user may receive on his/her terminal also cookies of different websites or webservers (so called third-party cookies); this happens because the visited websites contain items such as images, maps, sounds, specific links to pages of other websites that are hosted on a server other than the one on which the requested page is hosted. In other words, these are cookies that are set by a website different from the one that the user is currently visiting.

    The cookies may be limited to a single browsing session (so called session cookies) and, in such case, they automatically disable when the user closes the browser. Some other cookies may have a preset expiry date and, in such case, they will remain stored and active in the user’s hard-disk until such expiry date, continuing to collect information in the course of the subsequent browsing sessions (so called permanent cookies).

    Cookies are used for different purposes. Some of them are used to allow the user to visit a website and use its features (so called technical cookies). Some other cookies are used to collect statistical information, in aggregated or non-aggregated form, about the number of users who access a website and how a website is used (so called monitoring or analytics cookies). Lastly, other cookies are used to track the user’s profile as a consumer and display advertising on a website which are consistent with the user’s interests (so called, profiling cookies). The Website uses only technical cookies stored by CLIM (first-parties cookies) to make it work efficiently and help provide a better user experience. The Website does not use profiling cookies.

    As also indicated in section B below, the Website uses an identification cookie in the UCITS section to allow users to bypass the disclaimer page for a period of 180 days from the time they tick the accept box found on the disclaimer page. The cookie name is "disclaimer_ucits". The Website does not use third-party cookies to collect information.

    For further details about technical cookies please keep reading this Cookie Policy. Find out how they work and what they are used for and freely choose whether to provide or not your consent to their use.

    B. Technical cookies

    Technical cookies are used on the Website for the sole purpose of providing a better user experience. These cookies are always first-party cookies, as they are stored directly by us through the Website.

    Some technical cookies are necessary to provide you with an optimized user experience or to allow your authentication on the Website, e.g. to access your personal area (so called navigation cookies). Normally navigation cookies are session cookies and, therefore, once the internet browser is closed, they are automatically disabled.

    Other technical cookies are useful to allow the user to save some of his/her preferences (e.g. the language or the country of origin) without having to reset such preferences each time you visit the Website (so called functionality cookies). For this reason, functionality cookies are often persistent cookies, because they remain stored in your computer even after the internet browser has been closed, until the relevant expiry date or until you delete them from your browser.

    The following technical cookie is currently used on the Website:

    Cookie Name Cookie Category Cookie Function/Duration
    disclaimer_ucits functionality cookie This cookie allows you to bypass the disclaimer page for a period of 180 days from the time you tick the accept box found on the disclaimer page.
    pjAcceptCookie functionality cookie This cookie allows you to bypass the Privacy Policy acknowledgment pop-up window for a period of 180 days.

    C. How to control and disable cookies and how to opt-out from their use

    There are different ways to manage, disable or delete cookies depending on your browser:

    Changing the settings of Your browser

    Follow the instructions given by the developer of your Internet browser to find out how to control, disable or erase some or all the cookies/technical and analytics):

    Make your choices carefully. Rejecting the technical cookie, will affect the functionality mentioned above.

    D. Further information

    CLIM collects and processes certain of your personal data through first-party cookies that are managed via the Website for their legitimate interests to guarantee the Website security. We will process your data only by electronic means, in a totally automated manner. Therefore, our employees and related entities will never access the content of your personal data obtained through cookies. Some of our employees and related entities, who we have appointed as persons in charge of the processing, may perform maintenance operations on the IT systems that host your data, without ever being able to access their actual content. Personal data may be stored on servers managed by third parties (e.g. CLIG, or a supplier of IT services), which act as external data processors.

    We recognize data privacy is an ongoing responsibility. We reserve the right to update or amend this Notice from time to time and any such updates or amendments will be reflected in the Notice available on our website.

    For further information on cookies and your specific rights please visit the web-site of the UK Data Protection Authority (Information Commissioner’s Office (ICO)) https://ico.org.uk or your resident state authority.

REGULATORY INFO

Important Information  |  Form ADV & Disclosures  |  UK Stewardship Code
Capital Requirements  |  Privacy & Cookie Policy

City of London Investment Management Company Limited (“CLIM”) is authorised and regulated for the conduct of investment business within the UK by the Financial Conduct Authority (FCA), registered as an Investment Advisor with the United States Securities and Exchange Commission (SEC) and regulated by the Dubai Financial Services Authority (DFSA).
Registered in England and Wales No. 2851236. Registered Office: 77 Gracechurch Street, London, EC3V 0AS, England.

© 2020 City of London Investment Management Company Limited.
All rights reserved.

City of London Investment Management Company Limited (“CLIM”) is authorised and regulated for the conduct of investment business within the UK by the Financial Conduct Authority (FCA), registered as an Investment Advisor with the United States Securities and Exchange Commission (SEC) and regulated by the Dubai Financial Services Authority (DFSA). Registered in England and Wales No. 2851236. Registered Office: 77 Gracechurch Street, London, EC3V 0AS, England.

© 2020 City of London Investment Management Company Limited. All rights reserved.