Legal

This Website Does Not Provide Investment Advice

We are offering no financial or other professional advice on this site. We are not liable for any damages however arising from the use of or inability to use this site, or any material contained in it, or from any action or decision taken as a result of using this site or any such material.

Privacy Policy

Introduction

ICM Investment Management Limited ("ICMIM") respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). This policy will tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how ICMIM collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our news announcements AND/OR fill out a contact form].

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice 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 notice supplements the other notices and is not intended to override them.

Controller

ICMIM is the controller and responsible for your personal data (collectively referred to as ICMIM, the “Company”, "we", "us" or "our" in this privacy notice).

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

Our full details are:
ICM Investment Management Limited
Ridgecourt
The Ridge
Epsom
Surrey, KT18 7EP

For data protection related queries, please contact: shaun.sangster[at]icmim.limited

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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.

Changes to the privacy notice and your duty to inform us of changes

We may change this policy by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective 25 May 2018.

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.

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

We have then grouped together the data types within these categories as follows:
Identity Data includes first name and last name.
Contact Data includes company name and email address.
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 this website.
Profile Data includes your username or similar identifier and password, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Communications Data includes all communications we have with you whether by email, post, phone or otherwise.

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 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 notice.

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 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.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  ◦ apply for our products
  ◦ create an account on our website;
  ◦ subscribe to our service or publications;
  ◦ request marketing to be sent to you; or
  ◦ give us some feedback.
Automated technologies or interactions. As 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, server logs and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below.
  ◦ Technical Data from the following parties:
    a. Analytics, storage, tools and media providers based in and outside the EU;
    b. IP tracking service providers based within the EU;
    c. automated quality control tools based within the EU;
    d. automated security and compliance tools based outside the EU;
    e. social media and media networks such as Twitter, LinkedIn, Instagram, YouTube and Vimeo based outside the EU; and
    f. email distribution and survey providers based outside the EU;
• Identity and Contact data from providers of data feeds and hosting services provided inside the EU and outside of the EU.

4. How we use your personal data

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 a service for you.
• 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.
• Where we need to comply with a legal or regulatory obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

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 contacting 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 below.

1. To register you as a new customer

Type of data
(a) Identity
(b) Contact

Lawful basis for processing including basis of legitimate interest

Performance of a contract with you

2. To process and provide a service to you

This includes:
(a) Managing payments, fees and charges
(b) Collecting and recovering money owed to us

Type of data
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)

3. To manage our relationship with you

This includes:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(c) Answering any queries you may have

Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
(d) To deal with your enquiries

4. To administer and protect our business and this website

This includes troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data

Type of data
(a) Identity
(b) Contact
(c) Technical

Lawful basis for processing including basis of legitimate interest
(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 obligation

5. To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data
(a) Technical
(b) Usage

Lawful basis for processing including basis of legitimate interest
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)

6. To provide regulatory news via an automated email alert service

Type of data
(a) Identity
(b) Contact

Lawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests and as you have requested to receive RNS announcements

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and communications. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, purchased goods or services from us or expressed an interest in our products and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside of the ICM and ICMIM group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or experience or other transactions.

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 information to the owners of the site about aspects of your visit. 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. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. For more information about the cookies we use, please see our cookie policy.

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 contacting 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.

5. 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 section 4 above.
• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• 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 notice.

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.

6. International transfers

Wherever possible we do not transfer your personal data outside the European Economic Area (EEA).

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data may sometimes involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, 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 by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contacting us if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. 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.

8. Data retention

How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 from us by contacting us. In some circumstances you can ask us to delete your data: see Request erasure 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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

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

10. Glossary

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
Other companies in the ICM Group acting as processors and co-controllers and who are based in South Africa, Ireland, Singapore, Australia, New Zealand and Bermuda and provide IT AND/OR system administration services.

External Third Parties
• Digital service providers acting as processors, operating in the EU, who provide a number of services, including but restricted to data feeds, hosting, SSL, data analysis, CRM, video streaming, social media and sharing services.
• Professional advisers [acting as processors AND/OR joint controllers] including lawyers, bankers, auditors and insurers based South Africa, Ireland, Singapore, Australia, New Zealand and Bermuda who provide [consultancy, banking, legal, insurance and accounting services].
• HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Marketing services providers acting as processors including mailing and survey companies operating in and outside of the EU who provide distribution, reporting and analysis of emails and surveys.

YOUR LEGAL RIGHTS

You have the right to:

Request access 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
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
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
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
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; or (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
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
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.

Links to Other Sites

This website may include links to third-party websites, plug-ins and applications or store cookie files on your computer in order to deliver its service(s). Clicking on those links or enabling those connections may allow third parties to collect, store 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 notice of every website you visit.

Cookie Policy

Introduction

ICM Investment Management Limited ("ICMIM") respects your privacy and is committed to protecting your personal data. This cookie notice will inform you as to how and what cookies are used on this site.

For details about your privacy rights and how the law protects you please see our privacy policy.

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 information to the owners of the site about aspects of your visit. 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. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

Use of cookies by this website
The information below details cookie files that may be used within this website.

Anonymous analytics cookies
Each time a user visits our website, external software generates “anonymous analytics cookies” which can tell us whether or not you have visited the site before. Your browser will tell us if you have these cookies and if you do not, we generate new ones.

This allows us to track how many individual users we have and how often they visit the site. We are unable to use these cookies to identify individuals. We use them to gather statistics, for example the number of visits to a page or how long a user stays on the page.

Site performance cookies
This type of cookie remembers your preferences for tools used within our website, so you do not have to reset them each time you visit. Examples include:
• Disclaimers or notifications which require input (accept or decline).
• Filtering options for archives, news, case studies, etc.
• Video/audio streaming speeds that are compatible with your browser.

Third-party cookies
On some pages of our website, other organisations may also set their own anonymous cookies. They do this to track the success of their application, or to customise the application for you. Because of how cookies work, our website cannot access these cookies, nor can the other organisations access the data in cookies we use on our website.

For example, when you submit data through a website form or survey your data may be sent to an external third-party system. This could include a customer relationship management (CRM) system, social media networks or a careers application.

Accessibility

ICM Investment Management Limited ("ICMIM") seeks to make its website as accessible as possible and has built the site with the following in mind:
• the web pages are designed to be viewed on a wide range of screen resolutions;
• you can vary the text size by using your browser's text resize option (usually View > Text size);
• all images have been given descriptive alternative text tags;
• we have used text and background colour combinations that are sufficient in contrast;
• the page structure is easy to navigate by using a clear and user-friendly menu that is visible on each page of the site and uses HTML headings;
• Cascading Style Sheets control the presentation of pages and we have used properly structured mark-up for content. If style sheets are not supported or are turned off, information on the site can still be accessed and read;
• the use of JavaScript has been kept to a minimum. Where it is used then all pages are still accessible should JavaScript be turned off;
• all forms and fields follow a logical tab sequence to ensure easy navigation; and
• a sitemap is available to provide information about the layout of the website.

We believe that this website meets the requirements of the level 1 and 2 criteria of the World Wide Web Consortium Web Accessibility Initiative (WCAG WAI) 2.0 guidelines. We strive to meet level 3 whenever possible and we adhere to the accepted standards for accessibility and usability whenever we can, although it is not always possible to do so in all areas of the website, especially where guidelines are still evolving. We continue to review our solutions in line with updates to accepted accessibility guidelines and standards.

If you find a part of our site that is difficult to use please contact us so that we can continue to improve our overall accessibility. Alternatively, the following tips may be useful:

The text is too small for me to read – how can I change it?
If you are using a desktop PC, then follow these simple instructions:
• Mozilla Firefox: Go to View in your browser and select Zoom, select Zoom Text Only, then select Zoom In.
• Internet Explorer: Go to View in your browser and then select Text Size and select the size you require from the drop-down list.
• Google Chrome: Go to Options (denoted by a vertical line of three dots in the top right of the browser) and select Zoom and the percentage you require.

If you are using an Apple Mac, then follow these simple instructions:
• Mozilla Firefox: Go to the View menu, then Text size and select Increase/decrease text size.
• Internet Explorer: Go to the View menu and select Text zoom (or Text size). You can increase or decrease your font size by clicking on larger and smaller or by using the percentage range given.
• Safari: Go to the View menu and select Zoom in.

To reset your zoom setting most browsers accept the Ctrl + 0 command.

The mouse is difficult to use – how can I get around the website?
You can navigate your way to selected areas of our site using your keyboard. You can use the arrow keys to help you with scrolling up and down a page. You can also move up and down pages by using the Page Up and Page Down keys. Using the Home and End keys will take you to the top and bottom of pages, respectively. You may also use the Tab key to jump between links on a page.

I cannot download or view certain documents from the website – how can I get them?
Some documents require specific programs installed on your computer in order to view them. For example .pdf documents require the Adobe Reader program which you can download from www.adobe.com.

If you are unable to open or view documents using the following files types then you may require Microsoft Office products or an update to your software package:
• .docx (Microsoft Word)
• .xslx (Microsoft Excel)
• .pptx (Microsoft PowerPoint)

The Microsoft Office suite or individual readers are available to purchase here: office.microsoft.com.

Which web browsers are best for viewing the website?
This website is designed to function on the most up-to-date version of the following desktop browsers:
• Firefox
• Chrome
• Internet Explorer 11.0+
• Safari

To check if you are running the latest browser version please visit www.browsehappy.com.

Useful links
To learn more about web accessibility visit:
w3.org/wai – W3C accessibility guidelines
www.rnib.org.uk– The Royal National Institute for the Blind
www.legislation.gov.uk/ukpga/2005/13/contents – The Disability Discrimination Act 2005 (DDA)

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