Privacy Policy

INDEPENDENT UCITS, (“IUP”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy ("Policy") will inform you as to how we look after your personal data that you provide or we collect when you visit www.independentucits.com (the “Site”) (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you. Please note that this privacy statement only covers this website and does not regulate the privacy practices of other websites which may be accessible through or linked to this website.

This Policy does not apply to any other data, including personal data, that we collect offline.

By accessing this Site, you acknowledge that you have read and agree to the practices described in this Policy.

Personal data is any information that enables us to identify you, either directly or indirectly in conjunction with any other information we hold, by reference to an identifier such as name, address, date of birth or government identification number.

For the purposes of the EU General Data Protection Regulation 2018 (the “GDPR”) Zennor Asset Management LLP (“Zennor”) is the controller of personal data and responsible for the Site.

WHAT IS OUR LEGAL BASIS FOR PROCESSING PERSONAL DATA?

Under Article 6 (1b) of the GDPR, the legal basis that Zennor employs for processing your personal data is that processing of your personal data is necessary for the performance of a contract to which you, the ‘data subject’ is party, or in order to take steps at your request prior to entering into such a contract.

We also process your personal data under Article 6(1f) of the GDPR where processing is necessary for the purposes of our legitimate commercial interests, except where such interests are overridden by your rights and interests.

YOUR DATA PROTECTION RIGHTS

Unless subject to an exemption under the GDPR, you may have the following rights with respect to your personal data:

• to request a copy of your personal data which Zennor holds about you;

• to request that Zennor corrects any of your personal data if it is found to be inaccurate or out of date;

• to request your personal data to be erased where it is no longer necessary for Zennor to retain such data;

• to withdraw your consent to the processing of your personal data at any time;

• to request that Zennor provides you with your personal data, and where possible, to transmit the data directly to another data controller (known as the right to data portability);

• where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

• to object to the processing of your personal data with regards to Direct Marketing;

• to lodge a complaint with an EU Data Protection Authority, such as the Information Commissioner’s Office (ICO) in the UK.

MARKETING

We would like to send you information about products and services of ours and other companies within our group which may be of interest to you. If you have consented to receive marketing, you may opt out at a later date.

You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other entities within our group. If you no longer wish to be contacted for marketing purposes, please email or write to us at the addresses provided in the ‘Contact Details’ section of this Policy.

AUTOMATED DECISION MAKING

We do not use automated decision making to segment and target product offers based on our customers’ demands and needs. For further details, you may contact our Data Protection Officer whose details are provided in the ‘Contact Details’ section of this Policy.

FURTHER PROCESSING

If we wish to use your personal data for a new purpose, not defined by this Policy, then we will provide you with a new notice explaining this new use prior to the commencement of the new processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

CHANGES TO THIS PRIVACY POLICY

We will update this Policy from time to time, so please check back periodically.

The provisions contained in this Policy supersede all previous notices or policies regarding our use personal data.

CONTACT DETAILS

To exercise all relevant rights, or to raise queries or complaints, please in the first instance contact the Data Protection Officer, Hugh Hunter.

By email: admin@prodigycapital.net

By post: The Data Protection Officer, Zennor Asset Management LLP, 86 Duke of York Square, London SW3 4LY, United Kingdom.

Last updated: 10th September 2021

cookie Policy

This Cookie Policy applies to Zennor Asset Management LLP (“Zennor”, “we”, “us” or “our”).

Like most businesses, we employ “cookies” or similar technologies. This Cookie Policy tells you about the use of Cookies and similar technologies on www.independentucits.com/ (the “Site”).

When you first access the Site from certain jurisdictions, you will receive a message advising you that cookies and similar technologies are in use. By clicking “accept cookies”, closing the message, or continuing to browse the Site, you signify that you understand and agree to the use of these technologies, as described in this Cookie Policy.

You do not have to accept cookies and consent can be withdrawn at any time (see How to Control Cookies, below). You can change your browser settings to refuse or restrict cookies, and you may delete them after they have been placed on your device at any time. If you do not accept or delete our cookies, some areas of the Site that you access may take more time to work, or may not function properly.