Privacy notice for marketing recipients

Baillie Gifford is committed to protecting the privacy and security of personal information entrusted to us. This privacy notice is intended for individuals who, in a personal capacity, request information from us in relation to our products, services, events, promotions or other marketing materials and initiatives.

This notice describes how we as a "Data Controller", collect and use personal information about you, in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. It applies to all processing of personal data relating to our marketing recipients, and supplements any other similar notices or information provided to you at the time you supply your personal data such as, when you register to attend any of our events.

This privacy notice is not intended for individuals who previously invested directly with us through our Investment Trust ISAs, Share Plans or Children’s Savings Plans. Neither is it intended for those who invest directly with us in our range of OEICs, or for our business contacts. 

• If you are a former direct investor in our Investment Trust ISAs or Plans, please see the former investors privacy notice.
• If you invest in an OEIC, please see the OEIC investors privacy notice.
• If you are a business contact, please see the business contacts privacy notice.
• If you are a candidate for recruitment, please see the candidates privacy notice.

The kind of information we hold about you

We collect, store, and use the following categories of personal information about you:

• personal details you provide such as name, email address and postal address;
• your marketing preferences and other records of your engagement with our marketing campaigns

How is your personal information collected?

We collect personal information about those who request our marketing directly from them. We will collect other information about you with your consent in order to ensure we only send you marketing that meets your needs. We may collect additional personal information in the course of our relationship as a necessity of the services being provided.

How we use information about you

We will only use your personal information when the law allows us to; this is known as a “legal basis” for processing.

Situations in which we will use your personal information

We may use your personal information to:

• communicate with you to provide you with information about Baillie Gifford products, services, events, promotions or other insights; we will only do so where you have indicated to us that you wish to receive such information;
• update your marketing preferences when you indicate that you would like us to do so via the preference centre or by contacting us directly.

Change of purpose

We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Data sharing and third party processors

We may need to share your personal data with third parties, including other entities within the Baillie Gifford group and our preferred marketing partners who help us ensure we only send you marketing material that meets your needs/requirements. We will only do so where you have indicated to us that you wish to receive such material and you may amend or cancel your preferences at any time. Where we share your personal data with another party performing services for us (not for you), we require those third parties to respect the security of your personal data and to treat it in accordance with the law.

A list of our current third party service providers is provided at the end of this notice.

When might we share your personal information with other entities in the group?

We will share your personal information with other entities in our group only in so far as necessary to provide the marketing materials you have requested from us.

Data security

We have put in place measures to protect the security of your information. Details of these measures are included in group-wide policies which cover the following:

• management and organisation of information security;
• classification of data which includes data handling rules;
• staff training on responsibilities connected to information security and data protection, and the reporting of any information security incidents;
• physical and environmental security; and
• systems security, including backups, virus protection and access controls.

Our policies and controls are based on the international standard for information security, ISO27001, to which we have been certified since 2010. We are committed to implementing, maintaining and continually improving an information security management system in accordance with that standard. Our approach supports the enhancement of information security controls and our information governance framework is overseen by our Chief Information Security Officer. That framework includes a cross functional senior management group supported by expert external advice to oversee an effective information security strategy. We also have a rigorous third party oversight programme designed to maintain the confidentiality, integrity and availability of your data when it is processed by other organisations on our behalf.

Data retention

How long will you use my information for?

We will only retain your personal information whilst it is required to provide you with marketing materials. If you have notified us that you no longer wish to receive any marketing materials from Baillie Gifford, we will delete your details after 6 months.

Rights of access, correction, erasure, and restriction

Your rights in connection with personal information

In certain circumstances, by law you have the right to:

• Request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are processing it lawfully.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

You can exercise these rights by contacting trustenquiries@bailliegifford.com

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).

Right to withdraw consent

Where you have provided your consent to the collection, processing or transfer of your personal information in order to receive marketing material from us, you have the right to withdraw that consent at any time. To do so, please contact us using the details above, or where it relates to email marketing only, using the unsubscribe link provided in all Baillie Gifford marketing emails. Once we have received notification that you have withdrawn your consent, we will no longer send you the relevant marketing materials.

Your rights under the California consumer privacy act (CCPA)

In addition to the above rights, California residents have the right to instruct a business to stop selling their personal information. Baillie Gifford does not sell your personal information in exchange for any monetary consideration. In some cases, data obtained from cookies is shared with third parties and may be considered a “sale of personal information” under the CCPA. However, Baillie Gifford disables such cookies by default and sharing will therefore only occur where you have enabled them.

Data protection officer

If you have any questions about this privacy notice, please contact trustenquiries@bailliegifford.com. If you are unhappy with how we handle your personal information, please contact the Data Protection Officer at DataProtection@bailliegifford.com. If we do not resolve your concerns to your satisfaction, you have the right to make a complaint to the Information Commissioner's Office (ICO), the U.K. data protection regulator.

Changes to this privacy notice

We may update this privacy notice from time to time and will communicate such updates through our website. We will not do so where we believe this would materially impact your rights and freedoms; in those circumstances we will expressly notify you. We may also notify you in other ways from time to time about the processing of your personal information.

Third party providers who may currently process your personal data on behalf of Baillie Gifford

Corporate Mailing Solutions (CMS) - a mailing house used to send postal mailings on Baillie Gifford’s behalf. Only personal details necessary to fulfil any postal communication will be sent to CMS.

Equinet/Cobalt Sky – services used to ensure that our email marketing campaigns do not target individuals who have previously opted out of receiving electronic marketing.

Marketo - a marketing software as a service (SaaS) platform designed to help us perform marketing tasks, including sending our marketing emails. Name, email and postal address will be stored in Marketo for this purpose.

MessagePad - a firm appointed by Baillie Gifford to take messages from clients when calls volumes are high and outwith office hours.

Salesforce - a customer relationship management database which gives us a single view of each customer. Name, email and postal address will be stored in Salesforce for this purpose.

Zoom - a videotelephony and online chat service which allows us to facilitate webinars.

Please note that the above list is subject to change.

Baillie Gifford Overseas Limited (ARBN 118 567 178) is registered as a foreign company under the Corporations Act 2001 (Cth) and holds Foreign Australian Financial Services Licence No 528911. The information in this area is provided to you on the basis that you are a “wholesale client” within the meaning of section 761G of the Corporations Act 2001 (Cth) (“Corporations Act”). Please advise Baillie Gifford Overseas Limited immediately if you are not a wholesale client. In no circumstances should the information in this area be made available to “retail clients” as defined by the Corporations Act.

The information in this area contains general information only. It does not take into account any person’s objectives, financial situation or needs.