Rathbones - Multi Asset Portfolios

Privacy notice

“Data Protection Law” means the Data Protection Act 1998 until and including 24th May 2018, and with effect from 25th May 2018 the General Data Protection Regulation 2016 ((EU) 2016/679) and in each case any successor or delegated legislation and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK, including where applicable the guidance and codes of practice issued by the Information Commissioner, the Financial Conduct Authority, the Article 29 Working Party or relevant supervisory authority from time to time; and all applicable Law in any jurisdiction relating to the processing or protection of personal data and privacy, including where applicable, the guidance and codes of practice issued by the Information Commissioner, the Financial Conduct Authority, the Article 29 Working Party or relevant supervisory authority from time to time

This privacy policy sets out how we, EValue Limited (‘EValue’, ‘we’, ‘us’, ‘our’) will use any personal information that we collect from you, or that you provide to us, via this website (together, “personal data”). We are the ‘Data Controller’ for EValue Limited as defined under Data Protection Law and we will process your data in accordance with Data Protection Law. The purpose of this privacy policy is to inform you as a user of this website about what information we collect when you visit the service, how we use the information, whether the information is disclosed and the ways in which we protect users' privacy.

We want you to feel secure when using the website and associated services. We are committed to respecting your privacy. This is an overview of the data we collect:

Personal data collected

Navigation data

IP address and the website you came from.

Personal information

Includes your first name, last name, email address and postcode.

Analytics

Uses navigation data in services provided by EValue and third parties. For more information see our cookie policy.

Personalisation

Uses navigation data and personal information to enable us to tailor the services provided to you.

Data sharing

We may need to share personal information with trusted third parties to enable us to provide the service to you. We may also need to share your personal data with the Financial Conduct Authority, the Information Commissioner's Office or other relevant regulator in order to demonstrate that we are complying with our regulatory requirements and Data Protection Law relating to the secure processing of your personal data. Navigation data is also shared with trusted third parties to enable us to improve the service to you.

How do we use your information?

We analyse information to see what is most effective about our website and associated services to help us identify ways to improve it and to make it more effective. We may also use information for other purposes, which we would describe to you at the point when we collect the information.

If we decide to change the Privacy Policy, we will post these changes on this page so that you are always aware of the information we collect, how we use it and under what circumstances it is disclosed.

What Information do we collect when you use the EValue website?

When you use the EValue website, we use technology to collect information indirectly – such as your internet address. This is commonplace across all internet services to enable the investigation of issues such as malicious use. This information is then kept in our internet access logs.

We collect information directly from you in a number of ways. One way is by using cookies. Cookies are small files of information that save and retrieve information about your visit to our site, such as how you entered our site, how you navigated through the site and what information was of interest to you. This information is collected for a number of reasons, for example, to help develop the website and associated services.

The cookies we use identify you merely as a number. If you are uncomfortable about the use of cookies, you can disable them by changing the settings in the preferences or options menu in your internet browser. However, disabling cookies may affect our ability to provide services to you; if certain cookies are disabled you may not be able to access the functionality of the site.

See our cookie policy for more information on the cookies we use.

We also collect information when you give it to us. It is completely up to you whether you provide it, but not providing information may affect our ability to provide services to you. We will use your personal data to answer your request, for example to answer your questions. In addition, personal data may be used for management information and research. We may disclose information to our group companies and service providers for these purposes.

Information gathered by us includes the user's IP address, the web page a tool is accessed from, and how many times it is accessed. In some cases, tracking is used to show user journeys through a tool. This information is the sole property of EValue and may be shared with trusted third parties for the purposes of improving our service to you. All EValue tools store the number of times a user has visited the tool. Some tools also store ‘state’ information so that when a user returns to a tool it is in the ‘state’ they left it.

How long do we hold your personal data?

We will hold your personal data, for as long as we are required to do so under applicable law.

We will disclose your information to, or disclose it, to other trusted third parties

We do not share your personal data with other organisations unless the law permits us to do so. We do not sell individuals' information. We will share it only with our authorised Data Processors (as defined under Data Protection Law), who must act at all times on our instructions as the Data Controller under the Data Protection Act 1998. We use a third party hosting provider, The Bunker Limited, in the UK to host our software and the personal data that is stored on the software.

We may give you access to your information

You are entitled to know whether we hold information about you and, if we do, to have access to that information and require it to be corrected if it is inaccurate.

You can do this by contacting Data Protection Officer, EValue Limited, Benyon House, Newbury Business Park, London Road, Newbury RG14 2PZ.

Your data is kept under secure conditions

We take appropriate steps to maintain the security of your data on our service. The open nature of the internet means that data may flow over networks without security measures and may be accessed and used by people other than those for whom the data is intended. Our intention is that this should not happen and we take measures to ensure that it does not. However, we cannot guarantee the security of any information transmitted via the internet and cannot be held responsible for any damages you, or others, may suffer as a result of the loss of confidentiality or such information.

Changes to our Privacy Policy

All changes to this Privacy Policy will be posted here. Please visit this page regularly to stay up to date. This policy was last amended on 1st February 2018.

A cookie is a little text file composed of alphanumeric characters, which is created on your computer when your browser accesses a website that uses cookies. These cookies are used to help your browser navigate our website and fully use all its features like interacting with the website or viewing videos.

When someone visits our website we collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of our website. We collect this information in a way which does not identify anyone.

We use Google Analytics to help analyse use of our website. This analytical tool uses ‘cookies’, which are text files placed on your computer, to collect standard internet log information and visitor behaviour information in an anonymous form. The information generated by the cookie about your use of the website (including your IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of the website and to compile statistical reports on website activity.

We will not (and will not allow any third party) to use the statistical analytics tool to track or to collect any personally identifiable information of visitors to our site. We will not associate any data gathered from this site with any personally identifying information from any source as part of our use of the Google statistical analytics tool. Google will not associate your IP address with any other data held by Google. Neither we nor Google will link, or seek to link, an IP address with the identity of a computer user.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

Cookies are also used for social media interactions on our website. There may be times when you may wish to use social media in order to make other people who use social networking sites aware of various information which may be contained on our website. The information on these social media cookies help keep a track of what information you have shared out on your chosen social media site.

Our site contains videos which promote our products, these videos are hosted on YouTube. YouTube places cookies on your computer in order to analyse which videos have been viewed by yourselves.

For more information about cookies including how to disable them via your web browser please visit www.allaboutcookies.org or ico.org.uk.

If we do want to collect personally identifiable information through our website, we will be upfront about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

Contacting us about this Policy

If you have a query or complaint about our policy on cookies or about the site, please contact us.

This Acceptable Use Policy is incorporated by reference into the Customer's Agreement with EValue. It governs how the Customer (on its own behalf and on behalf of its group companies) and (where appropriate) the Customer User Community, sub-licensees, anyone accessing EValue's products or services with the Customer's permission, or as a result of the Customer assisting another person in an activity that would violate this AUP if performed by the Customer.

1. In relation to APIs:
   1. Only the designated “endpoint-healthcheck” API shall be used by the Customer to monitor the availability of the API endpoints. This can be called at a maximum rate of 1 call per minute.
   2. Load testing of the Customer's own systems that call API's is acceptable up to the Customer's agreed credit/call allowances.
   3. The Customer must not exceed a maximum of 20 simultaneous calls/requests per second.
2. Prohibited Use:
   As a condition of use of EValue's Product or Services, the Customer agrees not to use the Services or access the Products nor permit them to be used:
   1. for direct stress testing and load testing of the API endpoints (subject to paragraph 1a. above;
   2. for the purposes of caching or storing results of the APIs for longer than 24 hours in order to use those results on different days for different forecasts (for the avoidance of doubt, the Customer shall be permitted to store or cache the results of APIs for audit trail and regulatory purposes);
   3. for enumerating all possible inputs;
   4. for exhaustively calling the APIs for the purposes of extracting the underlying data;
   5. for purposes of promoting unsolicited advertising or sending spam;
   6. to simulate communications from EValue or another service or entity in order to collect identity information, authentication credentials, or other information (‘phishing’);
   7. in any manner that disrupts the operations, business, equipment, websites or systems of the Supplier or any other person or entity (including any denial of service and similar attacks) including excessive use of shared system resources;
   8. to promote any unlawful activity;
   9. in violation of export laws, controls, regulations or sanction policies of the United States or the Customer's applicable jurisdiction;
   10. to represent or suggest that EValue endorses any other business, product or service unless the Supplier has separately agreed to do so in writing;
   11. in any manner which may impair any other person's use of EValue's Products or use of any other services provided by EValue to any other person;
   12. in any manner to probe, scan, penetrate or test the vulnerability of EValue's system or network;
   13. to attempt to circumvent any authentication measures, security controls or mechanisms, whether by passive or intrusive techniques;
   14. to attempt to circumvent any password or user authentication methods of any person; or
   15. in any manner inconsistent with the Supplier's instructions or other instructions provided by the Supplier from time to time.
3. Operating System End of Life (“EOL”)
   The Customer is at risk at being exposed to unknown and unpreventable vulnerabilities by using the EOL operating system or software. The Customer may and should not utilize an operating system platform or software which has been declared by EValue to be End of Life (EOL). An EOL declaration is regarded as a safequard to the Customer which means that no further changes to the platform will be made, the support for the platform will end, there will be no new releases or patches created, there will be no testing being conducted after the EOL date, and there will be no technical support provided by EValue.
4. Cooperation with Investigations and Legal Proceeding
   1. If EValue is legally required to permit any relevant authority to inspect the Customer's content or traffic, the Customer agrees it can do so, provided however that, where possible without breaching any legal or regulatory requirement, EValue shall give the Customer reasonable prior notice of such requirement.
   2. EValue may, without notice to the Customer, report to the appropriate authorities any conduct by the Customer that it believes violates applicable law, and provide any information it has about the Customer, or its users or traffic and cooperate in response to a formal request from a law enforcement or regulatory agency investigating any such activity, or in response to a formal request in a civil action that on its face meets the requirements for such a request.
5. Right to Suspend
   EValue's right to suspend or terminate access to its Products applies even if a breach is committed unintentionally or without the Customer's authorisation, including through a Trojan horse or virus.
6. Changes to the AUP
   1. EValue may amend the AUP from time to time to advise of further reasonable restrictions and/or enhancements on the Customer's use of EValue's API's or Software. A revised version of the AUP will be published at https://www.ev.uk or in the event of a material adverse change to the AUP, EValue will provide the Customer with thirty (30) days written notice.
   2. The revised AUP will become effective on the first to occur of: (i) the Customer's execution of a new or additional order that incorporates the revised AUP by reference, (ii) the first day of a renewal term for an Order that begins at least thirty (30) days after the time that the revised AUP has been posted, or (iii) thirty (30) days following EValue's written notice to the Customer of a material change to the AUP.
   3. If for any reason, the revised AUP would adversely affect the Customer's use of the API's and Software, the Customer may terminate its Agreement with EValue by giving EValue written notice of its objection no later than thirty (30) days following the date that the revised AUP would otherwise have become effective as to the Customer. On these grounds, EValue will not charge the Customer an early termination fee. If the Customer wishes to continue using the API's or Software for up to an additional ninety (90) days, EValue will not enforce the revision as to the Customer during this time. The Customer will continue to be subject to the prior version. If the Customer chooses to terminate its Agreement, EValue may decide to waive that change as to its Customer and keep the Customer's Agreement in place for the remainder of the term.

1. Introduction

EValue Limited (“EValue”) is the UK's market leader in the provision of digital, personal finance advice products and services. These products combine expert actuarial knowledge, pioneering asset modelling and risk management. Primarily they are used in the UK by banks, product providers, advisers and employers (“Third Parties”) to enable them and their customers/employees to understand and make complex, individual, personal financial decisions.

EValue's software solutions cover all financial planning needs with versions for use by consumers and advisers. What's more, because all EValue's products are built on a single Planning & Advice Engine, all versions of our tools are entirely compatible, enabling both advisers and consumers to work together on financial plans.

2. Policy Statement

EValue is committed to ensuring a high standard of ethical and environmental trade practices. The ethical and environmental code of conduct (“Code”) outlines EValue's approach on conducting business honestly and with integrity.

3. Scope

The Code defines a minimum standard of requirement for all Third Parties and its employees to respect and adhere to when conducting business with EValue. The Code aids the continued implementation of EValue's commitment to its responsibility to disseminate, educate and exercise diligence in verifying compliance with its Third Parties and its employees. If the Third Parties do not comply with the Code, EValue will take necessary steps to review the contract which may lead to termination. The Code sets forth EValue's expectations of its Third Parties and employees which is divided into four essential areas of business.

4. Essential areas

4.1 Economic

Economic sustainability within EValue is used to define strategies that promote the allocation and utilization of resources in the most efficient, fair and responsible way providing long term benefits for the company. This area focuses on attaining economic benefit for employees, communities and investors therefore:

• Third Parties and employees must engage in ethical business conduct and fair dealing.
• Third Parties and employees must comply with national and international sanctions policy and legislation.
• Third Parties and employees must be aware and ensure that they have policies in place to stop money laundering, fraud, bribery and corruption.
• Third Parties and employees must ensure that they abide to the basic principles of the Code of Business Standards in adherence to UK laws and legislation.
• Third Parties and employees must abide by lawful payment policies to their own Third Parties and employees.

4.2 Social

Social sustainability focuses on EValue having an obligation to act ethically and with sensitivity towards social, cultural, economic and environmental issues for the benefit of its company employees and Third Parties. EValue is committed to improving human rights hence:

• Third Parties and employees must comply with all relevant legislation in the communities that they operate in.
• Third Parties and employees must engage in due diligence procedures and provide to EValue their implemented due diligence procedures.
• Third Parties must provide a safe work environment where health and safety are adhered with and managed accordingly.
• Third Parties must ensure that there are no unauthorised deductions and wage levels are in accordance with the industry standards.
• Third Parties need to ensure that employees normal and overtime working hours are in accordance with industry standards.
• Third Parties and employees must ensure that they practice non-discrimination against any person on social, religious, disability, gender and ethnic grounds as well as any protected class ensuring equal opportunities.
• Third Parties and employees must abide by the international human rights law currently recognised as national law in the United Kingdom.
• Third Parties and employees must ensure that they abide by grievance and disciplinary procedures preventing any physical, mental or verbal abuse.
• Third Parties and employees must not engage in any type of forced and bonded labour and slavery.
• Third Parties and employees must not support any form of human trafficking.
• Third Parties and employees must ensure that local and migrant employees have the right to leave employment freely.
• Third Parties and employees must never engage in using child labour and adhere to policies that govern the limitation of work by young workers.
• Third Parties and employees must ensure that their business dealings are not based on personal interests and relationships.

4.3 Technological

Technological sustainability focuses on EValue implementing sustainability with reuse and recycling, energy efficiencies, reduction in pollution, minimizing long term impact on the environment and providing adequate security levels against data loss hence:

• Third Parties and employees must ensure that that they can make use of reliable technical systems that are efficient, renewable and reusable.
• Third Parties and employees must ensure that they engage in recycling too minimise waste and create efficient use of resources.
• Third Parties and employees must ensure that they have stringent policies and procedures to ensure safety against security risks such as cyber intrusion, loss of privacy and open source software in adherence to their IT policy.
• Third Parties and employees must ensure that they develop safe digital technology which do not harm humans.
• Third Parties and employees must ensure that all employees are adequately trained to build long term viability considerations.

4.4 Environmental

Environmental sustainability focuses on EValue making responsible decisions that will reduce or eradicate the negative impact on the environment in which they operate hence:

• Third Parties and employees must have a written and sustainable environmental policy which addresses the prevention and/or mitigation of serious environmental harm and reduction in wastage of resources.
• Third Parties and employees must ensure that they abide by all environmental regulation and legislation in protecting the environment.
• Third Parties and employees must ensure that all employees are adequately trained and are aware of the environmental impacts of their work and activities and implement a meaningful environmental action plan to measure this progress.