Murray Income Trust plc (the "Company", "we", "us" or "our") is committed to protecting the privacy of individuals whose data it processes ("you" or "your").
In addition, it outlines your data protection rights under the EU General Data Protection Regulation (Regulation 2016/679) as it forms part of the laws of the United Kingdom (the "UK GDPR").
This webpage is not intended for children and we do not knowingly collect data relating to children through this webpage. Children should not access or use our webpage.
Murray Income Trust plc is incorporated in Scotland (registered number SC012725). For the purposes of data protection laws, Murray Income Trust plc is the controller of your personal data. Please contact Murray Income Trust plc by writing to us at 6th Floor, Exchange Plaza, 50 Lothian Road, Edinburgh, EH3 9BY or by email to [email protected], if you have any queries in relation to our processing of personal data.
The Company may share your personal data with third parties in connection with its business and as further detailed in this privacy notice. For example, we will share your personal data with:
• Artemis Fund Managers Limited ("Artemis"), alternative investment fund manager of the Company; and
• NSM Funds UK Limited ("NSM"), our Company Secretary.
In certain circumstances, these third parties will act as a "processor" of your personal data (where they act on the Company's behalf and on its instructions, for example to provide administrative services). In other circumstances, these third parties may process your personal data for their own purposes (e.g. to comply with laws to which they are subject) or for joint purposes with us (e.g. marketing and website analytics) and in these circumstances they will be a "controller" or “joint controller” of your personal data respectively. Details of their processing activities are in their respective privacy notices, available at artemisfunds.com/en-gb/individual/policies/privacy-notice (for Artemis) and nsm-groupprivacy-statement-november-2025.pdf (for NSM).
Details of other third parties with whom your personal data may be shared are in Section 3 of this privacy policy.
The following section of this policy sets out how the Company will process personal data relating to investors and shareholders (and potential investors and shareholders).
The kind of information we hold about you
We have grouped together the various types of data we may hold about you as follows:
We do not knowingly collect any sensitive personal data or special categories of personal data about you in your capacity as a shareholder/investor or a potential shareholder/investor of the Company (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), nor do we collect any information about criminal convictions and offences. You must not submit special category data to us. If, however, you otherwise inadvertently or intentionally transmit special category data to us, you will be considered to have explicitly consented to us processing that special category data under Article 9(2)(a) of the UK GDPR. We will use and process your special category data for the purposes of deleting it.
How we collect your personal data
We use different methods to collect data from and about you when you are a shareholder/investor (or potential shareholder/investor) including:
The types of personal data that we collect and use will depend on various circumstances, including whether you are a shareholder, investor or potential shareholder or investor. We may also process personal data about individuals that are connected with you as an investor (for example directors, trustees, employees, intermediaries, representatives, beneficiaries, shareholders, investors, clients, beneficial owners, advisers and/or agents). If you provide the Company with personal data relating to another data subject, you agree to provide that data subject with a copy of (or link to) this privacy policy.
Basis on which we process your data
We will only use your personal data as the law permits. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and the lawful bases for our processing of that personal data. We have also identified what our legitimate interests are where appropriate.
The legal bases we principally rely upon to process your personal data are these:
Where such processing is being carried out on the basis that it is necessary to pursue the Company's or a third party's legitimate interests, we will only carry out such processing if such legitimate interests are not overridden by your interests, fundamental rights or freedoms. You can find out about your right to object to our processing of your personal data when we rely on our or a third party's legitimate interests below. Such processing may include the use of your personal data (including your name and contact details) for the purposes of sending you electronic marketing communications, in relation to which you can at any time unsubscribe by following the unsubscribe instructions contained in each marketing communication (which is the most straightforward way for you to unsubscribe from receiving marketing communications). Alternatively, you can email us by contacting us at [email protected].
Where we need to collect personal data by law or under the terms of a contract to which you are a party and you fail to provide that data when requested, we may not be able to perform the contract or enter a contract with you (and accordingly may be unable to register you as a shareholder/investor, or, if you are a current shareholder/investor, allow you to exercise all of your rights in connection with your investment). We will notify you if this is the case.
Please 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 contact us at the address above if you need further information on the legal basis relied upon to process your personal data.
| PURPOSE / ACTIVITY | TYPE OF DATA | LEGAL BASIS FOR PROCESSING |
| To provide you with information on the Company (including performance updates), notifications and reminders of upcoming shareholder votes and invitations to events or meetings. Please note that we may obtain your personal data from third parties including investment platforms in order to contact you, including to identify the beneficial owners of the shares in the Company, as permitted by Section 793 of the Companies Act 2006. | Identity data Contact data Financial data | (a) Our legitimate interests of implementing our investment objectives and policies and operating, pursuing and developing our business (b) In certain circumstances, compliance with our legal and regulatory obligations |
| To manage our relationship with you, including to allow us to administer and manage, or assist the appointed registrar with their administration of, your holding in the Company (including fee calculations and any other information and the payment of dividends). | Identity data Contact data Financial data KYC data Correspondence data | (a) Performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract (b) Compliance with our legal and regulatory obligations (c) Our legitimate interests of pursuing and developing our business |
| To update and maintain records for the Company, including maintaining statutory registers. | Identity data Contact data KYC data Financial data Correspondence data | (a) Compliance with our legal and regulatory obligations (b) Our legitimate interests of ensuring effective and accurate record keeping |
| For identification purposes for the purposes of anti-money laundering checks and other actions to seek to detect, prevent, investigate and prosecute fraud and crime, comply with UK and/or international sanctions regimes, counter terrorist financing, suitability and appropriateness assessments, “Know Your Client” and credit-worthiness checks. | Identity data Contact data KYC data Financial data Correspondence data | (a) Performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract (b) Compliance with our legal and regulatory obligations (c) Our legitimate interests of the prevention of fraud, money laundering, sanctions, terrorist financing, bribery, corruption and tax evasion |
| To assist us in conducting market research. | Identity data Contact data Financial data Correspondence data | (a) Our legitimate interests of analysing trends and investigating product sales and performance |
| To prepare tax related information in order to report to tax authorities. | Identity data Contact data Financial data Correspondence data | (a) Compliance with our legal and regulatory obligations |
| To scan and monitor emails sent to us (including attachments) for viruses or malicious software, to process and encrypt personal data to protect and manage email traffic, and to store personal data on our systems. | Identity data Contact data Correspondence data | (a) Our legitimate interests of document retention and IT security (b) Compliance with our legal and regulatory obligations (including under data protection law) |
| To send you information about products, services and investments which we think may be of interest to you (including marketing communications). | Identity data Contact data Correspondence data Marketing preference data | (a) Our legitimate interests of promoting our business and related products, services and investments (for example, where you are an existing or past investor in the Company and were (and continue to be) given an option to opt-out of such communications). (b) In certain circumstances, with your consent. |
| Such other actions as are necessary to manage the activities and/or to comply with the legal obligations of the Company, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails and attachments therein) for quality control, analysis and training purposes and enforcing or defending the rights and/or interests of the Company. | Identity data Contact data KYC data Financial data Correspondence data | (a) Compliance with our legal and regulatory obligations (including under data protection law) (b) Our legitimate interests of pursuing and developing our business and monitoring email traffic (c) Performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract |
If the Company wishes to use your personal data for purposes which require your consent, you will be asked to provide this and/or we will contact you to request this. In such circumstances, we will provide you with details of the personal data that we would like to process and the reason we need to process it, so that you can carefully consider whether you wish to consent. Where you do consent and we rely on consent to process your personal data, you have the right to withdraw your consent at any time, although that will not affect the lawfulness of processing based on consent before its withdrawal. To withdraw your consent, please contact us at [email protected] or (in relation to marketing) follow the unsubscribe instructions included in each electronic marketing communications. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
The kind of information we hold about you
We may process different kinds of personal data about you which is provided to us though your use of our webpage, including by the use of cookies, server logs, pixel tags and other similar technologies. We have grouped together the various types of data we may hold about you as a webpage user as follows:
We do not knowingly collect any sensitive personal data or special categories of personal data about you through our webpage (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences through our webpage. You must not submit special category data to us. If, however, you otherwise inadvertently or intentionally transmit special category data to us, you will be considered to have explicitly consented to us processing that special category data under Article 9(2)(a) of the UK GDPR. We will use and process your special category data for the purposes of deleting it.
How we collect your data
We use different methods to collect data from and about you when you are a webpage user including:
Basis on which we process your data
We will only use your personal information as the law permits. 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.
The legal bases we principally rely upon are these:
Where such processing is being carried out on the basis that it is necessary to pursue the Company's legitimate interests, we will only carry out such processing if these legitimate interests are not overridden by your interests, fundamental rights or freedoms. You can find out about your right to object to our processing of your personal data when we rely on our or a third party's legitimate interests below. Such processing may include the use of your personal data for the purposes of sending you electronic marketing communications, in relation to which you can at any time unsubscribe by following the unsubscribe instructions contained in each marketing communication (which is the most straightforward way for you to unsubscribe from receiving marketing communications). Alternatively, you can email us by contacting us at [email protected].
Where we need to collect personal data by law or in connection with our webpage and you fail to provide that information, we may not be able to give you full access to our webpage. We will notify you if this is the case.
Please 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 contact us at the address above if you need further information on the legal basis relied upon to process your personal data.
| PURPOSE / ACTIVITY | TYPE OF DATA | LEGAL BASIS FOR PROCESSING |
To send you updates on the performance of the Company, newsletters, factsheets, invitations to events and other electronic marketing communications. | Identity data Contact data User type data Marketing preference data | (a) Our legitimate interests of pursuing and developing our business (for example, where you are an existing or past investor in the Company and were (and continue to be) given an option to opt-out of such communications); and/or (b) Your consent |
To use data analytics to improve our webpage, marketing and customer experiences. | Technical data Usage data User type data | (a) Our legitimate interests (to understand user behaviour and improve our webpage) |
To comply with legal or regulatory requirements. | Identity data Contact data Technical data User type data | (a) Compliance with our legal and regulatory obligations (including under data protection law) |
To scan and monitor emails sent to us (including attachments) for viruses or malicious software, to process and encrypt personal data to protect and manage email traffic, and to store personal data on our systems. | Identity data Contact data Technical data | (a) Our legitimate interests including for document retention purposes and IT security (b) Compliance with our legal and regulatory obligations (including under data protection law) |
Such other actions as are necessary to manage the activities of the Company, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) for quality control, analysis and training purposes and enforcing or defending the rights and/or interests of the Company. | Identity data Contact data Technical data Usage data User type data | (a) Compliance with our legal and regulatory obligations (b) Our legitimate interests (including to allow us to effectively conduct our business, process instructions, provide services and enforce or defend our rights) |
If we consider it necessary to obtain your consent in relation to the use of your personal data, you will be asked to provide this and/or we will contact you to request this consent. In such circumstances, we will provide you with details of the personal data that we would like to process and the reason we need to process it, so that you can carefully consider whether you wish to consent. Where you do consent and we rely on consent to process your personal data, you have the right to withdraw your consent at any time, although that will not affect the lawfulness of processing based on consent before its withdrawal. To withdraw your consent or to opt out of receiving marketing communications, please contact us at [email protected] or follow the unsubscribe instructions included in each electronic marketing communication. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Links to third party websites
Where our webpage provides links to other websites, the Company is not responsible for the data protection/privacy/cookie usage policies of such other websites, and you should check these policies on such other websites if you have any concerns about them. If you use one of these links to leave our webpage, you should note that we do not have any control over that other website. You should always exercise caution and review the privacy policy applicable to the website in question.
The kind of information we hold about you
We have grouped together the various types of data we may hold about business contacts of the Company as follows:
If you are a business contact of the Company, we do not knowingly collect any sensitive personal data or special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. You must not submit special category data to us. If, however, you otherwise inadvertently or intentionally transmit special category data to us, you will be considered to have explicitly consented to us processing that special category data under Article 9(2)(a) of the UK GDPR. We will use and process your special category data for the purposes of deleting it.
How we collect your data
We use different methods to collect data from and about you when you are a business contact including:
How we will use information about you
We will only use your personal information as the law permits. 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. The legal bases we principally rely upon are these:
Where such processing is being carried out on the basis that it is necessary to pursue the Company and/or a third party's legitimate interests, we will ensure that such legitimate interests are not overridden by your interests, fundamental rights or freedoms. You can find out about your right to object to our processing of your personal data when we rely on our or a third party's legitimate interests below. Such processing may include the use of your personal data (including your name and contact details) for the purposes of sending you electronic marketing communications, in relation to which you can at any time unsubscribe by following the unsubscribe instructions contained in each marketing communication (which is the most straightforward way for you to unsubscribe from receiving marketing communications). Alternatively, you can email us by contacting us at [email protected].
Where we need to collect personal data by law or under the terms of a contract to which you are a party and you fail to provide that data when requested, we may not be able to perform the contract or enter a contract with you (and accordingly may not be able to continue our relationship with you and (if you are a service provider) we may not be able to pay you). We will notify you if this is the case.
Please 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 contact us at the address above if you need further information on the legal basis relied upon to process your personal data.
| PURPOSE / ACTIVITY | TYPE OF DATA | LEGAL BASIS FOR PROCESSING |
To hold your personal data on our system and to contact you (including in connection with using the services that you provide). | Identity data Contact data Financial data Correspondence data | (a) Our legitimate interests, including in connection with using the services that you provide (b) Performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract |
In respect of suppliers, to consider appointing you and allow us to process payments and orders in respect of any goods and services provided. | Identity data Contact data Financial data Correspondence data | (a) Our legitimate interests, including in connection with using the services that you provide (b) Performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract |
To send you updates on the performance of the Company, newsletters, invitations to events and other communications. | Identity data Contact data Marketing preference data | (a) Our legitimate interests of pursuing and developing our business |
To comply with legal or regulatory requirements. | Identity data Contact data Financial data Correspondence data | (a) Compliance with our legal and regulatory obligations (including requirements to monitor our IT systems to comply with data protection law) |
To scan and monitor emails sent to us (including attachments) for viruses or malicious software, to process and encrypt personal data to protect and manage email traffic, and to store personal data on our systems. | Identity data Contact data Financial data Correspondence data | (a) Our legitimate interests including for document retention purposes and IT Security (b) Compliance with our legal and regulatory obligations (including under data protection law) |
Such other actions as are necessary to manage the activities of the Company, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) for quality control, analysis and training purposes and enforcing or defending the rights or interests of the Company. | Identity data Contact data Financial data Correspondence data | (a) Compliance with our legal and regulatory obligations (b) Our legitimate interests of pursuing and developing our business (c) Performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract |
If we consider it necessary to obtain your consent in relation to the use of your personal data, you will be asked to provide this and/or we will contact you to request this consent. In such circumstances, we will provide you with details of the personal data that we would like to process and the reason we need to process it, so that you can carefully consider whether you wish to consent. Where you do consent and we rely on consent to process your personal data, you have the right to withdraw your consent at any time, although that will not affect the lawfulness of processing based on consent before its withdrawal. To withdraw your consent or to opt out of receiving marketing communications, please contact us at [email protected] or follow the unsubscribe instructions included in each electronic marketing communication. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
We may disclose your personal data to third parties who are providing services to us, including IT service providers, payroll bureaus, pension brokers and providers, PR and marketing service providers, mailing service providers, background and/or credit reference services, recruitment agencies, processors of the Company (including printers, registrars, brokers, investment fund managers) telephone service providers, document storage and execution providers, backup and disaster recovery service providers and to healthcare brokers and providers. As detailed above, we also share your personal data with Artemis and NSM (AFIM and Company Secretary respectively).
We may also disclose personal data we hold to third parties in the following circumstances:
Where we disclose your personal data to third parties, those third parties may in certain circumstances require to process your personal data for purposes and means which they determine. For example, they may need to use your information to comply with their own legal obligations, including under antimoney laundering legislation. In those cases, the relevant service provider will be acting as a controller in respect of your personal data, and its use of your personal data will be subject to its privacy notice (which they are required by law to make available to you).
Where we transfer your personal data outside the UK or EEA we will ensure that we comply with applicable data protection law, including by ensuring that personal data is protected in a manner that is consistent with how your personal data will be protected in the UK or EEA. We usually do this by ensuring that an adequacy decision (by applicable data protection authorities) has been made in relation to the relevant recipient country, or by implementing appropriate safeguards (for example, standard contractual clauses approved by applicable data protection authorities) in relation to the transfer. Please contact us if you would like further information on the specific safeguards we use when transferring your personal data out of the UK or EEA.
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.
If you wish to exercise any of the rights set out above, please do so in writing and address this to the Company at 6th Floor, Exchange Plaza, 50 Lothian Road, Edinburgh, EH3 9BY or by email to [email protected].
You will not usually 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.
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.
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.
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 opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance. We will acknowledge complaints within 30 days and respond to them without undue delay. If you need our assistance with making a complaint, please let us know.