Privacy notice

This notice was updated on 17 September 2026.

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"). 

Important information and who we are

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. 

How we process your personal data

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: 

  • Identity data may include names, titles, dates of birth and pronoun preferences and personal identifiers such as your national insurance number and tax file number;
  • Contact data may include addresses, telephone numbers, work and personal email addresses and communication preferences (such as your marketing preferences);
  • KYC data may include copies of passports and/or driving licences and utility bills, data received in connection with anti-money laundering and/or due diligence activities (including politically exposed persons and sanctions checks) and data related to any public comments about you by statutory or regulatory authorities (including designated professional bodies);
  • Financial data may include the existence of and details of your shareholding in the Company (and whether it is direct or indirect (and details of the relevant investment platform)) and details relating to your investment activity and bank account details;
  • Marketing preference data may include details of whether you have opted-in or opted-out of receiving marketing, and details of the type of marketing you wish to receive; and
  • Correspondence data may include any other data which you provide to us in correspondence, telephone calls and/or documents (including subscription/offer documents and other forms).

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:

  • From you: we collect personal data from you directly as a result of your holding, investment and/or potential investment in the Company (including when you complete application forms and/or fundraising documents, through our webpage, telephone calls and/or corresponding with us);
  • From third parties: we may collect personal data from third parties, including investment platform(s) through which you hold shares (including to allow us to exercise our rights under section 793 of the Companies Act 2006); and other third parties such as the Company's registrar, secretary, and manager (including Artemis and NSM); and
  • From publicly available resources: we may collect your personal data from publicly available sources, such as Companies House.  

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:

  • it is necessary for the 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;
  • it is necessary for the purposes of our legitimate interests, or those of a third party, where such interests are not overridden by your rights or interests; and/or
  • it is necessary for us to comply with a legal obligation on us.

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 / ACTIVITYTYPE OF DATALEGAL 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. 

Visitors to our website

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:

  • Identity data may include names, titles, job titles, dates of birth and pronoun preferences; • Contact data may include addresses, telephone numbers, personal and work email addresses and marketing and communications preferences;
  • Technical data may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, internet server provider's domain name, browser plugin types and versions, operating system and platform and other technology on the devices you use to access this webpage;
  • Usage data includes information about how you use our webpage, products or services;
  • Marketing preference data may include details of whether you have opted-in or opted-out of receiving marketing, and details of the type of marketing you wish to receive; and
  • User type data includes information relating to the type of webpage user you are (for example, institutional investor, analyst or private investor).

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:

  • From you: direct interactions with you, including by you filling in forms. This includes personal data you provide when you subscribe to our publications and/or request marketing to be sent to you.
  • From automated technologies or interactions as you interact with our webpage, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and our cookie policy can be found at murray-income.co.uk/en-global/investors/cookies; and
  • From third parties: for example, we may collect technical data from third party analytics providers such as Google and search information providers, some of whom may be based outside of the UK and/or may process personal data outside of the UK.

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:  

  • it is necessary for the purposes of our legitimate interests, or those of a third party and where such interests are not overridden by your rights or interests; and/or
  • it is necessary for us to comply with a legal or regulatory obligation on us.

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 / ACTIVITYTYPE OF DATALEGAL 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. 

Business contacts

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:

  • Identity data may include names, titles, dates of birth and pronoun preference;
  • Contact data may include addresses, telephone numbers and personal or work email addresses;
  • Financial data may include bank account details, invoices and other financial information;
  • Marketing preference data may include details of whether you have opted-in or opted-out of receiving marketing, and details of the type of marketing you wish to receive; and
  • Correspondence data may include any other data which you provide to us in correspondence (including emails), telephone calls and/or documents.

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:

  • From you: direct interactions with you, including as a result of your contact with us, telephone calls and/or corresponding with us. We will collect personal data in the course of work-related activities (including in meetings, board meetings and through personal interaction with you);
  • From third parties: for example, credit check agencies; and
  • From publicly available resources: we may collect your personal data from publicly available sources, such as Companies House and social media.

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:

  • it is necessary for the 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;
  • it is necessary for the purposes of our legitimate interests, or those of a third party, where such interests are not overridden by your rights or interests; and/or
  • it is necessary for us to comply with a legal or regulatory obligation on us.

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 / ACTIVITYTYPE OF DATALEGAL 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. 

Disclosures of your personal data

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:

  • if you are an investor, where your shares are held through a broker, dealer, bank, custodian, trust company, financial adviser or other nominee (each a "Nominee") and it is lawful for us to do so, then details of your investments and valuations may also be provided to such Nominee;
  • to background, compliance, sanctions, shareholder register analysis and anti-money laundering check service providers;
  • to other third parties in connection with providing services to you and/or conducting our business;
  • as part of the acquisition of our business or assets, in which case we may disclose personal data we hold about you to the prospective and/or actual buyer of such business or assets; and/or
  • if we are permitted by law to disclose your personal data to a third party or are under a legal obligation to disclose your personal data to that third party. For example, we may disclose your personal data to relevant tax authorities, regulators (including the FCA), government departments or competent authorities of the UK or of other countries (such as Companies House) or make public disclosures. We may also be required to disclose your personal data in order to comply with a court order or to meet legal and regulatory requirements arising in the conduct of our business. Such disclosure may be made directly to such regulators or competent authorities or made indirectly to our advisers or providers who will make such filings or disclosures on our behalf.

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). 

Data retention

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.

International transfers

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.  

Data security

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. 

Your legal rights

  • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • 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. Please contact us if you believe that the information we hold about you is not accurate, complete or up to date.
  • 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. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • 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.
  • Withdraw your consent. If we are processing your personal data on the basis of your consent, you have the right to withdraw such consent at any time. Withdrawing your consent 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.

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. 

Changes to your data

The personal data we hold about you needs to be accurate and up-to-date in order to comply with data protection law. Please let us know of any changes to your personal data so that we can correct our records.

Changes to this privacy policy

We may update this privacy policy from time to time and will ensure that any such changes to this policy are added to the policy available on our webpage on their effective date. We may also notify you from time to time about the processing of your data. 

Further information

If you have any queries about this policy or your personal data, or you wish to submit an access request or raise a complaint about the way your personal data has been handled, please do so in writing and address this to the Company at 6th Floor, Exchange Plaza, 50 Lothian Road, Edinburgh, EH3 9BY. 

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