Data Protection Privacy Policy

This Privacy Policy (the Policy) describes how the GWM Group collects, uses and shares the personal information you provide to us and the information we collect in the course of operating our business and our website.

In this Policy when we refer to the “GWM Group” or “GWM” or “we”/“us”/“our” we mean GWM Group Holding SA and our subsidiaries and also other companies and entities that are associated with us. Our registered office is at 31, Grand rue, L-1661 Luxembourg, Grand Duchy of Luxembourg.

We may revise this Policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you.

This Policy describes:

• the information that we collect;
• how we use the information we collect;
• how we share information with third parties;
• how long we keep your information;
• your choices and rights;
• how we use cookies;
• how to contact us.

The information that we collect and where we get it from
"Personal information" is any information that can be used to identify you or that we can link to you and which we have in our possession or control. We will collect and process the following personal information about you:

Information that you provide to us
We will process personal information that you give to us including when you email us or contact us through various channels as follows:

• Our products or services: when you contact us with queries or respond to our communications relating to our investment products or services the personal information you provide may include your full name, title, telephone number, email address and content, date and time of your email correspondence and information about your employer or your business.

• As a client: if you are a client of GWM you will provide us with personal information when you or the company you represent becomes a client. If you are not a client, we may collect or receive your personal information because you provide services to or are otherwise connected to one of our clients.

• Recruitment application: when you apply for a role with us you may provide us with your full name, date of birth, nationality, education and qualification details, your gender, your CV, photograph, passport details, marital status, home address and home telephone number, mobile telephone number and other details set out in your application.

Information we otherwise collect about you
We may also collect information about you when you otherwise interact or correspond with us. We use various technologies to collect and store information when you visit our website. We may, for example, collect information about the type of device you use to access our website, your IP address and your geographic location, the operating system and version, your browser type, the content you view and features you access on our websites, the web pages and the search terms you enter on our website.

Information we obtain from other sources
• If you apply for a position with us we may collect personal information relating to your past employment, qualifications and education, opinions from third parties about you, past employment history and other details about you, which will be provided to us by a third party that provides background screening services to us.

• If we collect or receive your personal information in the context of our provision of investment products and services we might receive information from third parties such as your employer, other parties relevant to the products or services we are providing (e.g. our counterparties or your advisers or other service providers) and others such as regulators and authorities. That information could include your name, contact details, employment details and other information relevant to the products or services that we are providing to our client.

How we use the information we collect
We may do the following with your personal information:

• use it to provide investment products or services to the relevant client;
• use it to engage in marketing and business development activity in relation to our investment products and services, including sending you investment reports, newsletters, marketing communications and other information that may be of interest to you;
• where you have applied for a position with us, to review and process your job application;
• to comply with legal and regulatory obligations that we have to discharge;
• use it to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
• record and monitor your use of our website or our other online services for our business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports;
• use it for our legitimate business interests, such as managing the operation and promotion of our business;
• use it to look into any complaints or queries you may have;
• use it to prevent and respond to actual or potential fraud or illegal activities.

Also, we may collate, process and share any statistics based on an aggregation of information held by us provided that any individual is not identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.

Grounds for using your personal information
We rely on the following legal grounds to process your personal information, namely:

• Consent - we may (but usually do not) need your consent to use your personal information. You can withdraw your consent by contacting us (see below).
• Performance of a contract - we may need to collect and use your personal information to enter into a contract with you or to perform our obligations under a contract with you.
• Legitimate interest - we may use your personal information for our legitimate interests, some examples of which are given above.
• Compliance with law or regulation - we may use your personal information as necessary to comply with applicable law/regulation.

How we share information with third parties
We share personal information with our subsidiaries and the various companies and entities that are associated with us. As a result, your personal information may be transferred to locations outside Europe as well as within it for the purposes described above.

We may also share your personal information outside GWM. This may include:

• third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Policy. This may include, but is not limited to, IT and communications service providers and providers of external payroll services;
• third parties relevant to the investment products and services that we provide. This may include, but is not limited to, counterparties, professional service providers, regulators, authorities, governmental institutions and stock exchanges;
• to the extent required by law, regulation or court order, for example, if we are under a duty to disclose your personal information in order to comply with any legal obligation.

In other circumstances, the law may permit us to otherwise transfer your personal information outside Europe. In all cases, however, any transfer of your personal information will be compliant with applicable data protection law.

How long we keep your information
We may also share your personal information outside GWM. This may include:

• the purpose for which we are using your personal information - we will need to keep the information for as long as is necessary for the relevant purpose;
• legal obligations - laws or regulation may set a minimum period for which we have to keep your personal information.

We will ensure that the personal information that we hold is subject to appropriate security measures.

Your choices and rights
You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us using the details set out below.

These rights include:

• Obtaining information regarding the processing of your personal information and access to the personal information which we hold about you.
• Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information.
• Requesting that we correct your personal information if it is inaccurate or incomplete.
• Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information, but we are legally entitled to retain it.
• Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request.
• In some circumstances, receiving some personal information in a structured, commonly used and machine-readable format and/or requesting that we transmit that information to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided to us.
• Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.
• Lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us.
• We can, on request, tell you which data protection authority is relevant to the processing of your personal information.

Cookies
Information on our policy in relation to cookies can be found in the Terms and Conditions section of our website: www.gwmholding.com.

How to contact us
If you would like further information on the collection, use, disclosure, transfer or processing of your personal information or the exercise of any of the rights listed above, please contact us. You can do this by writing to us at: privacy@gwmholding.com.

I Agree

Terms and Conditions

The terms and conditions of use below apply to each of the pages of this website (collectively, the "Site").

Please read these terms and conditions of use carefully before using this Site.

By using this Site, you signify your agreement with the following terms and conditions of use without limitation or qualification. References in this Site to the "GWM Group" are to GWM Group Holding SA and its affiliates, including GWM Asset Management Limited and GWM Capital Advisors LLP. We may at any time revise these terms and conditions by updating this posting. You are bound by any such revisions and should therefore periodically visit this page to review the then-current terms and conditions of use to which you are bound.

Subsidiaries and affiliates of GWM Group include but are not limited to the following regulated entities:

• GWM Asset Management Ltd. is an alternative investment fund manager regulated by the Malta Financial Services Authority and is authorized to conduct business with professional clients (including collective investment schemes);
• GWM Capital Advisors LLP is regulated in the UK by the Financial Conduct Authority (the “FCA”) and is authorised to conduct investment advisory business with or for professional clients or eligible counterparties.

Not an offer of advisory services or securities
This Site is limited to the dissemination of general information about the services provided by GWM Group. This Site and the information contained herein do not constitute and should not be construed as an offering of advisory services, or an offer to sell or solicitation to buy, any securities or related financial instruments in any jurisdiction. Responses to any inquiry that may involve the rendering of personalized investment advice or effecting or attempting to effect transactions in securities will not be made absent compliance with applicable laws or regulations (including broker dealer, investment adviser or applicable agent or representative registration requirements), or applicable exemptions or exclusions therefrom.

Jurisdictional Issues
GWM Group makes no representation that material in or accessible through the Site is appropriate or available for use in all jurisdictions or that access to them wherever their content is located is not illegal and prohibited. Those who choose to access the Site from other locations do so on their own initiative and are responsible for establishing the legality, usability and correctness of any information or materials under any or all jurisdictions and the compliance of that information or material with local laws, if and to the extent local laws are applicable. The information provided in or accessible through the Site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject GWM Group to any registration or other requirement within such jurisdiction or country.

Restrictions on use of materials
Except as otherwise permitted by GWM Group, no materials from www.gwmholding.com or any website owned, operated, licensed or controlled by GWM Group may be copied, reproduced, republished, uploaded, posted, transmitted or distributed in any way. You may download material displayed on this website for non-commercial, personal use only, provided you also retain all copyright and other proprietary notices contained on the materials. You may not distribute, modify, transmit, reuse, report or use the content of this Site for public or commercial purposes, including the text, images, audio and video, without GWM Group’s prior written permission.

Trademarks and copyrights
This Site and all its content including, all trademarks, service marks, trade names, logos, and icons are proprietary to GWM Group. Nothing contained on the Site should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any trademark displayed on this Site without the prior written permission of GWM Group or such third party that may own the trademarks displayed on this Site. Your use of the trademarks displayed on this Site, or any other content on this Site, except as provided herein, is strictly prohibited.

Images displayed on this Site are either the property of, or used with permission by, GWM Group. The use of these images by you, or anyone else authorised by you, is prohibited unless specifically permitted herein. Any unauthorised use of the images may violate copyright laws, trademark laws, the laws of privacy and publicity, and communications regulations and statutes.

Login I.D. and passwords
Access to specific areas of this Site may require the usage of a Login I.D. and associated password. If you have a Login I.D. and password, you are responsible for the activities which occur in connection with their usage and as such should take steps to protect them from misuse. If you become aware of any unauthorised use of, loss or theft of your Login I.D. and password, immediately inform a representative of GWM Group.

Links to other websites
This Site may contain links to other websites. GWM Group does not review or monitor any websites linked from or to the Site and will not be responsible for the content of any such linked website. If you decide to access the linked website, you do so at your own risk. GWM Group is not responsible for the information, materials or services obtained on or from such other websites and will not be liable in any respect for any damages arising from your access of such websites. Any such links are provided merely for the convenience of the users of the Site and the inclusion of the links does not imply any endorsement, representation or warranty by GWM Group with respect to any such website or the content or services contained through such websites. Furthermore, you agree not to link any websites to this Site without the express prior written consent of GWM Group.

Disclaimers
GWM Group makes no warranties or representations as to the accuracy of this Site. Under no circumstances shall GWM Group or any party involved in creating, producing, or delivering the Site be liable for any direct, incidental, consequential, indirect, or punitive damages that result from the use of, or the inability to use, the materials on this Site, even if an GWM Group authorised representative has been advised of the possibility of such damages. Applicable law may not allow the limitation or exclusion of liability or incidental or consequential damages, so the above limitation or exclusion may not apply to you.

GWM Group also assumes no responsibility, and shall not be liable for, any damages to, or viruses that may infect, your computer equipment or other property on account of your access to, use of, or browsing in this Site or your downloading of any materials, data, text, images, video, or audio from this Site.

WITHOUT LIMITING THE FOREGOING OR ANYTHING ELSE SET FORTH HEREIN, THE SITE AND ALL OF ITS CONTENTS ARE MADE AVAILABLE BY GWM GROUP "AS IS," WITH ALL FAULTS, AND WITHOUT ANY WARRANTIES WHATSOEVER, EXPRESS OR IMPLIED. ALL WARRANTIES, INCLUDING BUT NOT LIMITED TO ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR ANY PARTICULAR PURPOSE, NON-INFRINGEMENT, TITLE, UNINTERRUPTED USE, QUIET ENJOYMENT, SYSTEM INTEGRATION, OR ACCURACY, SECURITY OF INFORMATION, OR RELIABILITY, ARE SPECIFICALLY EXCLUDED AND DISCLAIMED. GWM GROUP MAKES NO WARRANTY THAT THE SITE, IN WHOLE OR IN PART, WILL MEET USERS’ REQUIREMENTS. USERS OF THE SITE ASSUME ALL RISK AS TO THE QUALITY, ACCURACY, SUITABILITY, AVAILABILITY AND PERFORMANCE OF THE SITE AND ITS CONTENTS AND ACKNOWLEDGE THAT THE SITE AND ITS CONTENTS MAY BE REVISED, ALTERED AND CHANGED FROM TIME TO TIME IN THE SOLE DISCRETION OF GWM GROUP. GWM GROUP DOES NOT REPRESENT OR WARRANT THAT ANY SITE CONTENT WILL OPERATE CONTINUOUSLY OR WILL BE UNINTERRUPTED OR ERROR-FREE, OR THAT ANY DEFECTS WILL BE CORRECTED, OR THAT THIS SITE OR ANY SITE REFERRED OR LINKED TO IT IS FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS.

Indemnification
You agree to defend, indemnify and hold GWM Group and its directors, officers, members, partners, principals, employees, agents and representatives harmless from any and all claims, liabilities, costs and expenses, including, without limitation, reasonable attorneys' fees, arising in any way from (i) your use of the Site, in whole or in part, or (ii) your breach or violation of law or any provisions contained herein. We reserve the right, at our own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, and in such case, you agree to cooperate with any such defence.

Integration and severability
If any provision of these terms and conditions of use is found to be invalid, unlawful, void or for any reason unenforceable then that provision shall be deemed severable from these terms and conditions of use and shall not affect the validity and enforceability of any remaining provisions. These terms and conditions of use represent and constitute the entire agreement between GWM Group and you relating to the subject matter discussed herein.

Cookie policy
If you choose to use this site without blocking or disabling cookies or opting out of other technologies, you will indicate your consent to our use of these cookies. If you do not consent to the use of these technologies, please be sure to block or disable them using your browser settings.

What are cookies?
Cookies are small text files that are placed on your computer by websites that you visit. These text files can be read by these websites and help to identify you when you return to a website. Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your computer when you have gone offline, while session cookies are deleted as soon as you close your web browser.

Which cookies do we use?
We use Google Maps cookies for the creation and the operation of dynamic maps. The content and the creation of Google Maps cookies are not directly controllable, as well as the inclusion of automatically generated dynamic maps within some of the Site’s pages. Through Google Maps, Google may use cookies to collect information and preferences for this service.
For more information about cookies from Google, please see their Privacy Policy available at: http://www.google.com/intl/it/policies/privacy

Disabling cookies
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Below are links to the 'Help' pages of major browsers which explain how you can do this. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site or any other websites that you visit.

Chrome
Internet Explorer
Mozilla Firefox
Opera
Safari