Privacy Policy

1. Introduction

FINANCE AND INDUSTRIAL TRUST appreciates your interest in our products and services. Your privacy is important to us and we want you to feel comfortable using our products and services and visiting our websites. It is important to FINANCE AND INDUSTRIAL TRUST that your personal data is handled responsibly and in accordance with legal requirements. To do this, we take precautions such as implementing strong technical and organisational security measures, including password encryption, firewalls, authentication technologies, access control, employee information and training and appointing a Data Protection Officer ("DPO").

This Privacy Policy describes how we process your personal data when you use our products and services, visit our websites, use our mobile applications or register for any service and provide information about yourself (collectively "FINANCE AND INDUSTRIAL TRUST Services").

Please read our Privacy Policy carefully before registering or using any FINANCE AND INDUSTRIAL TRUST Services and in particular before entering any personal data to understand our views and practices regarding your personal data, how we will treat your personal data and on what basis it may be disclosed to third parties. Please note that any additional terms and conditions applicable to the FINANCE AND INDUSTRIAL TRUST Services will be provided when you register for such services.

2. Processing personal data

2.1 Categories of personal data

FINANCE AND INDUSTRIAL TRUST processes various categories of personal data (e.g. customer data, potential customers, website users, suppliers, suppliers or other third parties), it limits their processing to the necessary minimum and in accordance with applicable laws and regulations. This is understood to mean the following:

— Basic data (e.g. name, address, e-mail address, telephone number, date of birth, account and contract number, other account information, transactions made or third parties such as family members, authorised representatives, advisers who may also be affected by the data processing and other data transferred to us, if a person voluntarily fills in the registration form or comment field in the newsletter or when using certain services).

— Risk management data, transaction and/or order data (e.g. data relating to transfer recipients, card payments, investment product data, risk and investment profiles, fraud cases).

— Technical data (e.g. IP addresses, types and versions of browser plug-ins, cookies, internal and external identifiers, logging data, record of access and changes, content accessed by the site user, including time and date of access, business/account number).

— Marketing data (e.g. preferences, wishes, reference material requested).

FINANCE AND INDUSTRIAL TRUST does not intend to request any sensitive data (also called special category data) unless required by law. Sensitive data includes several types of data relating to racial or ethnic origin, political opinions, religious or other similar beliefs, trade union membership, physical or mental health, sexual life or criminal record. FINANCE AND INDUSTRIAL TRUST recommends that you do not provide sensitive data of this nature and advises you that if you do choose to do so, you do so at your own risk.

2.2 Origin of personal data

For the purposes of point 2.3, we may collect personal data - to the extent permitted by law - from the following sources in particular:

— Personal data that is provided to us by the data subject, namely when opening an account, during consultations, when making enquiries, as part of registration on our websites or when using certain products and services, subscribing to a newsletter and/or events, participating in discussion forums or other social media functions on our websites or any information relating to registration for employment.

— Personal data which is necessary to facilitate the use of products and services and which is transmitted to us via our technical infrastructure (e.g. via our websites, login information, electronic banking, applications, payment and trading transactions or cooperation with financial or IT service providers or marketplaces and promotions). Personal data from third parties, such as authorities, sanctions lists (e.g. UNO/EU), Worldcheck, rating agencies, credit reporting organisations (e.g. Swiss Central Credit Information Bureau (ZEK), Consumer Credit Information Bureau (IK), Schufa Holding AG (SCHUFA)), providers of analytical services or search information, and group companies of FINANCE AND INDUSTRIAL TRUST.

— Personal data that can be publicly evaluated (e.g. information from a public registry, public social media platforms).

2.3 Purpose and use of data

We may process personal data as described above to provide our services and/or for our own lawful purposes and to the extent permitted by law. This shall be understood to include, in particular, the following:

— The processing, improvement, management and execution of our products and services (e.g. accounts, payments, invoices, cards, finance, financial planning, investments, stock exchange, pensions, electronic banking, succession planning) and the updating of data of individuals with whom we have a business relationship.

— Product and service development, statistics, business decisions (e.g. developing ideas for new or evaluating existing products, services, procedures, technologies and profitability, identifying key service usage indicators and utilisation rates).

— Management, control and monitoring of business decisions and risks, timely business processing (e.g. investment profiles, limits, market, credit, operational and fraud risks).

— Systematically administer and provide aggregated statistical information on browsing patterns and actions that do not identify a single individual.

— Compliance, legal and/or regulatory disclosure, notification and reporting obligations to authorities, courts, including but not limited to money laundering and terrorist financing (e.g. automatic exchange of information with foreign tax authorities, prosecution authorities).

— Market research, marketing, comprehensive customer service, advice and information on the range of services and products, etc. (e.g. events for customers, potential customers and interested third parties, cultural events, sponsorship, assessment of customer, market or product potential, information on changes, customer satisfaction determination, online and paper advertising).

— Protecting our interests and rights in the event of claims against us or our employees and customers.

FINANCE AND INDUSTRIAL TRUST may communicate with you via email or physical newsletters containing and offering news, promotional offers, events or service information ("Newsletter Services") if you are a registered user (i.e. if you create a user account with us) and agree to receive the Newsletter Services. If you prefer not to receive marketing communications or newsletters from us, you can 'opt-out' by following the 'opt-out' instructions in the footer of each email or by contacting us.

3. Transmission of data via the Internet

Please note that data transmitted over the Internet cannot be adequately protected in transit, even if the sender and recipient are in the same country.

We cannot guarantee the security of data transmitted via the Internet and accept no responsibility in this regard. Any notifications you send us by e-mail may not be secure. If you send us any sensitive information by email, you do so at your own risk. When contacting us, please do not send data via the internet, but via a secure mechanism where appropriate.

The sender and recipient can still be identified, even if the information being transmitted is encrypted. As a result, a third party may - inadvertently or otherwise - infer a commercial relationship between you and FINANCE AND INDUSTRIAL TRUST. We therefore recomend that you avoid transmitting any highly confidential information over the Internet.

4. Outsourcing

In certain circumstances, FINANCE AND INDUSTRIAL TRUST has to outsource areas and services to FINANCE AND INDUSTRIAL TRUST companies or service providers outside FINANCE AND INDUSTRIAL TRUST in whole or in part (e.g. payment transactions, subscription and redemption of fund units, printing and sending of bank documents, IT systems and other support functions). We may also use such service providers to provide services that are new and not previously provided by us.

In such cases, we generally use service providers registered in EU/EEA countries and Switzerland and, where possible, favour companies in our own group in order to ensure compliance with relevant laws and regulations. Where client data is to be transferred to service providers, the relevant service providers must also comply with the bank-client confidentiality provisions and other applicable rules and regulations. If, in exceptional cases, services are outsourced to a service provider abroad, FINANCE AND INDUSTRIAL TRUST will disclose this information in accordance with the applicable rules and regulations.

5. Storage of data

Once you have provided personal data to us, this data is stored securely for the purposes outlined in this Privacy Policy and for the purposes for which the information was provided.

We have put in place suitable and robust data security measures to ensure that this information is only accessible to a limited number of authorised individuals and that it is protected against unauthorised access, misuse, loss or damage.

In general, all data that is collected in any country or by any FINANCE AND INDUSTRIAL TRUST company is transmitted to and stored by us in Switzerland. Switzerland is recognized as a country that offers an adequate level of data protection.

Although the retention period of personal data depends on legal provisions on retention periods, the applicable legal basis and the purpose of the data processing, FINANCE AND INDUSTRIAL TRUST will retain your personal data only for as long as necessary, taking into account our obligations to respond to enquiries or concerns, to provide improved and new services and to act in accordance with applicable laws and regulations.

In particular, this means that we have the right to retain your personal data for a reasonable period after your last contact with us. If the personal data we have collected is no longer needed, we are obliged to delete it in a secure manner.

6. Rights of the data subject

You have the right to be informed whether we process personal data concerning you. On request, we will disclose to you the personal data in our databases, including available information about the origin of the data, the purpose and, if applicable, the legal basis for processing and the categories of personal data processed, the parties involved in the data collection and the data recipients.

You may at any time withdraw your consent to the processing of your personal data and/or refuse to use your information for promotional or marketing purposes. You may exercise other rights, such as the right to correction, and have the right to have any inaccuracies in your personal data corrected, blocked or deleted, depending on the legal basis on which we process the particular personal data.

7. Note on children

FINANCE AND INDUSTRIAL TRUST understands the importance of protecting the privacy of children, especially in an online environment. Therefore, our services are not directed at or intended for children under the age of 16 and we do not knowingly collect any personal information from such users, unless the child is applying for an apprenticeship, internship or introductory day. In this case we will obtain a written statement of consent for pupils from their parents or legal guardians.

8. Cookies and web analytics services

Different types of cookies are used on our websites. Please see our Cookie Policy for more information on their use.

We also use web analytics tools to get information about how people use our websites and online offerings. These tools are usually provided by third parties. Typically, information for this purpose is collected through cookies and sent to the third party server. Depending on the provider, these servers are sometimes located in other countries.

We only transfer abbreviated IP addresses to prevent the identification of individual end-user devices. Your IP address is not linked to any other data from these third parties. Any further transfer by third parties is only permitted on the basis of legal regulations or as part of a data processing service agreement.

9. Contact

Please let us know if we are not meeting your expectations regarding the processing of personal data or if you wish to complain about our data protection practices; this will give us the opportunity to investigate your issue and make improvements if necessary.

You can contact us using our online form or by sending us a clear request in writing to one of the DPO email addresses or by post to the addresses below.

FINANCE AND INDUSTRIAL TRUST
Graham House,7 Wyllyotts Place,Potters Bar,
Hertfordshire,England,EN6 2JD
Email: support@faitrust.com

10. Changes to this Privacy Policy

We reserve the right to make changes to this Privacy Policy without notice. Therefore, we recommend that you check the Privacy Policy on our websites regularly. This Privacy Policy was last updated on 1 September 2023.