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  • Terms of use and
    legal notice
  • Privacy notice for
    website visitors
  • Privacy notice for client
    and prospective clients
  • Special legal
    information
  • Complaints
    procedure
  • SmartWealth
    Terms and Conditions

Last updated October 2018

Please read these terms carefully

Terms of use

Before using this website, you should read the following important information carefully. This information (together with the other documents referred to in it) (collectively these “terms”) governs your use of this website. By using this website, you indicate that you accept these terms of use and that you agree to be bound by them. If you do not agree, please do not use our website.

Changes to these terms

The content of this website, including these terms, may be changed by us without notice, and you should check this page from time to time for any updated terms. 

We may also need to make changes to the customer portal on our website to reflect changes in law or best practice or to deal with additional features which we introduce. We will aim to notify you of any changes and seek your consent when you attempt your first login to the customer portal after such changes have been made. If you do not agree to the changes to the customer portal, you will not be able to login or access the customer portal.

Regulatory information

LGT Vestra LLP is authorised and regulated by the Financial Conduct Authority ("FCA") and is a member of the London Stock Exchange. Our FCA registration details are set out in the FCA Register under Firm Reference number 471048 (www.fca.org.uk). LGT Vestra LLP is registered in England and Wales (registered number OC329392) and our registered office is 14 Cornhill, London EC3V 3NR. For more information about the regulatory framework within which LGT Vestra operates see the Special Legal Information.

Other terms

These terms of use refers to the following terms which also apply to your use of the site:

Our Privacy Notice for Website Visitors which applies to your use of our site, sets out the terms on which we process any personal data we collect from you, or that you provide to us. By using our site, you consent to such processing and you confirm that all data provided by you is accurate. It also sets out information about the cookies on our site.

Our LGT Vestra Online Service Terms which sets out the permitted uses and prohibited uses of our site’s customer portal. When using our site’s customer portal, you must comply with the terms of our LGT Vestra Online Service Terms. If you fail to do so, we may take such action against you as we deem appropriate which may include the immediate, temporary or permanent withdrawal of your right to use our site’s customer portal.

Suspension or withdrawal of our site

Access to our site is permitted on a temporary basis. We do not guarantee that our site, or any content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of our site for business and operational reasons.

You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these terms of use and other applicable terms and conditions, and that they comply with them..

Accessing our site

If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures, you must treat such information as confidential, and you must not disclose it to any third party. We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our opinion you have failed to comply with any of the provisions of these terms of use.

If you know or suspect that anyone other than you knows your user identification code or password, you must promptly notify us at dpo@lgtvestra.com.

Information on our site

The information contained in this website should not be regarded as advice or an offer, invitation or solicitation to enter into any financial obligation, activity or promotion of any kind as defined by the Financial Services and Markets Act 2000. The provision of any investment services and products, whether or not mentioned in this website, may not always be suitable for an investor, and we recommend that any potential investor consults a financial adviser before entering into any investment contract. Investors should be aware that past performance is not an indication of future performance, the value of investments and the income derived from them may fluctuate and you may not receive back the amount you originally invested.

The content on our site is provided without any representations, guarantees, conditions or warranties as to its accuracy or completeness or as to whether it is up to date.

Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked websites or information you may obtain from them. We have no control over the contents of those sites or resources and accept no responsibility for them or for any loss or damage that may arise from your use of them.

Intellectual property rights

We are the owner or the licensee of all intellectual property rights in our site and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

The intellectual property rights in all elements of our customer portal, including software, databases, data and other information viewed, used or accessed through the customer portal, shall remain vested in us and/or our licensors, and you will not acquire or retain any proprietary right, interest or title in such elements.

You may print off one copy, and may download extracts, of any page(s) from our site for your personal reference and you may draw the attention of others within your organisation to material posted on our site.

You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.

Our status (and that of any identified contributors) as the authors of material on our site must always be acknowledged.

You must not use any part of the materials on our site for commercial purposes without obtaining a licence to do so from us or our licensors.

If you print off, copy or download any part of our site in breach of these terms of use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

Our responsibility for loss or damage suffered by you

We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors and for fraud or fraudulent misrepresentation.

Our limitation of liability under these terms does not affect our duty or liability to you which we have under the Financial Services and Markets Act 2000 or under the regulatory system.

Please also see the LGT Vestra terms and conditions which set out our limitation of liability for any services we may provide to you.

If you are a business user of our site:  

We exclude all conditions, warranties, representations or other terms that may apply to our site or any content on it or to our customer portal (whether express or implied) including but not limited to, to the maximum extent permitted by law, any implied warranties of satisfactory quality, fitness for a particular purpose, non-infringement, compatibility, security and accuracy.

We will not be liable to you for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:

  • use of, or inability to use, our site; or
  • use of or reliance on any content displayed on our site

In particular, we will not be liable for:

  • loss of profits, sales, business, or revenue;
  • business interruption;
  • loss of anticipated savings;
  • loss of business opportunity, goodwill or reputation; or
  • any indirect or consequential loss or damage.

If you are a consumer user:

Please note that we only provide our site to you for domestic and private use. You agree not to use our site for any commercial or business purposes, and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.

Viruses, hacking and other offences

We do not guarantee that our site will be secure or free from bugs or viruses.

You are responsible for configuring your information technology, computer program and platform to access our site. You should use your own virus protection software.

You acknowledge that you are responsible for keeping any device on which you access our site secure, and that you must close access to our site when you are not using it.

You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site and you must not attack our site via a denial-of-service attack or a distributed denial-of service attack. You may commit a criminal offence under the Computer Misuse Act 1990 if you do so.

We will report any such offence to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such an offence, your right to use our site will cease immediately.

We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our site or to your downloading of any material posted on it, or on any site linked to it.

Linking to our site

You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it in any way whatsoever, but you must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.

Jurisdiction and applicable law

If you are a consumer, please note that these terms of use, their subject matter and their formation, are governed by English law. You and we both agree that the courts of England and Wales will have exclusive jurisdiction except that if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland.

If you are a business, these terms of use, their subject matter and their formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.

Entire agreement

These terms of use and any document expressly referred to in them constitute the whole agreement between us and supersede all previous discussions, correspondence, negotiations, previous arrangement, understanding or agreement between us relating to the use of our site.

 

Last updated February 2020

Please read these terms carefully

The protection of your personal data is very important to us. We process your data in accordance with the EU General Data Protection Regulation (“GDPR”), and the Data Protection Act 2018. In this data privacy notice we inform you of the most important aspects pertaining to the processing of your data, which we collect when you use our website, social media profiles, mobile apps or any other web applications. This data privacy notice also explains some of the measures used to ensure the confidentiality of the data transmitted and to protect your privacy.

This data privacy notice applies to the website of LGT Vestra LLP and certain affiliates (“Website”). We reserve the right to amend this data privacy notice without prior notice of any changes (e.g. legal circumstances, product or services offering, data processing policy). Any amendments become applicable from the time they are published on the Website. Some pages may contain links to other providers (“Third-party Providers”) within and outside LGT Group, to which this data privacy notice does not apply. The conditions and data privacy notices of the respective Third-party Providers apply for the linked websites and content. We assume no liability in connection with linked third-party websites.

1. Contact with us

If you establish contact with us by e-mail or by using the contact form provided on the Website, your data are used for processing or post-processing of the inquiry, to establish contact and for technical administration purposes.

We collect and use personal data on the Website in order to improve the information, products and services provided, to further align our business processes with the needs of clients and visitors to the Website (“Visitors”) and to ensure efficient access to information and online banking applications.

2. Web server logs

When you use the Website, access data are stored (e.g. log files, IP address, date and time of access, name of the requested file, access status, page from which access is gained, top-level domain, web browser used, operating system used). We use these data for statistical purposes, for technical analysis, to optimize the server infrastructure, to ascertain the frequency of access and to improve user-friendliness and functionality.

3. Use of cookies

The Website uses what are known as cookies. Cookies are small text files that are stored by the browser on your end device. They do not cause any damage, and serve only to make it easier for you to use and individualize the Website.

If you do not wish for cookies to be used, you can set up your browser so that it informs you about the setting of cookies and enables you to allow this on a case-by-case basis. In addition, the most commonly-used browsers have a settings option enabling you to block or to disable cookies. Instructions on how to manage cookies on your browser can usually be found under the browser’s help function or in the instruction manual of your end device. For the most commonly-used browsers, instructions on how to disable cookies can also be found at the following links:

- Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
- Firefox: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop
- Chrome: https://support.google.com/chrome/answer/95647?hl=en&hlrm=en
- Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
- Opera: https://help.opera.com/en/latest/web-preferences/#cookies

Rejecting or disabling cookies, can, however, restrict the functionality of the Website.

3.1 Technically essential cookies

Some cookies are necessary in order for the Website to function. Technically essential cookies remain stored on your end device for the intended duration (see table) or until you delete them.

You can delete technically essential cookies from your browser after using the Website.

We use the following cookies:

Cookie name (type) Provider Description Duration
AL_SESS_PR-S (HTTP) LGT Stores an identifier to assign page views to a specific user session (Session ID). Session
jmaCPVideo (HTTP) LGT Stores the domicile selected to prevent certain citizens from viewing the footage. 30 days
lgtdomicil (HTTP) LGT Stores the domicile selected. 30 days
LGT-Cookie (HTTP) LGT Stores the cookie banner settings and the settings for external content (maps, videos). 365 days
lgtInternetQueryMedian (HTTP) LGT Used to store the user’s search history. Session
lgtInternetQueryOldest (HTTP) LGT Used to store the user’s search history. Session
lgtInternetQueryRecent (HTTP) LGT Used to store the user’s search history. Session


3.2 Statistic cookies

We strive to continuously improve the Website. To this end, cookies are used for website and performance analysis. These are cookies that provide us with overall statistics on the number of Visitors, the pages visited, etc. As a result, we receive statistical analyses, which we use to establish whether the Website is designed to meet the intended needs. Our providers are not able to identify you or to establish a connection with your person during this process.

We use the following cookies:

Cookie name (type) Provider Description Duration
_ga (HTTP) Google Analytics Serves to distinguish between users. Registers a unqiue ID to generate statistical data on how a visitor uses the website. 2 years
_gat (HTTP) Google Analytics Used to restrict the frequency of queries to Google Analytics. 1 minute
_gid (HTTP) Google Analytics Stores an identifier to associate requests with a particular logged-in user session. 24 hours
1P_JAR (HTTP) gstatic.com

pending

 
__hssrc (HTTP) assessfirst.com Enables visitors and traffic sources to be counted and to thus improve the performance of our website. This cookie helps to determine which pages are the most and least visited and how visitors move around the website. All information collected by this cookie is anonymous. Session
__hstc (HTTP) Wistia.com

pending

2 years

You can prevent the use of statistic cookies by not selecting “Statistics” in the “Cookie information” pop-up that appears when you visit the Website and clicking on “Confirm selection”


3.3 Marketing cookies

When you visit some of our pages, targeting service providers may store temporary cookies on your mobile end device that are automatically deleted after a specified period of time. Targeting refers to processes that enable the display of target group-specific or individualized content on websites. These cookies contain a machine-generated alphanumeric identifier that does not allow any conclusions to be drawn about your person or your end device’s IP address.

We use the following cookies:

Cookie name (type) Provider Description Duration
_fbp (HTTP) Wistia.com

pending

3 months
_sp_id.2b40 (HTTP) Wistia.com Used by Wistia to generate anonymized statistics on the use of videos. 1 year
hubspotutk (HTTP) Wistia.com

pending

 

You can prevent the use of marketing cookies by not selecting “Marketing” in the “Cookie information” pop-up that appears when you visit the Website and clicking on “Confirm selection”.

4. Incorporation of third-party services and contents

Third-party content and services may be incorporated into the Website (known as externally embedded components or plugins/widgets). These always require that the Third-party Providers of such content use Visitors’ IP addresses, as no content can be sent to the Visitor's browser without the IP address.

In order to share website content via social media channels (Facebook, Twitter, etc.), a cookie must be installed on your end device. Once you have used this function, the responsibility for further data processing lies with the respective Third-party Provider. By clicking on the symbol, you consent to communication with the relevant platform and the transmission of information to the third-party provider in question.

We have no control over the amount of information that these Third-party Providers collect by means of the button or as a result of your use of pages that incorporate certain third-party services. If you use the services of Third-party Providers, the responsibility for the further processing of data lies with the respective third-party provider.

On the Website, we use the following third-party products for these purposes:

4.1 Google Analytics provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google").

The cookies used for analysis by Google Analytics do not contain any personal data. Your IP address is abbreviated directly on your computer. Your IP address is sent to Google Analytics in this anonymized form. Google Analytics will not link your IP address to other information held by Google Analytics and will only pass on data to third parties where this is provided for by law. Information on the services and privacy policy of Google Analytics at can be found at:

https://support.google.com/analytics/answer/6004245?hl=en

You can prevent the use of cookies by Google Analytics by not selecting “Statistics” in the “Cookie information” pop-up that appears when you visit the Website and clicking on “Confirm selection”.

4.2 Wistia-Videos provided by Wistia Inc., 17 Tudor Street, Cambridge, MA 02139, USA

As soon as you play a Wistia video on a page, information on user behavior is collected using cookies. Wistia generates viewing statistics of the videos and analyzes these. Information about the data collected by Wistia and about Wistia’s services and privacy policy can be found at: https://wistia.com/terms

Content from video platforms is blocked on the Website by default. You can prevent the use of cookies by Wistia by not clicking on the play symbol that is shown on the videos. By clicking on the play symbol or the field "Always allow videos" you agree to the setting of cookies and the transmission of personal data to Wistia.


4.3 Google Maps provided by Google Maps (API) of Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”) shows our locations and makes it easier to find your way to us.

If you click on pages incorporating maps provided by Google Maps, data (e.g. IP address) are transmitted to and stored on Google's systems in the US. Google creates and analyzes user profiles. If you have a Google account and are logged in to this account, your data are also linked to your Google account. You have the right to object against the creation of user profiles, which you can exercise towards Google. Information about the services and privacy policy of Google and Google Maps can be found at:

https://policies.google.com/terms?hl=en&gl=en
https://www.google.com/intl/en_US/help/terms_maps/
https://policies.google.com/privacy?hl=en&gl=en

Content from Google Maps is blocked on the Website by default. You can prevent Google Maps from using cookies by not clicking on the “Load Map” button that appears on the maps. By clicking on the “Load Map” symbol or the “Always allow Google Maps” box, you consent to the setting of cookies and the transfer of personal data to Google Maps.

5. Newsletter

You can subscribe to our newsletter on the Website. To this end, we require your e-mail address and potentially further information for personalization purposes as well as your confirmation that you agree to the newsletter subscription.

Once you have subscribed to the newsletter, you will receive a confirmation e-mail containing a link to confirm the subscription.

You can cancel your newsletter subscription at any time by clicking on the corresponding link in the newsletter. Your data collected in connection with the mailing of the newsletter will then be deleted, unless you have granted explicit consent to the continued use of your data or we have reserved the legal right to continue to use your data.

The mailing of our newsletters and the processing of the data of the newsletter recipients is carried out by contracted providers based in the EU, who are obligated to comply with the GDPR.

 

6. Data protection

6.1 Data processing and data storage

Due to cookies, the IP data of the owner of the connection is stored when visiting the Website. Under certain circumstances, personal data such as the Visitor's name and address may also be collected via input masks.

Visitors to the Website are informed of the collection of personal data on the respective pages. We use personal data for whose processing you have granted us consent (e.g. when subscribing to newsletters or ordering brochures) or that are necessary for the performance of a contract or the initiation of business contact.

Personal data that we collect via the Website are only used in accordance with the purpose that results from the page in question and will be stored until this purpose has been fulfilled. In the event of the conclusion of a contract, the data from the contractual relationship will be stored until the statutory retention or limitation periods have expired.

The data collected on the Website that have been entered by you are forwarded to the competent unit within LGT Group. The data remain confidential during this process. The data are not disclosed to third parties, unless required (e.g. the mailing of newsletters or brochures by a provider).

The use of state-of-the-art security software and certified encoder and encryption procedures ensure that our IT infrastructure complies with international security standards. We have also implemented additional comprehensive security measures and technical as well as organizational measures to protect your data against loss, unauthorized access and misuse in accordance with state-of-the-art technology for Internet access to accounts and custody accounts.

Irrespective of the measures taken to protect your data, data protection and confidentiality may be limited when data is processed via universally accessible media. When using the Internet to send transmissions from a computer, mobile phone or another end device, it cannot by its nature be excluded that third parties can obtain access to your data and in so doing, can draw inferences concerning possible business relationships, or that personal data are transmitted to third countries without our cooperation or knowledge.

We recommend that particularly sensitive data, especially personal data and data relating to client relationships (account, custody account, transactions, etc.), be transmitted only via secure communication channels. Due to the risks involved, your entry or transmission of personal or business data within the scope of the Website or other digital services is done voluntarily and without any assurances. We do not accept any liability for direct and indirect damages arising in connection with the use of the Website, digital services or their contents.

6.2 Legal basis and purposes of processing

Your data are processed on the basis of a legitimate interest (Art. 6 para. 1 (f) GDPR) for the following purposes:

- As the operator of the Website, we have a legitimate interest in the effective design of the Website, the highest degree of stability and functionality of the Website, the statistical analysis of visitor behaviuor for optimization and marketing purposes, the targeted advertising or personalized direct advertising and the secure, user-friendly mailing of newsletters.

- Due to the legitimate interest of a Third-party Provider (e.g. Google, Wistia) to incorporate personalized advertising based on Visitors’ surfing behaviour or on market research. The Third-party Providers have undertaken to observe the Privacy Shield Framework between the EU and the US regarding the collection, use and storage of personal data from EU member states.

Where required, your data can also be processed for the purposes of performance of a contract or the initiation of business contact or on the basis of your explicit consent.

6.3 Your rights

You have the following data subject rights with regard to your personal data (Art. 15 to 21 GDPR):

- The right to information: you can request information about whether and to what extent we process your personal data.

- The right to rectification, erasure and restriction of processing: you can have inaccurate or incomplete personal data rectified or you can demand that your data be erased (e.g. if they are no longer necessary, you have withdrawn your consent, or these data are being unlawfully processed) or that the processing thereof be restricted.  

- Right of revocation: you can revoke your consent for the processing of your data at any time. The revocation of consent is only effective for the future and does not have any impact on the lawfulness of the data processed until the time of revocation. Revocation also has no impact on data processing conducted based on a different legal basis.

- Right of data portability: you can have the data which you have provided to us transmitted in a structured, commonly-used and machine-readable format. 

- Right to lodge a complaint: if you feel that your rights have been violated by our data processing, you can lodge a complaint with the United Kingdom Information Commissioner's Data Protection Office or another supervisory authority of an EU or EEA member state (e.g. in your place of residence or work or in the place where the GDPR was violated).

The contact details of the competent supervisory authority of LGT Vestra LLP clients are:

Information Commissioner's Office
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
Great Britain

Phone: +44 303 123 1113

www.ico.org.uk


 

6.4 Right to object

- In individual cases: if the processing of your data is carried out in the public interest or to safeguard legitimate interests by us or a third party, you can object to this processing at any time on grounds relating to your particular situation.

- Direct marketing: you can object informally to the use of your data for direct marketing purposes. In the case of such an objection from you, we shall no longer process your data for such purposes.


6.5 Contact

Please contact us at the following address if you have any questions regarding data protection or wish to exercise your rights:

The registered address and phone number of LGT Vestra LLP is: 14 Cornhill, London EC3V 3NR Great Britain Phone: +44 203 207 8000.

LGT Vestra reserves the right to change this data privacy notice from time to time and revised terms will be posted on our website.

If you have any questions about this data privacy or the information we collect and use about you, please contact the Data Protection Officer;

Paul Martin LGT Vestra LLP 14 Cornhill, London EC3V 3NR Great Britain

E-mail: dpo@lgtvestra.com

Phone: +44 203 207 8000

 

Städtle 38
Postfach 684
FL-9490 Vaduz
Liechtenstein

Privacy notice

Our approach

This Privacy Notice describes what happens to the personal information which you supply to LGT Vestra LLP, LGT Vestra US Ltd and LGT Vestra (Jersey) Ltd (referred to as “LGT Vestra”, “our” or “we”) in connection with the services LGT Vestra provides to you. LGT Vestra LLP and LGT Vestra US Ltd are registered with the Information Commissioner's Office (ICO) in the United Kingdom as a data controller.

LGT Vestra (Jersey) Ltd is registered with the Jersey Office of the Information Commissioner (JOIC) as a data controller.

The registered address and phone number of LGT Vestra LLP and LGT Vestra US Ltd are: 14 Cornhill, London EC3V 3NR, +44 203 207 8000.

The registered address and phone number of LGT Vestra (Jersey) Ltd is: Charles Bisson House, 30-32 New Street, St Helier, Jersey JE2 3TE, +44 (0)1534 786400.

LGT Vestra reserves the right to change this Privacy Notice from time to time and revised terms will beposted on our website.

If you have any questions about this Privacy Notice or the information we collect and use about you, please contact the applicable Data Protection Officer depending upon where your account(s) is/are held.

LGT Vestra LLP and LGT Vestra US

Paul Martin 

14 Cornhill

London, EC3V 3NR

dpo@lgtvestra.com

+44 203 207 8000

LGT Vestra (Jersey) Ltd

Simon Boyle

30-32 New Street

St Helier, Jersey JE2 3TE

dpo@lgtvestra.com

+44 (0) 1534 786400

What information do we hold about you and how do we collect it?

LGT Vestra collects, uses and stores personal information you have provided to us or personal information which is necessary for us to provide the services you have requested.

Personal information may include but is not limited to:

 

  • personal details (e.g. name, date of birth, nationality, marital or civil partnership status, country of residence, dependents);
  • address and contact details (e.g. physical address, telephone number, e-mail address);
  • identification data (e.g. passport, National Insurance Number or other identity card numbers) and authentication data (e.g. specimen signature);
  • information on spouses, partners and other family details, or on authorised signatories and representatives;
  • information about financial matters (e.g. the assets in your portfolio, account numbers, origin of assets, your bank details);
  • professional and personal background information (e.g. employment, professional activity, preferences);
  • information on electronic communication with LGT Vestra or other technical data (e.g. records of accessing our website);
  • image and audio data (e.g. CCTV or voice recordings); and
  • where necessary to provide certain services to you and with your consent, we may collect and process sensitive personal information which may include information about your physical or mental health.

We collect information through a variety of sources, including:

 

  • the account agreements you complete for our services;
  • conversations and correspondence with us, including recorded telephone lines;
  • anti-money laundering verification services;
  • public registers and agencies;
  • our online services and website;
  • agents, brokers, dealers, introducers and other intermediaries; and
  • other companies who provide personal data for individuals with whom we seek to establish a business relationship. We may pay a fee to the providers of these services may.

How do we use and upon what legal grounds do we process your personal information?

We use your personal information, and may share it with other third parties acting on our behalf, for several purposes. These purposes and the legal basis upon which we process your personal information are set out below.

 

  • We may process your personal information because it is necessary in connection with the provision of our services. This includes personal information we require to fulfil a request for our products or services prior to entering into a contract with you and for the performance of that contract.
  • We may process your personal information for our legitimate interests as a business (except where your interests or fundamental rights override these). For example, it is within our legitimate interests to use your personal information:

to send you market commentary and information about your investments, products and services we believe are relevant and of interest to you;

to respond to any enquiry or complaint you may make to us;

to send you a brochure introducing you to our services;

to invite you to an event which may be of interest to you;

for market research purposes, where we may contact you to ask for your feedback;

to prevent abuses of our website, for example, by requesting verification information in order to reset your account password (if required);

to ensure the security of our premises;

to maintain compliance with our internal policies and procedures; or

for our own administrative purposes, including training our staff and conducting internal audits.

 

  • We may process your personal information in order to comply with our regulatory and legal obligations such as to prevent money laundering, fraud, market abuse or other criminal activity, to comply with tax laws or to meet our regulatory reporting obligations.
  • We may process your information because you have given us your consent to do so. For example:

where you have provided us with sensitive personal information necessary for us to provide you with the services you have requested, such as information about your health;

where you have agreed we can contact you with information about the products and services we can offer to you; or 

where you have provided information to us via our website.

If at any time after you have consented to us using your personal information for marketing purposes and you wish us to stop using your information for these purposes, please email us at info@lgtvestra.com.

Is automated decision-making, including profiling, carried out?

As a basic principle, our decisions are not based on automated processing of personal data. There are areas of the business where personal data are processed at least partly by automated means. The objective of this is to evaluate certain aspects of the relationship where we are obligated to do so by legal and regulatory requirements (e.g. prevention of money laundering) and for the purposes of risk management.

Do we share your personal information with other third parties?

There are circumstances where we may wish to disclose or are compelled to disclose your personal information to third parties. For example, we may pass on your data to:

 

  • our subsidiaries, branches or associated offices within the LGT Group;
  • government institutions, regulators, authorities and courts (when legally obliged to do so) such as the Financial Conduct Authority (FCA), the ICO or the HM Revenue & Customs (HMRC);
  • providers of investments we recommend; and
  • service providers who are processing the data on behalf of LGT Vestra under contractual obligations of confidentiality, such as IT service providers, auditors, printing services, professional advisers and fraud prevention organisations.

We will only transfer your personal information to countries outside the European Union (EU) or European Economic Area (EEA) (so-called third countries):

 

  • where it is necessary for the implementation of pre-contractual measures or the performance of a contract;
  • where it is necessary for the provision of services or processing of orders (e.g. execution of payment instructions or securities transactions);
  • where it is necessary for data to be held by LGT Group so that security controls remain in place;
  • where you have given us your consent (e.g. for referral to another LGT Group company for a product or service you have requested); and
  • where it is required by law or regulation (e.g. to comply with anti-money laundering regulations or reporting obligations under tax law).

These disclosures of personal information to third parties will only take place in accordance with the law and for the purposes listed above.

How do we keep your personal information secure?

LGT Vestra takes all reasonable steps to ensure that any personal data that you provide to us is kept secure, and we have put in place measures to guard against unauthorised use of your personal information or accidental loss, destruction or damage. Because of the nature of the Internet, we cannot guarantee the security of your data transmitted to the website or via email, and any inward transmission of data is carried out at your own risk.

How long do we retain your personal information?

Your personal information will be retained for as long as it is necessary to carry out the purposes set out in this Privacy Notice (unless longer retention is required by law). However, we will not retain any of your personal information beyond this period and the retention of your personal information will be subject to periodic review. We may keep an anonymised form of your personal information, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

What are your legal rights under data protection laws?

Data protection law provides individuals with certain rights, including the right to: access, rectify, withdraw consent, erase, restrict, transport, and object to the processing of their personal information.  Individuals also have the right to lodge a complaint with the relevant information protection authority if they believe that their personal information is not being processed in accordance with the law. Further information about your rights is set out below:

 

  • Right to be informed. You have the right to be informed about how we collect and use your personal information.
  • Right to obtain a copy of your personal information. You have the right to obtain a copy of the personal information we hold about you. If you like would to obtain a copy of this information please email us at info@lgtvestra.com. You may be required to submit a proof of your identity and a fee.
  • Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete personal information.
  • Right to withdraw consent. You may, as permitted by law, withdraw your consent to the processing of your personal information at any time if that is the legal basis upon which we are processing your information. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal information is essential.
  • Right to restrict processing. You may, as permitted by law, request that we restrict or limit processing your personal information.
  • Right to erasure. You may request that we erase your personal information, unless there is a lawful reason for us not doing so.
  • Right to data portability. You have the right to request a copy of your information in a structured, commonly used and machine-readable format; and
  • Right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your personal information. However, you do have the right to contact the ICO directly using the contact details below.

You also have a right to object to the processing of your data for the purposes for direct marketing, and we must comply with your request. You may also object to the processing of your information where we are processing your data for our legitimate business interest or for statistical or research purposes, although we may have compelling legitimate grounds to continue processing your data.

To contact the Information Commissioner’s Office for more information on your rights or other question you may have, please visit the ICO website or contact them via the following:

Information Commissioner's Office

Wycliffe House Water Lane

Wilmslow Cheshire SK9 5AF

Phone: 0303 123 1113

If your account(s) is/are held with LGT Vestra (Jersey) Ltd, to contact the Information Commissioner's Office for more information on your rights or other questions you may have, please visit the ICO Website at www.jerseyoic.org of contact them via the following:

Information Commissioner's Office

2nd Floor, 5 Castle Street,

St Helier, Jersey JE2 3BT

Phone 01534 716530

Linked websites

Please note that any websites that may be linked to our website are subject to their own privacy policy. LGT Group's data protection notice can be found on their website (www.lgt.com), and we encourage you to read that notice as well to understand how LGT may process your data.

Cookies

For more information please visit our Cookies Policy.

carefully

Last updated December 2019

Please read these terms carefully

This Special Regulatory Information document (together with the documents referred to in it) provides you with important information about the regulatory framework within which LGT Vestra operates.

The information contained herein may be changed by us without notice and so you should check this page from time to time for any updates.

Regulatory information

LGT Vestra LLP is authorised and regulated by the Financial Conduct Authority ("FCA") and is a member of the London Stock Exchange. Our FCA registration details are set out in the FCA Register under Firm Reference number 471048 (www.fca.org.uk). LGT Vestra LLP is registered in England and Wales (registered number OC329392) and our registered office is 14 Cornhill, London EC3V 3NR.

Services

LGT Vestra LLP’s advisory and discretionary portfolio management services are restricted to providing clients with specialist expertise and advice on the management of investment portfolios. As a firm LGT Vestra LLP is able to source investment solutions from the whole of market and we are not tied to any products or providers. However, we will not consider clients’ wider financial planning and pension requirements, unless a client expressly wishes us to do so, when the client will be referred to one of our wealth planners.

 

Execution policy

For our execution policy, please click here.

Execution venues 

For more information about execution venues please click here.

For analysis of our use of execution venues please click here.

For the data relating to execution venues please click here.

Pillar III Disclosures as at 31.12.2019

Pillar III Disclosures

Given the industry that LGT Vestra operates in it is subject to a number of risks including but not exclusively credit risk, market risk, operational risk, liquidity risk and interest rate risk. Please click here for our Pillar III Disclosure.

Remuneration

Our remuneration policy is designed to ensure that we comply with the Remuneration Code and our compensation package is in line with the Firm’s strategy and objectives. The policy is designed to create a direct link between reward and performance, encourage a team ethic throughout the business, and promote effective risk management. For our full disclosure statement, contained within our Pillar III disclosure.

LGT Vestra and the UK Stewardship Code

As a wealth management firm, our responsibility to look after our clients and their assets is one of our core values. We do this by offering a bespoke approach to wealth management, taking into account not only clients' investment objectives, time horizon and risk profile but also any additional needs and ethical views they may have. Looking after our clients' interests in this manner and ensuring our investment decisions and recommendations are taken with our clients' best interests in mind is at the heart of our stewardship responsibilities.

To LGT Vestra, effective stewardship means we seek the best outcome for our clients by taking an active interest in both the financial and non-financial aspects of the companies and funds in which we invest on behalf of or recommend to our clients.

UK Stewardship Code ("Code")

The Code was issued by the Financial Reporting Council ("FRC") in July 2010 and has been revised and strengthened with effect 1st January 2020. The FRC is an independent regulator which oversees the areas of auditing, financial reporting and corporate governance as well as stewardship in the financial services industry.

The Code aims to enhance the quality of engagement between investors and companies to help long-term risk-adjusted returns to shareholders. Whilst the Code is largely concerned with institutional investing, LGT Vestra considers effective stewardship to be an important duty we have to all of our clients.

Discharging our stewardship responsibilities

As a wealth manager, our primary duty is to maximise investment returns for our clients whilst operating within the confines of our contractual obligations and the objectives, goals and other parameters we have agreed with our clients. We look to achieve this through our sound and thorough approach to identifying suitable investment opportunities.

Investment opportunities are identified through comprehensive financial analysis but other aspects of the company or fund may be given consideration. Those factors include:

  • Corporate governance;
  • Strategy;
  • Culture;
  • Non-financial performance and risks;
  • Capital structure; and
  • Social and environmental impact.

The significance assigned to these factors is considered on a case by case basis at the discretion of our in-house research team.

Monitoring Investee Companies and Funds

Effective monitoring of investee companies and funds is fundamental to fulfilling our responsibility to our clients. Each company’s or fund's ability to create, sustain and protect value is central to our investment process. Therefore, we continually assess the performance and management of companies and funds in which we have invested on behalf of our clients to determine if our client’s interests are being served.

Comprehensive and continuous research and monitoring of investee companies is fundamental to LGT Vestra’s investment process as our investment strategy typically looks to long-term investment rather than continual turnover of clients’ portfolio holdings.  Monitoring of specific companies typically occurs though financial reporting, general meetings, news, special announcements and other research conducted by our research team. Monitoring of funds typically occurs through ongoing returns and holdings based analysis with regular fund manager engagement. Market views and industry research is also taken into account when looking into new investment ideas or reviewing our recommendations.

Financial and non-financial risks are actively considered and detailed in a specific section within our research reports.

Where we have concerns about the performance or strategy of an investee company/fund or where we have reason to believe that our client’s rights as shareholders are being compromised in any way, we will escalate our engagement with the investee company’s management and take any actions or decisions accordingly.

Voting Rights and Behaviour

LGT Vestra supports our clients in exercising their right to vote where deemed appropriate. From time to time, our research analysts identify a significant issue which could have an impact on the holdings of our clients. When this occurs, LGT Vestra exercises the vote on behalf of shares held by our clients through our nominee. Where clients identify a vote where they wish to exercise their rights, they may instruct us to vote on their behalf and we will cast a vote for the shares held by them through our nominee.

Where necessary or appropriate, we endeavour to engage with investee companies regarding significant votes. Records of our votes on behalf of particular clients are available to those clients upon request.

We do not use the services of proxy advisers.

We regularly report investment activity to our clients and disclose how we have voted at the general meetings of companies in which we hold shares where the vote has been significant.

Communicating with other shareholders and relevant stakeholders

LGT Vestra’s long term investment strategy and research process mean that it will rarely be necessary for us to cooperate or communicate with other shareholders or relevant stakeholders. However, if such communication is deemed to be in the best interests of our clients, it will be carefully considered and action taken accordingly.

Managing conflict of interest

LGT Vestra maintains a policy on managing conflicts of interest which is designed to ensure its decisions are taken wholly in the interest of its clients. LGT Vestra aims to ensure that all potential and actual conflicts are identified, recorded, evaluated, managed and monitored.

LGT Vestra does not engage in proprietary trading and therefore any conflict of interest between us and our clients with regard to the advice we give, investment decisions we may take on a discretionary basis or the exercise of voting rights is eliminated.

LGT Vestra's conflicts of interest policy is available to clients upon request.

Annual Voting Declaration 2019

COBS 2.2B requires firms to disclose publicly on an annual basis how their engagement policy has been implemented. In 2019, our voting activity was as follows:

In 2019, we voted at a General Meeting of Capital Gearing Trust (CGT). We voted in favour of a resolution to allow the Board to issue shares for up to 30% of issued share capital without having to return to shareholders for additional approval. We voted in favour because one of the features of CGT is the ability of the Trust to issue shares so investors can buy at net asset value (NAV). As investors, we prefer this to trading at discount and premium.

 

Important risk information 

 

YOU SHOULD BE AWARE THAT A POSITIVE PERFORMANCE IN THE PAST IS NO GUARANTEE OF A POSITIVE PERFORMANCE IN THE FUTURE. THE RISK OF FALLING PRICES, FOREIGN CURRENCY LOSSES AND FLUCTUATING RETURNS DUE TO EXCHANGE RATES WHICH ARE UNFAVOURABLE FOR INVESTORS CANNOT BE EXCLUDED. IT IS POSSIBLE THAT INVESTORS WILL NOT GET BACK THE FULL AMOUNT THEY INVESTED. COMMISSIONS AND CHARGES LEVIED ON THE ISSUANCE AND REDEMPTION OF UNITS ARE DEBITED SEPARATELY TO EACH INVESTOR.

INVESTORS ARE SPECIFICALLY ADVISED THAT CERTAIN INVESTMENTS ARE HIGHLY VOLATILE. SUCH INVESTMENTS, SUCH AS DERIVATIVES, MAY BE SUBJECT TO SIGNIFICANT PRICE FLUCTUATION, WHICH MAY BE EQUAL TO OR GREATER THAN THE AMOUNT OF CAPITAL INVESTED.

CERTAIN SPECIFIC INVESTMENTS MAY NOT BE IMMEDIATELY REALIZABLE. IT MAY THEREFORE BE DIFFICULT FOR INVESTORS TO SELL AN INVESTMENT, REALIZE A PROFIT, OR OBTAIN RELIABLE INFORMATION AS TO ITS VALUE OR THE DEGREE OF RISK TO WHICH THE INVESTMENT IS EXPOSED.

WHEN BUYING OR SELLING INVESTMENTS INVOLVING A CONTINGENT LIABILITY, NOT ONLY MAY YOU LOSE THE AMOUNT INVESTED, BUT IN CERTAIN CIRCUMSTANCES YOU MAY ALSO BE REQUIRED TO PAY AN ADDITIONAL AMOUNT. 

Last updated May 2019

We take care to maintain high standards of service. If we are aware of client concerns or unease, we give priority to resolving the matter as quickly as possible. To assist with this process we have prepared procedures to ensure that complaints are handled fairly and within reasonable timescales. The below is a summary of our complaint handling procedure. A copy of our full procedure is available on request.

How to make a complaint
If you have a complaint about us and/or our services, you should direct this in the first instance to your investment manager. If you are uncomfortable doing so, your complaint can be directed to the Compliance Officer or the Chief Executive Officer. You can complain in writing, by telephone, by fax or via e-mail. Details can be found on the Contact us page.

What happens after I have complained?
Upon receipt of a complaint, a senior person who, where possible is independent of the case, will investigate the complaint. You will be given the name and contact details of the person dealing with your complaint. We will aim to resolve the complaint as quickly as possible. The person investigating your complaint will;

  • Initiate a record and file of your complaint; and
  • Acknowledge your complaint as soon as is reasonably practicable after the receipt of your complaint. This will generally be within 3 working days of receipt.

The acknowledgement may, especially in the case of an oral complaint, set out the nature of the complaint and may request further clarification if necessary. Your complaint will be investigated using our files together with reports from other parties if relevant. We may also write to you if further information is required.

We will keep you informed of the progress of the complaint investigation. After eight weeks, if a final response letter has not already been sent to you, you will receive a final response letter detailing our conclusions and resolution to the complaint. If we are not in a position to make a final response, we will give the reasons for the delay and will indicate when we expect to be able to provide a full response.

What if I am still not satisfied?
Within our final response letter to you, we will include details of the Financial Ombudsman Service (the “FOS”) whom, provided you are an eligible complainant, you have the right to right to refer a complaint if you are not satisfied with our response. Any referral to the FOS must be made within 6 months of receiving our final response. Further information about the FOS and whether you are an eligible complainant can be found at http://www.financial-ombudsman.org.uk or by calling 0800 023 4567.

LGT Vestra SmartWealth

Our SmartWealth General Terms and Conditions of Use are available to download here.