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SL Investment Management Ltd is committed to protecting and
respecting your privacy.
information about you, how we use it, the conditions under which we
may disclose it to others and how we keep it secure.
Any updates to this Policy will be published on our website so
please check this periodically to ensure that you remain happy with
any changes made. By engaging with us, you are agreeing to be bound
by this Policy.
Should you have any questions regarding this Policy you can
contact us using one of the following methods:
SL Investment Management Ltd is a UK based Alternative
Investment Fund Manager (AIFM) authorised and regulated by the
Financial Conduct Authority. We specialise in providing investors
with access to secondary insurance investments.
SL Investment Management Ltd is a registered company in England
and Wales; registered number 02485382.
In collecting your personal data we take responsibility as the
Data Controller. We acknowledge and agree that any personal data of
yours that we handle will be processed in accordance with all
applicable data protection laws in force from time to time.
We collect information about you when you use one of our
websites, enter information via one of our web forms, or contact us
via email or telephone to enquire about our range of products or
The personal information we collect, hold and process will
typically include your name, address, email address, telephone
number and if applicable, company name. We may also hold a log of
our communications with you made via email or telephone.
Where we provide a service, or enter into a transaction with
you, we may collect and hold financial and identification
information about you - for example, using a copy of your passport
and utility bill to fulfil regulatory obligations in terms of Know
Your Customer (KYC) checks; or processing your bank account details
to make payment for the proceeds of a financial transaction.
To help us improve the type of information and range of services
provided to you, we track general visitor interaction with our
websites using Google Analytics tracking code. This data is
analysed by us on an aggregated basis, and any personal information
stored within Google Analytics is deleted on a regular basis
according to our Data Retention Policy.
We may use your information to:
We review our retention periods for personal information on a
regular basis. We are legally required to hold some types of
information to ensure we meet our regulatory obligations - for
example, details of any financial transactions we complete with
you. We will hold your personal information only for as long as is
necessary for the relevant activity, or as long as is set out in
any relevant contract you hold with us.
All electronic personal data that we hold on you is stored on
our databases in the UK. Any paper files are held securely on site,
and where necessary archived at a local secure facility that
complies with data protection legislation.
We will not share, sell or rent your information to third
parties for their marketing purposes without your express
We may pass your information to our third party service
providers, agents, subcontractors and other associated
organisations for the purposes of completing tasks and providing
services to you on our behalf. For example, utilising third party
service providers to complete KYC checks; or, where you have
provided consent, working with third party email service providers
to engage in email marketing activities.
We are obliged to share your personal information with a third
party where there is a legal requirement for us to do so. For
example, working with the Financial Conduct Authority in the
prevention of fraud and financial crime.
Whenever we are required to disclose your information to a third
party, we will only disclose the personal information necessary for
them to complete the purpose for which they are engaged. We
maintain contracts with such parties, requiring them to keep your
information secure and to limit the use of the data solely to the
activity in which they are engaged by us.
We may transfer your personal information to a third party as
part of a sale of some or all of our business and assets or as part
of any business restructuring or reorganisation. However, we will
take steps with the aim of ensuring that your privacy rights
continue to be protected.
Your data will be retained for no longer than is necessary and
in accordance with our Data Retention Policy.
When you provide your personal data to us, you are providing us
with your consent to process your personal information. We may
subsequently process your personal information on the basis of our
legitimate interest. For example, when transacting an endowment
policy purchase according to your instructions.
You have the right at any time to ask for a copy of the personal
information that we hold about you. We do not process your data by
automated means so cannot provide the data in a machine readable
In addition to this right of access, you also have the following
Should you want to make a request for a copy of the information
we hold about you, or to exercise one of your rights as listed
above, please contact us using the contact details outlined at the
you also have the right to contact the lead supervisory authority
in the UK (the Information Commissioner's Office at the time of
If you have provided us with your consent to process your data,
for the purpose of using our services, you have the right to
withdraw this at any time. To withdraw your consent please contact
us using the contact details outlined at the beginning of this
When you provide us with personal information, we take steps to
ensure that it is treated securely and that any sensitive
information is encrypted in an appropriate manner. For example, our
websites utilise SSL encryption technology, indicated by a lock
icon which appears next to the domain URL in your web browser.
Therefore, personal information you enter via our encrypted web
forms is considered to be secure and cannot be intercepted.
However, information transmitted routinely over the Internet
(for example, emails) cannot be guaranteed to be totally secure. As
a result, whilst we strive to protect your personal information, we
cannot guarantee the security of any information you transmit to us
routinely via the Internet, and you do so at your own risk.
Once we receive your information, we make our best efforts to
ensure its security on our systems. Where we have given (or where
you have chosen) a password which enables you to access certain
parts of our websites, you are responsible for keeping this
password confidential. We request that you not to share your
password with anyone.
We may analyse your personal information to create a profile of
your interests and preferences so that we can contact you with
information relevant to you. We may make use of additional
information about you when it is available from external sources to
help us do this effectively. We may also use your personal
information to detect and reduce fraud and credit risk.
Like most other companies we may utilise cookies on our
websites. 'Cookies' are small pieces of information sent by an
organisation to your computer and stored on your hard drive to
allow that website to recognise you when you visit.
Cookies collect statistical data about your browsing actions and
patterns and do not identify you as an individual. For example, for
whether you have visited our website recently, and if not, to
display a disclaimer splash screen before allowing you to visit the
content on our website. This can help us to improve our website and
deliver a better more efficient and personalised service.
It is possible to switch off cookies by setting your browser
preferences. However, turning cookies off may result in a loss of
functionality when using our websites.
Our website may contain links to other websites run by other
organisations. This Privacy Notice applies only to our websites' so
we encourage you to read the privacy statements on the other
websites you visit. We cannot be held responsible for the privacy
policies and practices of other sites even if you access these
using links from our website.
In addition, if you linked to our website from a third party
site, we cannot be responsible for the privacy policies and
practices of the owners and operators of that third party site. We
recommend that you check the policy of these third party sites.
As part of the services offered to you, the information which
you provide to us may at times reside outside the European Union
("EU"). For example, should you email us from a country located
outside of the EU, or should we happen to use third party providers
who have servers located in a country outside of the EU.
These countries may not have similar data protection laws to the
UK. By submitting your personal data, you are agreeing to this
transfer, storing or processing. Rest assured that should we
transfer your information outside of the EU in this way, we will
take steps to ensure that appropriate security measures are taken
to protect your privacy rights in accordance with this Policy.
(last updated May 2018)