At Newton, we take the issue of privacy very seriously. We would like to assure visitors to our Website of the security, privacy and confidentiality that they would expect from a leading financial services institution.

Information collected

General

We do not collect any personal information from anyone who is merely visiting or browsing our Website. However, personal information may be requested from visitors who choose to respond to online surveys or to send Newton an email message.

Email and product inquiry

Visitors to our Website are invited to send email messages to Newton in order that we may respond to enquiries regarding Newton or our products or services. These contact details are available from the ‘Contact us’ page on this Website.

Use of cookies

A cookie is a small piece of information about an internet session that may be created when a visitor accesses a website. Our Website uses cookies to facilitate easier navigation within the site and provide a higher level of convenience for the visitor. Your internet browser is likely to accept cookies by default, however you can set your browser to reject cookies and delete them from your system at any time. The cookies used by Newton do not retrieve any information from the visitor’s personal computer. For more information, please read our Cookie policy.

Use of information collected

Improved customer service

Newton uses the information collected from visitors to our Website to address the specific needs of those visitors and to provide better customer service, including the supply of the latest information regarding Newton products.

Record of communications

The information collected is also used to maintain a record of communications between Newton and our Website visitors, and to comply with any applicable legal or regulatory requirements.

Data Protection & transfer of personal information

The uses of your personal information are covered by the registrations of the Newton Group under the Data Protection Act 1998. The personal information you supply may be used to provide the service applied for, confirm/update customer records and establish your identity. The information will be held on a database and may be shared with and used by any company within The Bank of New York Mellon Corporation in the UK and internationally who are obliged by law or agreement to comply with the principles set out in the European Directive 95/46/EC. Under the Act you have the right to obtain a copy of the information held about you by contacting Newton Investment Management Limited in writing at any time, for which you may be charged a fee. You hereby agree that we may use, disclose and transfer this personal data as described herein. If you do not wish for your details to be used in the above manner and/or if you do not wish to receive marketing approaches relating to products and services offered by The Bank of New York Mellon Corporation which we believe may be of interest to you, then please write to Newton Investment Management Limited at BNY Mellon Centre, 160 Queen Victoria Street, London EC4V 4LA.

Access to information collected

Employees

Selected Newton employees have access to the information collected in order to respond to each visitor’s needs and provide that visitor with information regarding specific products in which they may have an interest. Newton employees are instructed to use strict standards of care when handling the personal/confidential information of Newton customers, and the handling of such information is dealt with in The Bank of New York Mellon’s Code of Conduct, which applies to its subsidiaries. Newton employees who do not conform to The Bank of New York Mellon’s confidentiality rules are subject to disciplinary sanctions.

Third parties

Newton does not transmit any personal information collected through its Website to any third-party marketers. However, Newton does offer the opportunity to its Website visitors to link to the web pages of third parties who provide products and services not supplied by Newton. Once the visitor leaves the Newton site, Newton does not receive any further information from the visitor.

Visitors

Visitors having specific questions regarding any information they have sent to Newton through our Website should send an email to contact@newton.co.uk

Information for Residents of the United States

Protection of Social Security Numbers

In this section, “We” refers to the family of companies owned by The Bank of New York Mellon Corporation.

Like all financial services companies, we collect a variety of information about individuals, including but not limited to our customers and employees. In many cases that information includes individuals’ Social Security numbers. We use records of Social Security numbers for many purposes, especially to comply with federal and state laws such as tax laws and anti-money-laundering laws.

Our policy is (i) to comply with all laws restricting the use and disclosure of Social Security numbers, (ii) to protect the confidentiality of Social Security numbers, (iii) to prohibit the unlawful disclosure of Social Security numbers, and (iv) to limit access to Social Security numbers to our employees, and in certain cases to non-affiliated parties that provide services to us, based on their responsibilities. To safeguard Social Security numbers, we maintain physical, electronic, and procedural safeguards that are designed to comply with applicable legal standards. Our employees are prohibited from disclosing Social Security numbers for unauthorised purposes.

We may share Social Security numbers among our affiliated companies or with non-affiliated parties for administrative purposes, such as to process transactions, verify identities and service accounts. We disclose Social Security numbers as required or permitted by law, such as to the Internal Revenue Service or to credit bureaus. When necessary, we disclose Social Security numbers to regulatory agencies, law enforcement agencies, courts and parties to lawsuits.

We may share Social Security numbers among our affiliated companies or with non-affiliated parties for administrative purposes, such as to process transactions, verify identities and service accounts. We disclose Social Security numbers as required or permitted by law, such as to the Internal Revenue Service or to credit bureaus. When necessary, we disclose Social Security numbers to regulatory agencies, law enforcement agencies, courts and parties to lawsuits.

We may share Social Security numbers among our affiliated companies for marketing purposes, but only in compliance with legal restrictions, including required opportunities to opt out of such sharing. We do not, without consent of the individual involved, share Social Security numbers with parties not affiliated with us to enable them to market their own products or services.