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Privacy Notice

This Privacy Notice informs you about how Amati Global Investors Ltd may collect and process information that relates to you, how we aim to protect your information, your rights and how you can exercise those rights.

Amati Global Investors Ltd is committed to the principles of good information management, and we intend to go beyond basic legal requirements when it comes to processing your information.  This is because we recognise and value the trust you place in us to handle your information in a lawful, fair, and transparent way.  We are committed to assuring you that your privacy is protected with us.


Amati Global Investors Ltd holds and processes personal data in accordance with the General Data Protection Regulation (GDPR) and is registered with the Information Commissioners Office. Our registration number is Z591809X.

Amati Global Investors Ltd is the "Data Controller" for the personal data of:

  • Investors who have, or have had, general accounts in the Amati Global Investors Inheritance Tax Portfolio Service that were not being held in an individual savings account (ISA).
  • Independent financial advisers and other financial intermediary business contacts.
  • Business contacts with whom we have a contractual relationship.
  • Company contacts who provide investment research information.

Amati AIM VCT PLC is the "Data Controller" of the personal data of.

  • Investors who invested in the Amati AIM VCT.

Amati Global Investors Ltd is a "Data Processor" of the personal data of:

  • Investors who invested in the TB Amati UK Smaller Companies Fund.
  • Investors who invested in the Amati AIM VCT.
  • Investors who have ISA accounts in the Amati Global Investors Inheritance Tax Portfolio Service.

As a Data Controller and a Data Processor we have responsibilities and obligations to ensure that we look after the personal data with which  we are entrusted in accordance with the GDPR.


If you have any questions about this privacy notice, or about how your data is handled, please contact:

Data Protection Officer
8 Coates Crescent
Edinburgh EH3 7AL

Email: dpo@amatiglobal.com
Telephone: 0131 503 9100


We monitor how you use our site, by collecting information about your computer and what pages you visit each time your computer requests a page from our website. This includes the IP address of your computer (or the temporary IP address assigned by your Internet Service Provider), and is limited to information found in standard webserver access logs.

You may knowingly provide us with personal details when you contact us via one of the email links on the website; for example, if you request further information from us about one of our products or services. This information might include your name, your postal address, your email address and your telephone number. We use this information to comply with your request, and send you the information you require.

We may also send you, from time to time, additional information about our products and services which we think may be of interest to you. We will not pass this information on to any third parties. You may request not to receive further information at any time by contacting  us via email on info@amatiglobal.com.

Please note that this privacy policy only covers this website. Any other websites which may have links to or from our website are subject to their own policy, which may differ from ours.

Cookies and this website.

Our website uses cookies. A cookie is a small file of letters and numbers that we put on your computer with your agreement. Our session cookie will expire when you close your browser.

We use the session cookie to record that you have read and agreed to the risk warning. It is good industry practice that visitors to our website have read the risk warning before seeing information about our financial products.

You can learn more about cookies, generally, at www.allaboutcookies.org

3rd Party Cookies.

Some of our web pages use 3rd party services, such as Youtube, which may use cookies. As some of these services are based outside the UK and the European Union, they may fall outside the jurisdiction of EU and UK laws. If you are concerned about this, you can visit the Information Commissioner's website for more information, or change the cookies settings on your browser.

Amati also maintains a presence on social media channels including LinkedIn and Twitter. If you share content from one of Amati's websites, a cookie may be used by the service you have chosen to share that content. Amati does not control those cookies.


When you contact us via social media outlets you are using services and/or applications that are outside the control of Amati Global Investors. We cannot guarantee the security of any communication made using social media and we advise that should you have any concerns that you look at the Privacy Notices that these applications publish.

When you contact us via email we use an industry standard tool called Transport Layer Security (TLS) to encrypt and protect email traffic.  If your email service does not support TLS you should be aware that any emails we send or receive may not be protected in transit.

We also monitor emails and attachments sent to us for identification of any viruses or malicious software.


When you contact us we may process your information for the following purpose or purposes:

  • General enquiries.
  • Requesting literature and reports concerning our financial products such as Fact Sheets, Newsletters, Prospectuses, and Offers for Subscription.
  • Enquiries about your investments.
  • Requesting services or engaging in a contract with us.
  • Investment research.
  • Complaints handling procedures.

We will process your information as part of the exercising of a contract you have with us, or in preparing a contractual offering to you, or if we believe we have a legitimate interest in contacting you.

In some circumstances, there may be a legal obligation placed upon us to process information and share it with third parties, for example for law enforcement or anti money laundering purposes.

Amati records all incoming and outgoing telephone conversations for lawful business regulation purposes.

In all cases we do not intend to collect or process more information than we need, nor retain that information for longer than is necessary.


This section explains what type of information we're collecting, the reason we collect it, and the legal basis for processing it. Where we are the data controller, either we, or our data processors may collect

  • Contact information, marketing and preferred communications preferences, so that we can update investors, their intermediaries and independent financial advisers with factsheets, newsletters, and notifications of events. We have a Legitimate Interest for processing personal data in this way.
  • We use contact information, and preferred communications preferences to send investors regulatory or legal notices. Our basis for processing personal data would be to fulfil a legal obligation.
  • We collect personal data to enable us to verify investors when they contact us. We need that personal data to fulfil a legal obligation.
  • Financial information of shareholders and the contact details of their Independent Financial Advisors and other Intermediary contacts, so that we can process investments in our financial products. We need to process that personal data in order to fulfil a legal obligation and to honour a contract.
  • Physical evidence of investors identity, so that we can comply with Money Laundering Regulations. This personal data is required in order to fulfil a legal obligation.
  • Contact details of individuals at companies who are either data processors or service companies we rely on to provide our business services. We collect this personal data in order to honour a contract.
  • Name and Contact details of key officers, of companies that Amati is considering investing in, used to support our investment process. We have a Legitimate Interest for processing personal data in this way.


The kind of information that we may ask you to entrust us with includes but is not limited to:

  • Basic personal details such as your name, address, email address, telephone number, date of birth or age, gender.
  • Marketing and preferred communications preferences.
  • National Insurance Number, Bank account details, Platform account details and other financially sensitive information including ownership of securities, valuations of investments, and dividend preferences.
  • Certified copies of passports, driving licences, bank or building society statements, utility bills or tax bills

We will not process any of your information as part of any automated decision making. In other words should we use your information to assist us in making any decisions, for example offering you a service, we will treat you and your information with respect and dignity and not use a machine to make decisions for us.


As part of any agreed contractual arrangements we have with you we may share your information with other organisations that we use to process that contractual service. In such cases we will work with that third party to ensure there are written contractual obligations in place that require the third party to protect your information as both you and we would expect, and that they do not process the information for any other reason than the specific reasons within the contract. We will ensure that your information is not subsequently shared further by these third parties without our agreement.

Where possible we aim to ensure that any third party with whom that information is shared is based within the United Kingdom or the European Union. In some instances, as part of our agreed contractual relationship with you, we may undertake an international transfer of information to a third party.

We do not share any personal data for the purposes of 3rd party marketing, nor do we buy any personal data lists for the purposes of marketing our products.

We may share information should there be a legal obligation for us to do so. These legal obligations may include, as examples, the prevention of fraudulent activity, criminal investigations, or the release of share register information under the Companies Act 2006


As part of our commitment towards continual improvement and ensuring your trust in us, Amati Global Investors reviews the retention periods of all types of information that we hold, whether that involves information that can identify someone or not.

We are committed to being transparent about the management of our information, and this includes ensuring that we do not continue to hold this information for longer than is necessary.


Amati Global Investors has the Cyber Essentials Plus accreditation.

We have developed technological controls (for example anti-virus solutions, firewall solutions, regular operating system security updates and electronic monitoring applications) together with organisational controls (for example policies, procedures, employee vetting and training) with the express aim of protecting your information.


At Amati Global Investors we want to work with you to ensure we deliver an excellent service to you, and we recognise that you should feel and remain confident that you are in control of how we use your information.

Within legislation and regulations governing the management of your information we embrace and fully support your rights and the exercising of these. The following paragraphs describe those rights to you and provide you with information as to how to exercise them.

Some of these rights include a legal obligation for Amati Global Investors to respond to any request without delay and in most cases within a calendar month. As Amati Global Investors recognises the importance of your information we will expand this requirement and aim to process any of your requests within one calendar month, irrespective as to whether it is a legal requirement.

Your right to be informed about the information we collect and process that can identify you.

You have a right to be informed what information is collected about you by Amati Global Investors, and for what purpose. This Privacy Notice is intended to give you information you may require in order to better understand what information is processed and why. We will also look for further opportunities to inform you when we are in communication with you.

Should you require any further clarification or information please contact the Data Protection Officer at the contact address provided at the start of this Privacy Notice.

Your right of access to your information.

You have a right to access the information with which you have provided us, or any other information we hold about you. Unless we consider the request to be exceptional or excessive (and we will communicate further with you should we consider this to be the case) then this service will be free.

You can exercise this right by contacting the Data Protection Officer via one of the contact addresses provided at the start of this Privacy Notice.

Your right to make changes to the information we hold.

If you believe that the information that Amati Global Investors holds about you requires updating, for example you have a new contact address, or believe that any information we hold is currently inaccurate, then you have a right to have changes made to it. This right is sometimes referred to as your right to rectification.

You can exercise this right by contacting the Data Protection Officer via one of the contact addresses provided at the start of this Privacy Notice.

Your right to have your information removed or deleted.

If you believe Amati Global Investors should no longer be processing information about you, or you no longer wish Amati Global Investors to process your information then you have a right to request that your information be deleted. This right is sometimes referred to as your right to erasure, or your right "to be forgotten".

You can exercise this right by contacting the Data Protection Officer via one of the contact addresses provided at the start of this Privacy Notice.

Your right to request that we temporarily restrict the processing of your information.

You have a right to request that we place a temporary halt to any processing of your information, rather than requesting that we delete your information. You may wish to exercise this right for example should you be involved in any dispute or legal proceedings regarding the processing of your information, or in connection with a contractual arrangement.

You can exercise this right by contacting the Data Protection Officer via one of the contact addresses provided at the start of this Privacy Notice.

Your right to have us transfer your information elsewhere in a readily available format.

This right allows you to obtain and re-use your personal information for your own purposes, to move it easily from one IT service to another in a secure manner. This right assists you to take advantage of other applications or services that can use this information to offer you a service. This right is sometimes referred to as the right to data portability.

You can exercise this right by contacting the Data Protection Officer via one of the contact addresses provided at the start of this Privacy Notice.

Your right to object to the processing of your information.

Should you no longer wish to have dealings with Amati Global Investors, for example you have been receiving marketing communications from us, and you no longer wish to be in receipt of these then you have a right to ask that we stop doing this. If you have previously given us your consent to process your information and we have relied upon this consent to contact you then you can withdraw this consent at any time. This right is sometimes referred to as the right to object.

You can exercise this right by contacting the Data Protection Officer via one of the contact addresses provided at the start of this Privacy Notice.

Your right to have any automated decision made about you reviewed.

If you believe that Amati Global Investors has made a business decision in respect of you that has been based entirely upon an automated process, for example profiling of your circumstances prior to offering of any services, then you have a right to ask for that decision to be reviewed. Please note that we do not make any decisions without human intervention, but believe that we should still be transparent and inform you of this right, even though we do not believe you will need to exercise it with us.

You can exercise this right by contacting the Data Protection Officer via one of the contact addresses provided at the start of this Privacy Notice.


We would like to work with you to understand how we can provide a better service to you in the exercise of your rights, and in our processing and use of your information. We understand the importance of your privacy and want you to feel that you can entrust us with your valuable information.

Should you be dissatisfied with how we have responded to you when you have tried to exercise your information rights with us then we would ask that you initially contact us to express your dissatisfaction and ask that we conduct an internal review of how we have responded. You can contact us at:

Compliance Officer
8 Coates Crescent
Edinburgh
EH3 7AL

You also have a right to lodge a complaint directly with an independent "supervisory body" should you wish. The supervisory body can act upon your behalf and investigate to ensure that your rights have not been compromised. Within the United Kingdom the supervisory body is the Information Commissioner's Office (ICO), and they can be contacted directly at:

Customer Contact
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF

or via telephone: 0303 123 1113
or via their website: www.ico.org.uk/concerns


Amati Global Investors aims to ensure that this Privacy Notice, which we understand may cover important and complex issues surrounding your privacy, has been written in a clear and straightforward way. We have tried to avoid the use of legalistic language and terminology. We welcome any feedback on how we can improve this Notice for you.

This Privacy Notice was last updated on 5th November 2018