Privacy Policy

Last updated: September 2024

TwentyFour Asset Management LLP and any of its subsidiaries (“TwentyFour”, “us” or “we”) respect your right to privacy. This Privacy Notice explains how we collect, share and use personal data about you, and how you can exercise your privacy rights.

The Privacy Notice applies to the processing of personal data when you visit our website at twentyfouram.com, when you sign up to an account, when you visit our offices, register for events, fill out surveys or other promotional activity, or when you correspond with us or interact with us on social media platforms including but not limited to LinkedIn. You should read this Privacy Notice carefully so that you are fully aware of how and why we are using your personal information.

If you have any questions or concerns about our use of your personal data, then please contact us using the contact details provided at the bottom of this Privacy Notice.

What personal data does TwentyFour collect and why?

The personal data that we may collect about you generally falls into the following categories:

Information that you provide voluntarily

PurposeData typesLegal basis
Provide access to customer section of the website. 

Name, contact details (e.g. business mailing address, phone number, current and prospect e-mail address).

Employment details (e.g., your employer, job title), account details (e.g. login names, passwords), and public postings

Contractual necessity
To respond to any enquiries, provide product or service updatesName, contact details (e.g. mailing address, phone number, current and prospect e-mail address)

Contractual necessity

Legitimate interest

To provide promotional activitiesName, contact details (e.g. mailing address, phone number, current and prospect e-mail address)

Consent

Legitimate interest

Liaise with you and maintain a correspondence record.

Name, contact details (e.g. mailing address, phone number, current and prospect e-mail address).

Employment details (e.g. your employer, job title)

Legitimate interest
Website activity information including how your device interacted with our website to provide customers with superior service and to provide all visitors a smooth, efficient, and personalized experience while using our website. We use this information for our internal analytics purposes and to improve the content of our website and to make our website easier to use.Language and geographic location, website visits, time and activity, browser-type information from your device through cookies (see our cookie notice)

Legitimate interest

Consent

Ensure the security of our premises and website

Visitor logs for our premises

Device information as outlined above

Legitimate interest

Certain parts of our website may ask you to provide personal data voluntarily which include your name and contact details (e.g. mailing address, phone number, current and prospect e-mail address), employment details (e.g., your employer, job title), account details (e.g. login names, passwords), and public postings. We may ask you to provide personal data voluntarily when you subscribe for a product or service, subscribe for certain promotional activities, fill out surveys, and correspond with us.

From time to time, we may receive personal information about you from third party sources (including event sponsors or individuals who have asked us on your behalf) to provide information to you, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

TwentyFour understands the importance of protecting children's privacy, especially in an online environment. Therefore, TwentyFour’s services are not directed to or intended for children under the age of 16 and we do not knowingly collect any personal information from such users, except when a child is taking part in an educational event. In these cases we only collect participants names.

Who does TwentyFour share my personal data with?

We may disclose your personal data to the following categories of recipients:

  • to our group companies (including Vontobel entities), third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our website), or who otherwise process personal data for purposes that are described in this Privacy Notice or notified to you when we collect your personal data;
  • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
  • to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Privacy Notice;
  • to any other person with your consent to the disclosure.

Where personal data is shared we will have appropriate contractual arrangements in place to protect any such data – in line with applicable data protection laws and regulation. We do not sell, trade, or rent to others the personal data we collect online.

Your data protection rights

You may have the following data protection rights:

  • If you wish to access, correct, update or request deletion of your personal data, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below. 
  • In addition, you can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below. 
  • You have the right to opt-out of marketing communications we send you at any time. In addition, you can manage your preferences at any time. You can exercise these rights by clicking on the “unsubscribe” or “preferences” link in the marketing e-mails we send you or contact us using the contact details provided under the “How to contact us” heading below. 
  • Similarly, if we have collected and processed your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Cookies and similar tracking technology

A “cookie” is a small data file transferred by a website to your computer’s hard drive. We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal data about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice here.

How does TwentyFour keep my personal data secure?

We use appropriate technical and organisational measures to protect the personal data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data.

International data transfers

Your personal data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country. If service providers in a third country are used, they are obligated to comply with the data protection levels in the UK and Europe in addition to written instructions by agreement to the EU standard contractual clauses.

The information you provide may be processed and stored on cloud servers operated by the service providers and located in data centres within the UK, Switzerland, the EU/EEA and the United States. This means that when we collect your personal data we may process it in any of these countries. Your personal data will only be transferred to countries or international organisations if such transfer is required for the fulfilment of our obligations to you, prescribed by law or where you have given us consent. Where your personal data is transferred outside the UK, Switzerland or the EU/EEA, it will only be transferred if the relevant country (or data protection framework applicable to such country) is considered to provide an adequate level of data protection by the relevant authorities or institutions, or in the absence of such adequacy decision , if the recipient guarantees adequate protection based on appropriate safeguards provided by data protection laws and regulations (for example, Standard Contractual Clauses issued by the European Commission, and adapted to local law as required), or statutory exemptions provided by data protection laws and regulations (for example, your explicit consent).

Data retention

We retain personal data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

Links to other websites and third parties

The website may link you to third party website including LinkedIn. These third party websites will have their own data protection practices. We recommend that you review their respective privacy notices before accessing the third party links.

Publications and subscriptions

We may communicate with you via e-mail or physical mailings containing and offering news, event information or services (“Publication & Subscription Services”), subject to any restrictions under applicable laws and regulations. If you would rather not receive Publication & Subscription Services from us, you may “opt out” by following the “opt out” instructions in each e-mail footer or by contacting us.

Other legislation aspects, including telephone recording

In order to comply with applicable laws and regulations, we may be obliged to record telephone conversations with reference to operations concluded in the performance of our services. 

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will post those changes here so that you will always know what information we collect online, how we use it, and what rights you have. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.   

You can see when this Privacy Notice was lasted updated by checking the "last updated" date displayed at the top of this Privacy Notice. 

How to contact us

If you have any questions or concerns about our use of your personal data, please contact us at privacy@twentyfouram.com .

The data controller of your personal data is TwentyFour Asset Management LLP, The Monument Building, 11 Monument Street, London EC3R 8AF.