Privacy Policy

Our policy is to protect your privacy and your personal information. This Privacy Policy sets out the information we collect from you in order for you to use our services, how we manage that data and our reasons for holding it.Ā 

This notice describes how Sterling Investment Management (Sterling) uses personal data. It outlines Sterlingā€™s data protection obligations and your data protection rights under the General Data Protection Regulation 2018 (ā€œGDPRā€)

Our policy is to protect your privacy and your personal information. This Privacy Policy sets out the information we collect from you in order for you to use our services, how we manage that data and our reasons for holding it. We respect the confidentiality of your information and your right to privacy. We are bound by the General Data Protection Regulation and relevant laws and regulations.
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From time to time we may update this Privacy Policy and will notify you of these changes by posting the updated terms on our website www.sterlingim.co.uk
Sterling Investment Management Limited is the data controller of your personal information, and this policy applies to the processing of activities by us.
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  • Which data items are used, how they are used and who they are shared with;
  • Why this is done and the lawful basis;
  • Your rights and Sterlingā€™s obligations.

Collection of your data

As part of providing our services, or information about our services, to you, and to ensure we do this in a compliant way, under the authorization of our regulator and the General Data Protection Regulation, we must collect some personal information from our clients, potential clients, visitors to our website and service providers or suppliers. This may include third parties carrying out credit or identity checks on our behalf. The credit search is required to adhere to money laundering regulations.
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We may collect your name and contact details (such as your email address, phone number or address) in order to send you information about our products and services which you might have expressed interest in. We may collect this directly from you, or through a third party. If a third party collected your name and contact details, they will only pass those details to us for marketing purposes if you have consented to them doing so. It is in our legitimate interest to use your personal information in such a way. If you do not wish to receive this information, please contact us by emailingĀ info@sterlingim.co.ukĀ or by writing to us at the following address:
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Data Protection Officer
Sterling Investment Management LIMITED
Lynwood House, 2-4 Crofton Road,
BR6 8QE

Our web pages and emails may contain; cookies, web beacons or pixel tags or any other similar type of data analysis tools which allow us to track receipt of correspondence and to count the number of users that have visited our webpage or opened our correspondence.

Information collected

We may collect the following types of information from actual or potential customers:

  • Your full name, address and contact information including but not limited to phone number and email address;
  • Your date of birth and gender;
  • Your professional and employment details;
  • Your identification details such as your passport or driverā€™s licence;
  • Proof of address such as a bank statement or utility bill;
  • Your national insurance or tax identification number;
  • Criminal convictions data
  • Corporate information;
  • Information about your income or the source of your funds and wealth including details about your assets and liabilities;
  • Your trading experience and transaction history;
  • Financial information including investment portfolio details, income levels, and taxation details;
  • Information regarding relationships you have with banks and/or other financial institutions (including bank details);
We obtain this information through your use of our services or our websites, the onboarding process and from information provided in the course of ongoing customer communication.
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This information is held by us on servers based in the United Kingdom. When you interact with our services, our servers keep an activity log unique to you that collects certain administrative and traffic information including: the source of your IP address, the time of access, the date of access, and the web pages you visited. We need this information to provide you with our services.
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We are required to collect information about visitors to our premises. We may record information if your visit us such as your name, the date and time you arrived and left, who you are visited, your firm or employer name and your contact details.
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We may record any communications, email, electronic, by telephone, in person or otherwise, that we have with you in relation to the services we provide to you and our relationship with you. These recordings will be our sole property and constitute evidence of the communications between us. Any telephone conversation may be recorded without the use of a warning tone or any other further notice.
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We take care to ensure your personal information is safe, secure and is protected from misuse, interference, unauthorised access, loss, modification or disclosure. Your personal information is generally stored in our computer database. Any paper-based information is stored in secure areas. In relation to information that is held on our computer database, we apply the following guidelines:
  • Passwords are required to access the system and passwords are routinely checked and are not shared;
  • Data ownership is clearly defined and data is only held where necessary;
  • Employees have restricted access to certain sections of the system;
  • The system automatically logs and reviews all unauthorised access attempts;
  • Unauthorised employees are barred from updating and editing personal information;
  • All computers which contain personal information are secured both physically and electronically;
  • Data is encrypted during transmission over the network; and
  • Print reporting of data containing personal information is Limited.
We train our employees who handle personal information to respect the confidentiality of customer information and the privacy of individuals. We regard breaches of your privacy very seriously and will impose appropriate penalties where necessary.
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When we consider that personal information is no longer needed, we will remove any details that will identify you or we will securely destroy the records. We may need to hold some information and maintain certain records for up to 7 years after the end of us providing services to you. This is because we are subject to regulatory requirements and anti-money laundering laws which require us to retain;
  • Account opening forms and any documents used to comply for customer due diligence obligations; and
  • Supporting evidence and records of trades and transactions with you.
  • Details of your communications and relationship with us, for a period of seven years after our business relationship with you has ended.

Collection of personal information

Personal information will generally have been collected directly from you through our onboarding process and other communications with you. We will only use the personal information as set out in this Privacy Policy. We will not retain or have access to any debit/credit card information. We will not collect sensitive information about you without your consent unless an exemption in the regulations applies. These exceptions include if the collection is required or authorised by law or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.
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We may collect personal information about you from a third party or parties or share information with a third party, such as identity verification services, regulators, an introducing broker, marketing agencies, online vendors and service providers. We may engage the services of third-party service providers to provide technical support, process your online transactions and maintain your account. We take steps to ensure that our arrangements with third-party service providers and online vendors protect your privacy and that any such party is subject to the General Data Protection Regulations. Any personal information will only be disclosed to third parties in accordance with this Privacy Policy. We will not sell, lend or rent your personal information.
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We may be required to disclose your personal information if requested to do so by law, or if we believe in good faith that such action is necessary;
  • To comply with any legal process served on us or in circumstances where we are under a similar legal or regulatory obligation;
  • To protect and defend our rights or property; or
  • To act to protect the personal safety of users of the services or the public. If, in our sole determination, you are found to have cheated or attempted to defraud us, our Affiliates, or any other user of the Services in any way including, but not limited to, market or price manipulation, payment fraud, including use of stolen credit cards, or any other fraudulent activity (including any chargeback or other reversal of a payment) or prohibited transaction (including money laundering).

Where required to disclose the information we reserve the right to share information, together with your identity with other financial services providers, banks, credit card companies, and appropriate regulatory and legal agencies.

Transfer of personal data abroad

We may on occasion need to transfer some of your information to other group companies or service providers in countries in or outside the EEA (European Economic Area). This may happen if our servers or suppliers and service providers are located elsewhere. When we transfer your personal data outside the EEA, we will ensure the data recipient is subject to the same data requirements under GDPR. By using our services and providing us with your information, you consent to the collection, transfer, storage and processing of your information outside of the EEA.

Your personal data rights

  • You have the right to be informed,
  • You have the right to check what personal information is held by us, at no cost,
  • You have the right to have wrongly recorded data amended,
  • You have the right to ā€œOpt-outā€
  • You have the right to object to the processing of your personal information,
  • You have the right to request the transfer of your personal information,

You have the right to withdraw your consent.

Concerns or complaints

If you are concerned about us any aspect of our conduct regarding your privacy, you can make a complaint. We will act upon it promptly. To make a complaint, please e-mail us at info@sterlingim.co.uk We will respond and address, without delay, any request, question, complaint or enquiry you have about your personal information or our conduct in processing it. If you are not satisfied with the way we handled your response, or you believe we have not adequately resolved a matter, you have the right to complain to the Information Commissionerā€™s Officer (the ā€˜ICOā€™). You can find further details on the ICO website atĀ https://ico.org.uk/
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You also have the right, at any time, to complain to the Information Commissionerā€™s Office. As an independent UK authority, the ICO upholds information rights in the public interest, and promotes openness by public bodies and data privacy for individuals.
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Sterling Investment Management LIMITED is registered with the Information Commissionerā€™s Office. Ā 

Cookies Policy

Our website uses cookies. You consent to our use of cookies in accordance with the terms of this policy.
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Cookies consist of small files, often including unique identifiers, that are sent by web servers to web browsers, and which may then be sent back to the server each time the browser requests a page from the server.
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Cookies can be used by web servers to identity and track users as they navigate different pages on a website and to identify users returning to a website.
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Cookies may be either ā€œpersistentā€ cookies or ā€œsessionā€ cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies on this website

We use both session cookies and persistent cookies on this website.

How we use cookies

Cookies do not contain any information that personally identifies you, but personal information that we store about you may be linked, by us, to the information stored in and obtained from cookies.
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We may use the information we obtain from your use of our cookies for the following purposes:
  • To recognise your computer when you visit our website;
  • To track you as you navigate our website, and to enable the use of the some of the features on our website;
  • To improve the websiteā€™s usability;
  • To analyse the use of our website;
  • In the administration of this website;
  • To personalise content on our website for you.

Third-Party Cookies

When you use our website, you may also be sent third-party cookies. We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on usersā€™ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Googleā€™s privacy policy is available at:Ā http://www.google.com/privacypolicy.html

Blocking Cookies

Most browsers allow you to refuse to accept cookies. For example:

  • In Internet Explorer you can refuse all cookies by clicking ā€œToolsā€, ā€œInternet Optionsā€, ā€œPrivacyā€, and selecting ā€œBlock all cookiesā€ using the sliding selector;
  • In Firefox you can block all cookies by clicking ā€œToolsā€, ā€œOptionsā€, and un-checking ā€œAccept cookies from sitesā€ in the ā€œPrivacyā€ box.

Blocking all cookies will, however, have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use many of the features of this website.

Deleting Cookies

You can also delete cookies already stored on your computer. The method of doing so will depend upon your web browser. Instructions are available at the following URLs.

IMPORTANT INFORMATION

We consider the following to be very important and recommend that you read this warning and disclaimer before proceeding, as it explains certain legal and regulatory restrictions applicable to any investment services we provide.

Sterling Investment Management Limited (ā€œSterlingā€) is authorised and regulated in the UK by the Financial Conduct Authority (ā€œFCAā€). On the FCA register, our reference number is 933798. We are not regulated by any other Regulator.

Cookies

Sterling does use cookies on its website. By proceeding you consent to our use of cookies.
Please read more in our cookie policy.

Disclaimer

It is the responsibility of the individual user to consider his or her legal and regulatory position in the relevant jurisdiction, the risks associated with trading such products and to ensure that the use of the content and the subsequent making of any investment does not contravene any such restrictions or applicable laws and regulations of any jurisdiction. Please seek the advice of professionals, as appropriate, regarding the evaluation of any specific security, index, report, opinion, advice or other content. This does not exclude or restrict any duty or liability that Sterling has to its clients under the Financial Services and Markets Act 2000 (as amended from time to time) or any other regulatory system under the laws of applicable jurisdictions.

Sterling or its subsidiaries, associated entities, partners, employees, representatives or suppliers will not be liable, on any grounds whatsoever, contractually or not, for any direct or indirect damage that may arise as the result of it being possible or impossible to gain access to this site, the accessing, visiting or use of this site and/or the information provided, the sending, or receiving of information via this site and/or the operation or non-operation of this site, except in the event of intentional or serious blame on its part. The information contained on this site, including any third-party data is published in good faith and Sterling believes that the information is accurate at the time of publication but no representation or warranty, express or implied, is made by Sterling as to its accuracy or completeness and it should not be relied on as such.

Sterling is not authorised to deal with retail investors and this website and its contents are intended for professional investors only. Nothing in this website is intended to represent a recommendation or investment advice.Ā  Where we mention individual companies thisĀ is for illustrative purposes only, to demonstrate our diverse range of investments. Any mention of any company should not be taken as a recommendation or otherwise.Ā  If you are seeking company information, please visit the website of the relevant company.

Over the sixty years of the existence of the YFS Sterling Select Companies Fund, it has invested in many companies across several industries. The companies we mention reflect our investments and views on a given day and are subject to change, anytime and without any announcement or notice, due to corporate activity or general portfolio operation.

Sterling shall therefore have no liability, save for any liability that Sterling may have under the UK Financial Services and Markets Act 2000, for any loss or damage arising out of the use or reliance on the information provided including without limitation, any loss of profit or any other damage, direct or consequential. Nor will Sterling, its subsidiaries, associated entities, partners, employees, representatives or suppliers be, under any circumstances, liable for any corruption of data that may occur as the result of technical problems (e.g. transmission errors, technical failures, breakdowns, intervention of third parties, etc.) and/or for any damage or loss relating to software or hardware that is the result of any virus, defect or malfunction in relation to access or use of the site.

All the contents of this website are the property of Sterling Investment Management Limited.Ā  Nothing on this website is designed to grant any licence or right to use any image, trademark or logo. No act of downloading or otherwise copying from this website will transfer any legal entitlement to any software or material on the website to the transferer. Sterling Investment Management reserves all intellectual property rights to all material on the website and will enforce such rights to the full extent of applicable law.

Past performance is not a guide to future performance. The value of investments and the income from them may go down as well as up and you may not get back the full amount of your original investment. The information provided in this website is solely for use by individuals who are resident in the United Kingdom.Ā  It is not intended as, and should not be regarded as, an offer or solicitation to sell investments in any jurisdiction other than the UK. Individuals who are not resident in the UK should not continue as it may be contrary to local laws or regulations for them to receive information in connection with, or to apply for, a UK investment.Ā  By proceeding, you represent and warrant that you are not resident in, or a citizen of, a jurisdiction outside the UK.

Data Protection and Privacy:Ā To the extent any information you provide or which we obtain from this website constitutes personal data, you consent to its processing by Sterling and its agents and other third parties. If you are submitting your email you are also giving us permission to use it and send you emails. All such companies are required to maintain the confidentiality of such information. If you do not wish your information to be used in this way, you should advise Sterling in writing. Please see our Privacy Policy and Cookie Policy for more detailed information.

You should consider the website as an advertising document that describes Sterlingā€™s capabilities and is for information purposes only. None of the material contained on this website is intended to constitute an offer to sell, or an invitation or solicitation of an offer to buy any product or service provided by Sterling and must not be relied upon in connection with any investment decision. This website does not provide any specific investment advice and does not take into consideration the investment needs of any particular investor or investors. Nothing in this website should be construed as investment, tax, legal or other advice. Irrespective of your size or circumstances please seek professional financial advice to ascertain whether our fund is suitable. It is very likely that our fund may not be suitable, given your personal circumstances and risk profile.

The contents of this website have been approved by Sterling Investment Management Limited which is authorised and regulated by the Financial Conduct Authority.

Governing Law:Ā The content of this website should be construed under and governed by the laws of England and Wales and the courts of this jurisdiction will have exclusive jurisdiction in respect of any dispute that may arise, except where such content is expressed to be governed by the laws of another jurisdiction. If for any reason a court of competent jurisdiction finds any provision of this Important Information section unenforceable, that provision shall be enforced to the maximum extent permissible, and the remainder of this Important Information shall continue in full force and effect.

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