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Legal Information

Last Updated : April 2013

You must read the following information before proceeding. It provides information on some of the laws and regulations applicable to this web site.

The information on this Site is issued and approved by Witan Investment Services Limited (WIS). Witan Investment Services Limited is registered in England no. 5272533 of 14 Queen Anne’s Gate, London SW1H 9AA. Witan Investment Services Limited provides investment products and services and is authorised and regulated by the Financial Conduct Authority. We may record telephone calls for our mutual protection and to improve customer service.

WIS's investment products are only available through this web site to UK residents and by proceeding this far you are representing and warranting that you are resident for tax and investment purposes in the United Kingdom. What follows is not an offer or invitation to acquire an investment, and should therefore not be relied upon by, any person anywhere other than the United Kingdom or any person in any jurisdiction where such an offer or invitation would be unlawful. Persons in respect of whom such prohibitions apply must not access this web site.

Where access to any part of this web site or a linked site is restricted or requires possession of a valid password, no other person should attempt to gain access to such part of the web site. Any prices and other information on this web site or a linked web site are provided solely to enable you to make your own investment decisions and do not constitute personal recommendations or advice.

You should be aware that the internet is not a completely reliable transmission medium. We shall not have any liability for any data transmission errors such as data loss or damage or alteration of any kind, including, but not limited to, any direct, indirect or consequential damage, arising out of the use of the services provided herein.

Messages that you send to us by e-mail are not secure. We recommend that you do not send any confidential information to us by e-mail. If you choose to send any confidential information to us via e-mail you do so at your own risk with the knowledge that a third party may intercept this information. Instructions sent by you via e-mail and to the Site are processed exclusively at your risk.

An application for any of  WIS’s investment products should be made having read fully not only the relevant application form, but also, for UK investors, the relevant terms and conditions of the key features document, brochure, and latest annual or semi-annual report applicable to the chosen product. All these relevant documents can be found on this web site. It is your responsibility to review such documentation and in any event by making an On-Line Application you will be deemed to be representing that you have read such applicable documentation and agree to be bound by its contents.

Our affiliates, officers and/or employees may have holdings in WIS’s investment products and may otherwise be interested in transactions that you effect in those products.

Please remember that past performance of an investment is not a guide to future performance. The value of an investment and the income from it can fall as well as rise as a result of market and currency fluctuations and you may not get back the amount originally invested. Tax assumptions may change if the law changes, and the value of tax relief (if any) will depend upon your individual circumstances. Investors should consult their own tax advisers in order to understand any applicable tax consequences.

If you are unsure about the meaning of any information provided on this web site, then please consult your financial or other professional adviser. We do not offer investment advice.

Otherwise than as specifically set out, the information on this web site must in no circumstances be copied, reproduced or redistributed in whole or in part. You may download or print copies of some of the documentation contained on this web site for your own private use only, provided that you do not change any copyright, trademark or other proprietary notices. All intellectual and other property information contained in this web site shall continue to be held by us and no rights of any kind in it shall pass to you.

This web site may contain or be linked to advice or statements of third parties. We make no representation as to the accuracy, completeness, timeliness or suitability of such information, and we have not and will not review or update such information and caution you that any use made of such information is at your own risk. Some of the information contained on this web site may also have been prepared or provided by third parties and may not have been verified by Witan Investment Services. Witan Investment Services hereby excludes any liability arising out of any preparation or provision of such information for the web site and makes no warranty as to the accuracy, suitability or completeness of any such information.

Witan Investment Trust Benchmark Source: FTSE International Limited (“FTSE”). FTSE is a trade mark of the London Stock Exchange Group companies and is used by FTSE under license. All rights in the FTSE indices and/or FTSE ratings vest in FTSE and/or its licensors. Neither FTSE nor its licensors accept any liability for any errors or omissions in the FTSE indices and/or FTSE ratings for underlying data. No further distribution of FTSE data is permitted without FTSE’s express written consent.

 

This web site is governed by the laws of England. On-line Applications will also be governed by English law.

This Important Legal Information may be updated from time to time. You will be advised within this site of the last date on which any updates have been made. If you choose to bookmark pages within the web site for future use, you agree that it is your responsibility to check if any such updates have been made since you last visited this web site.

PRIVACY POLICY

We take the privacy of our customers very seriously and we are concerned to protect your personal data. We believe it is important that you know how we treat the information about you that we receive through this web site. Therefore we will only use your personal information as set out in this Privacy Policy. If you have any questions in relation to the information we hold about you or our use of that information, please feel free to contact us.

Personal Data

In general, you may visit this web site without revealing any information about yourself. Our servers collect the domain names of visitors and this data is only held for the period you are logged onto the web site. This information is anonymous and we aggregate it to measure the use of and to improve the content of our web site.
We will, however, retain and use all personal information (for example name, e-mail address and your financial details) that you provide to WIS via this web site, including for example, when you register for the WIS's Online Service, request a brochure, or apply for an account.

Use of Your Personal Data

We will use the personal data which you provide to us on the web site to process any applications you make and to keep you informed (via e-mail and other methods of contact) about our products and services and those of our affiliate companies which may be of interest to you. If you do not want us to use your personal data to inform you of such products and services please indicate this in the tick box provided online. We may also pass your data to third parties, selected by us, with respect to certain activities. We will ensure that any such third parties will only use your information in accordance with this Privacy Policy. For administration purposes your personal data may be transmitted to other entities, including entities located outside the European Economic Area in countries where laws do not exist to protect personal information. These entities will be required to ensure that your personal information is protected to the standard applicable under United Kingdom data protection law.

Use of cookies by Witan

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

The table below explains the cookies we use and why.

Cookies Name Purpose More Information
Browser Session Cookie SESS[uniqueID] This cookie is set by the website when a user visits the site and is an essential cookie for the operation of the website This cookie does not display any identifiable or tracking information and is deleted when the user closes their browser
Text Size textsize If you change the text size using the built in + - buttons the website will set a cookie remembering your preferences for that session only. No identifiable information is captured
Check for JavaScript has_js Many of the charting features of the site require JavaScript. The website checks to see if you have this enabled to enhance the functionality of the website. No identifiable information is captured
Google Analytics

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These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Click here for an overview of privacy at Google

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

SUMMARY OF CONFLICTS OF INTEREST POLICY

Conflicts of Interest

A regulatory requirement arising from the implementation of the Markets in Financial Instruments Directive on 1 November 2007 is the need for us to provide you with a summary description of our policy on conflicts of interest and when a material interest or conflict of interest may or does arise, to disclose to you the manner in which we will ensure your fair treatment.

Witan Investment Services Ltd – Conflicts of Interest Policy: A Summary Description

Our policy remains to always manage any conflict in your best interests, to always disclose any conflict where relevant and to not undertake the activity if a conflict cannot be effectively managed (and disclosure would not be appropriate). Our aim is to ensure that there is effective management of conflicts that may arise when our interests and yours differ or where discharging our duties to one client could make it difficult to comply with the duties owed to another client. For instance a potential conflict could arise in instances where we aggregate your order to purchase or sell shares with those of another client or where we act for both the buyer and seller in a transaction. Additionally, a conflict could arise between our interests and yours when the underlying investment trusts undertake transactions in their own shares. We will ensure that we will not knowingly act on your behalf in relation to a transaction unless we have taken reasonable steps to ensure your fair treatment. Where we are unable to manage a specific conflict, we will notify you of the circumstances in order that you are able to take an informed decision of whether to proceed with the transaction or not. 

We operate a Conflicts of Interest Policy which is communicated to all relevant employees and which identifies the types of conflict that may arise and provides instructions on the management of those conflicts. Under the Policy we maintain a record of identified potential conflicts. Further, we regularly review our business to identify potential conflicts of interest and to assess whether we are taking appropriate steps to manage those that could have an adverse effect on clients. Formal reports are made to the Board and senior management. There are also specific policies and procedures on when and how employees are permitted to undertake personal account transactions, restrictions on the offering and receiving of gifts to or from clients, and an outright ban on any gift that could be construed as an inducement. As part of our conflicts management policy we also consider the way in which our staff are remunerated, in order to ensure that remuneration structures do not create a conflict between  incentives given to staff and our clients’ best interests. Any client who wishes, may receive a copy of the full Conflicts of Interest Policy.

Data Protection Act 1998

We treat all customer information in a confidential and secure manner. We comply with the Data Protection Act 1998, which lays down a set of standards that must be followed whenever personal information is processed. We may use the information provided by you to check and verify your identity, and the identity of any other persons that may provide monies on behalf of any investments made in your name. We may provide this information to credit reference and fraud prevention agencies that will record this information and may make this information available to others in order to verify your identity. If we are unable to verify your identity initially, we may request further information from you. If you provide false or inaccurate information that result in us suspecting fraud, we will notify the relevant authorities. We may transfer your information to a jurisdiction outside the European Economic Area but will only do so if that jurisdiction ensures an adequate equivalent level of protection for your rights and freedom in relation to the processing of your information. You have the legal right to find out what information, if any, is held by us about you and the details of the agencies that we may obtain information from and may record information with about you. A request for this information may be subject to a fee by us and by the agencies and must be in writing to us.  

Further Information

Please note that we may change this Privacy Policy or Important Legal Information from time to time so please check it regularly.

You have the right, at any time, to access and correct your personal information and privacy preferences or request to be removed from our mailing lists by writing to us at Witan Investment Services Ltd, 14 Queen Anne’s Gate, London SW1H 9AA.

We may record telephone calls for our mutual protection and to improve customer service.

This web site may contain links to other sites. We are not responsible for the content or privacy practices of those other sites.

© 2013. Issued by Witan Investment Services Ltd, authorised and regulated in the UK by Financial Conduct Authority.

 

 

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