Elwood

Elwood

Cookies and Privacy

Cookies and Privacy

This Cookies and Privacy Policy describes how we handle your personal information on our site. It applies generally to our site. In addition to the privacy practices set out in this Cookies and Privacy Policy, we have Terms of Use which incorporate the terms of this Cookies and Privacy Policy. Some words used in this Cookies and Privacy Policy are defined in our Terms
of Use.

1. Personal or other data that we collect
"Personal data" is any information that relates to you and that identifies you either directly from that information or indirectly, by reference to other information that we have access to. We receive personal data directly from you when you use our website or one of our online services by collecting information about your visit and how you interact with our website.

When you visit one of our websites, we automatically collect, store and use technical information about your equipment and interaction with our website. This information is sent from your computer to us using a variety of cookies (explained further below).

In addition, we may collect and process the following data about you in accordance with this Cookies and Privacy Policy:

— information that you provide to us via our site (including your email address, name and telephone number);

— if you contact us, we may keep a record of that correspondence; and

— details of your visits to our site and the materials and information that you access.

2. How we use your personal data
We will only use your personal data fairly and where we have a lawful reason to do so.

We are allowed to use your personal data if we have your consent or another legally permitted reason applies. This includes to fulfil a contract with you, when we have a legal duty to comply with, or when it is in our legitimate business interest to use your personal data. We can only rely on our legitimate business interest, if it is fair and reasonable to do so.

Our use of your personal data depends on how and where you interact with us but generally we expect to use data held about you in the following ways:

— to support your interaction with us, including to ensure that the content of our site is presented in the most effective manner for you and your computer;

— to provide you with market insights, product material or other information, in each case which you may have requested through our site;

— to notify you about changes to our site and to ensure the ongoing accuracy and relevance of such data;

— to carry out any security or other verification activities to ensure the proper operation of our site or to ensure compliance with our regulatory obligations;

— for general internal research purposes, including to identify and analyse the regularity of the use of our site and the nature of our site’s users; and to design products and services for your use.

We may share your personal data with third parties when you have consented to us doing so.

We will only transfer your personal data outside of the European region under the following circumstances: (i) where the transfer is to a country or other territory which has been assessed by the European Commission (or an equivalent UK body) as ensuring an adequate level of protection for personal data; (ii) with your consent; or (iii) on the basis that the transfer is compliant with General Data Protection Regulation and other applicable laws.

Please contact our Legal team at legal@elwoodam.com → if you have any questions regarding the above.

3. Your rights regarding your personal data
You have certain rights regarding how we use and keep your personal data. These are:

— you can require us to stop processing your information for direct marketing purposes; if you withdraw your consent, we may not be able to provide certain products or services to you; and

— you have the right to object to our use of your personal data more generally.

You may also have the right, in certain
circumstances to:

— be provided with a copy of any personal data that we hold about you, with certain related information. There are exceptions to this right; for example where information is legally privileged or if providing you with 


— the information would reveal personal data about another person;


— to require us, without undue delay, to delete your personal data;


— to "restrict" our use of your information, so that it can only continue subject to restrictions; and


— to require personal data which you have provided to us and which are processed by using automated means, based on your consent or the performance of a contract with you, to be provided to you in machine readable format so that they can be "ported" to a replacement service provider.


You can exercise the above rights, where applicable by contacting our Legal team at legal@elwoodam.com →. We will require you to provide satisfactory proof of your identity in order to ensure that your rights are respected and protected. This is to ensure that your personal data is disclosed only to you.

This Cookies and Privacy Policy describes how we handle your personal information on our site. It applies generally to our site. In addition to the privacy practices set out in this Cookies and Privacy Policy, we have Terms of Use which incorporate the terms of this Cookies and Privacy Policy. Some words used in this Cookies and Privacy Policy are defined in our Terms
of Use.

1. Personal or other data that we collect
"Personal data" is any information that relates to you and that identifies you either directly from that information or indirectly, by reference to other information that we have access to. We receive personal data directly from you when you use our website or one of our online services by collecting information about your visit and how you interact with our website.

When you visit one of our websites, we automatically collect, store and use technical information about your equipment and interaction with our website. This information is sent from your computer to us using a variety of cookies (explained further below).

In addition, we may collect and process the following data about you in accordance with this Cookies and Privacy Policy:

— information that you provide to us via our site (including your email address, name and telephone number);

— if you contact us, we may keep a record of that correspondence; and

— details of your visits to our site and the materials and information that you access.

2. How we use your personal data
We will only use your personal data fairly and where we have a lawful reason to do so.

We are allowed to use your personal data if we have your consent or another legally permitted reason applies. This includes to fulfil a contract with you, when we have a legal duty to comply with, or when it is in our legitimate business interest to use your personal data. We can only rely on our legitimate business interest, if it is fair and reasonable to do so.

Our use of your personal data depends on how and where you interact with us but generally we expect to use data held about you in the following ways:

— to support your interaction with us, including to ensure that the content of our site is presented in the most effective manner for you and your computer;

— to provide you with market insights, product material or other information, in each case which you may have requested through our site;

— to notify you about changes to our site and to ensure the ongoing accuracy and relevance of such data;

— to carry out any security or other verification activities to ensure the proper operation of our site or to ensure compliance with our regulatory obligations;

— for general internal research purposes, including to identify and analyse the regularity of the use of our site and the nature of our site’s users; and to design products and services for your use.

We may share your personal data with third parties when you have consented to us doing so.

We will only transfer your personal data outside of the European region under the following circumstances: (i) where the transfer is to a country or other territory which has been assessed by the European Commission (or an equivalent UK body) as ensuring an adequate level of protection for personal data; (ii) with your consent; or (iii) on the basis that the transfer is compliant with General Data Protection Regulation and other applicable laws.

Please contact our Legal team at legal@elwoodam.com → if you have any questions regarding the above.

3. Your rights regarding your personal data
You have certain rights regarding how we use and keep your personal data. These are:

— you can require us to stop processing your information for direct marketing purposes; if you withdraw your consent, we may not be able to provide certain products or services to you; and

— you have the right to object to our use of your personal data more generally.

You may also have the right, in certain
circumstances to:

— be provided with a copy of any personal data that we hold about you, with certain related information. There are exceptions to this right; for example where information is legally privileged or if providing you with 


— the information would reveal personal data about another person;


— to require us, without undue delay, to delete your personal data;


— to "restrict" our use of your information, so that it can only continue subject to restrictions; and


— to require personal data which you have provided to us and which are processed by using automated means, based on your consent or the performance of a contract with you, to be provided to you in machine readable format so that they can be "ported" to a replacement service provider.


You can exercise the above rights, where applicable by contacting our Legal team at legal@elwoodam.com →. We will require you to provide satisfactory proof of your identity in order to ensure that your rights are respected and protected. This is to ensure that your personal data is disclosed only to you.

4. What are cookies?
Cookies are small text files which are placed on the computer of a website user to provide the website operator with information about use of our site. They are used to enable websites to function or to provide information to the owners of a website.

Some cookies are deleted when you close down your browser. These are known as session cookies. Others remain on your device until they expire or you delete them from your cache. These are known as persistent cookies and enable us to remember things about you as a returning visitor.

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 →. Alternatively, you can search the internet for other independent information on cookies.

5. Why do we use cookies?
In broad terms we use cookies on our site for the following purposes:

Analytical purposes: Analytical cookies allow us to recognise, measure and track users of our site in anonymous form. The information collected includes the number of visitors to our site, where visitors have come to our site from and the pages that they have visited. This helps us to improve the way our site works, for example, by determining whether site visitors can find information easily, or by identifying the aspects of websites that are of the most interest to them (this is further explained below).

Usage preferences: Some of the cookies on our site are activated when visitors to our sites make a choice about their usage of our site. The site then ‘remembers’ the settings preferences of the user concerned. This allows us to tailor aspects of our site to the individual user.

Disclaimer: We use cookies on our site to record when a site visitor has seen a policy, such as this one, or provided consent, such as consent to this policy and our Disclaimer. This helps to improve the user’s experience of our site – for example, it avoids a user from repeatedly being asked to consent to the same terms.

Session management: The software that runs our websites uses cookies for technical purposes needed by the internal workings of our servers. For instance, we use cookies to distribute requests among multiple servers, authenticate users and determine what features of our site they can access, verify the origin of requests, keep track of information about a user’s session and determine which options or pages to display in order for our site to function.

Functional purposes: Functional purpose cookies store information that is needed by our applications to process and operate. For example, where transactions or requests within an application involve multiple workflow stages, cookies are used to store the information from each stage temporarily, in order to facilitate completion of the overall transaction or request.

6. Your cookie preferences
To make full use of our site, your computer or mobile device will need to accept cookies, as our site will not function properly without them. In addition, cookies are required in order to provide you with personalized features on our site.

7. Third party cookies
When you visit our website, you may receive cookies that are set by third parties. These cookies are used for the purposes described in the “Why do we use cookies?” section of this policy and, in particular, refer to analytic cookies (described further below). We do not completely control the setting of these third party cookies, so we suggest you might wish to check the third party websites for more information about their use of cookies and how to manage them.

Analytic cookies are used to gather statistics about the use of the website in order to improve the performance and design of our services. For these purposes, analytic cookies collect information about your device type, operating system type, browser type, domain, other system settings, IP address, referring URLs, information on actions taken on the websites and the dates and times of your visits, as well as the country and time zone in which your device is located.

These cookies are provided by our third-party analytics tool provider, Google Analytics (a web analytics service provided by Google, Inc., whose servers may be in the UK, EU or in the United States of America). The information obtained through these cookies will be disclosed to, or collected directly by, this third-party service provider. For more information about Google Analytics' cookie and information practices (including the types of cookies used and their expiration date), please visit the link below:

Google Analytics →
You can opt-out of Google Analytics data collection with the Google Analytics Opt-out Browser Add-on.

8. How to control and amend cookies
You can control which cookies you want to be stored on your computer through the settings in your web browser. You can configure your browser to accept or reject certain or all cookies, as well as see what cookies have been set.

If you wish to remove cookies set by our site from your browser in the future, you may delete them. The instructions for removing cookies from your computer or mobile device depend on the operating system and web browser you use. Please note, however, that withdrawing your agreement to the use of cookies on our site will impair the functionality of our site.

The "Help" menu in the toolbar of most web browsers will tell you how to change your browser's cookie settings, including how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. Below is some helpful guidance about how to make these changes.

Internet Explorer
If you are using Microsoft Internet Explorer and

4. What are cookies?
Cookies are small text files which are placed on the computer of a website user to provide the website operator with information about use of our site. They are used to enable websites to function or to provide information to the owners of a website.

Some cookies are deleted when you close down your browser. These are known as session cookies. Others remain on your device until they expire or you delete them from your cache. These are known as persistent cookies and enable us to remember things about you as a returning visitor.

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 →. Alternatively, you can search the internet for other independent information on cookies.

5. Why do we use cookies?
In broad terms we use cookies on our site for the following purposes:

Analytical purposes: Analytical cookies allow us to recognise, measure and track users of our site in anonymous form. The information collected includes the number of visitors to our site, where visitors have come to our site from and the pages that they have visited. This helps us to improve the way our site works, for example, by determining whether site visitors can find information easily, or by identifying the aspects of websites that are of the most interest to them (this is further explained below).

Usage preferences: Some of the cookies on our site are activated when visitors to our sites make a choice about their usage of our site. The site then ‘remembers’ the settings preferences of the user concerned. This allows us to tailor aspects of our site to the individual user.

Disclaimer: We use cookies on our site to record when a site visitor has seen a policy, such as this one, or provided consent, such as consent to this policy and our Disclaimer. This helps to improve the user’s experience of our site – for example, it avoids a user from repeatedly being asked to consent to the same terms.

Session management: The software that runs our websites uses cookies for technical purposes needed by the internal workings of our servers. For instance, we use cookies to distribute requests among multiple servers, authenticate users and determine what features of our site they can access, verify the origin of requests, keep track of information about a user’s session and determine which options or pages to display in order for our site to function.

Functional purposes: Functional purpose cookies store information that is needed by our applications to process and operate. For example, where transactions or requests within an application involve multiple workflow stages, cookies are used to store the information from each stage temporarily, in order to facilitate completion of the overall transaction or request.

6. Your cookie preferences
To make full use of our site, your computer or mobile device will need to accept cookies, as our site will not function properly without them. In addition, cookies are required in order to provide you with personalized features on our site.

7. Third party cookies
When you visit our website, you may receive cookies that are set by third parties. These cookies are used for the purposes described in the “Why do we use cookies?” section of this policy and, in particular, refer to analytic cookies (described further below). We do not completely control the setting of these third party cookies, so we suggest you might wish to check the third party websites for more information about their use of cookies and how to manage them.

Analytic cookies are used to gather statistics about the use of the website in order to improve the performance and design of our services. For these purposes, analytic cookies collect information about your device type, operating system type, browser type, domain, other system settings, IP address, referring URLs, information on actions taken on the websites and the dates and times of your visits, as well as the country and time zone in which your device is located.

These cookies are provided by our third-party analytics tool provider, Google Analytics (a web analytics service provided by Google, Inc., whose servers may be in the UK, EU or in the United States of America). The information obtained through these cookies will be disclosed to, or collected directly by, this third-party service provider. For more information about Google Analytics' cookie and information practices (including the types of cookies used and their expiration date), please visit the link below:

Google Analytics →
You can opt-out of Google Analytics data collection with the Google Analytics Opt-out Browser Add-on.

8. How to control and amend cookies
You can control which cookies you want to be stored on your computer through the settings in your web browser. You can configure your browser to accept or reject certain or all cookies, as well as see what cookies have been set.

If you wish to remove cookies set by our site from your browser in the future, you may delete them. The instructions for removing cookies from your computer or mobile device depend on the operating system and web browser you use. Please note, however, that withdrawing your agreement to the use of cookies on our site will impair the functionality of our site.

The "Help" menu in the toolbar of most web browsers will tell you how to change your browser's cookie settings, including how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. Below is some helpful guidance about how to make these changes.

Internet Explorer
If you are using Microsoft Internet Explorer and

you wish to block our website cookies, you can perform the following actions:

1. On your browser tools menu, select 'Internet Options'
2. Click on the 'Privacy' tab and then on the 'Sites' button
3. Type into the 'Address of website' field: www.elwoodam.com
4. Click on the 'Block' button
5. Click on the OK button

Other browsers
Guidance on how to block website cookies on other browsers can be found below:

Firefox cookie management →
Chrome cookie management →
Safari cookie management →

9. Consent
By using our website and accepting this policy you (i) consent to the processing of your personal data in accordance with this Cookies and Privacy Policy and our Terms of Use →, (ii) warrant that all data provided by you is true and accurate, and (ii) agree that unless you have set your device's browser to reject them, we can place the types of cookies set out above on your device, and use the data derived from such cookies in accordance with this Cookies and Privacy Policy.


you wish to block our website cookies, you can perform the following actions:

1. On your browser tools menu, select 'Internet Options'
2. Click on the 'Privacy' tab and then on the 'Sites' button
3. Type into the 'Address of website' field: www.elwoodam.com
4. Click on the 'Block' button
5. Click on the OK button

Other browsers
Guidance on how to block website cookies on other browsers can be found below:

Firefox cookie management →
Chrome cookie management →
Safari cookie management →

9. Consent
By using our website and accepting this policy you (i) consent to the processing of your personal data in accordance with this Cookies and Privacy Policy and our Terms of Use →, (ii) warrant that all data provided by you is true and accurate, and (ii) agree that unless you have set your device's browser to reject them, we can place the types of cookies set out above on your device, and use the data derived from such cookies in accordance with this Cookies and Privacy Policy.


Elwood Asset Management LLP

Elwood Asset Management LLP

Disclaimer          Privacy

Disclaimer          Privacy