EU and UK Privacy Policy

Artisan Partners' protection of your account information is very important to you and to us. We maintain the confidentiality of your information and do not sell nor disclose it to anyone except as permitted or required by law or as described in this statement.

Artisan Partners generally has an obligation to maintain the confidentiality of your account information pursuant to regulatory requirements. Our Code of Ethics directs Artisan Partners’ employees regarding the permitted and restricted uses of account names and non-public information. Within Artisan Partners, access to information about your account is restricted to those employees who need to know the information to service your account. Employees are trained to follow our procedures to protect your privacy and are instructed to access information about you only when they have a business reason to obtain it. Artisan Partners uses physical, electronic and procedural safeguards to keep your information secure. Our third-party relationships use account information only to perform the services for which they have been hired, and are not permitted to use or disclose that information for any other purpose.

This privacy policy provides notice on how we handle your personal data and your rights in relation to that personal data introduced by the General Data Protection Regulation (Regulation (EU) 2016/679, the “GDPR”). Any changes we may make to our privacy policy in the future will be posted on this page. For the purpose of applicable data protection laws, the controllers of your personal data are Artisan Partners UK LLP of 25 St. James's Street, Third Floor, London SW1A 1HA, United Kingdom (“APUK”) or APEL Financial Distribution Services Limited, 202-204 Fitzwilliam Hall, Fitzwilliam Place, Dublin 2, D02 T292, Ireland (“APEL”) (together “we” or “us”). There may also be times where other third-parties assist with certain processes and may use your personal data for purposes they have determined to be lawful and necessary.

What data do we process?

When you interact with this website or through representatives of Artisan Partners’ EU and UK business, you may provide us with certain personal information which constitutes personal data within the meaning of GDPR. This may include, but is not restricted to, data such as name, residential address, email address, place of birth, date of birth, bank account details and details relating to investment activity. Our website uses cookies to facilitate easier navigation within the site and provide a higher level of convenience for the visitor. Whilst we typically only interacts with institutional investors, details of the individuals related to those institutions (employees, directors, consultants, etc.) may constitute personal data under GDPR. It is important that institutional investors provide such persons with a copy of this Privacy Policy to ensure they understand that their personal data will be provided to us and processed by us or our delegates and ensure, if required, that such persons have provided their consent to the processing of personal data by us.

If you wish to apply for employment at APUK or APEL through the Artisan Partners careers portal, you may be asked to submit certain personal information and application materials, such as a resume, an online career profile, or other general information.

Please note that we may also obtain information from third-party sources for due diligence purposes as appropriate to the context of our relationship with you, which may include information from publicly available sources (including third-party agencies such as credit reference agencies, fraud prevention agencies, law enforcement agencies, public databases, registers and records such as UK Companies House, CBI register and the FCA Register) and information from sanctions checking and background screening providers.

How we use personal data and who we share it with?

We use personal data held about you to:

  • manage our relationship with you and the institution that you work for or represent;
  • inform you about, and provide, our investment products and services to the institution that you work for or represent;
  • carry out our obligations under any contracts with the institution that you work for or represent;
  • assess your employment application (as applicable); and
  • comply with applicable laws and regulations.

We will process your personal data on one or more of the following legal bases:

  • where this is necessary for the performance of a contract;
  • where this is necessary for compliance with a legal obligation to which we or our affiliates are subject; and
  • where this is necessary for the purposes of the legitimate interest for us and our affiliates or a third-party and such legitimate interests are not overridden by your interests, fundamental rights or freedoms, such as:
  • allowing us to effectively and efficiently manage and administer the operation of our business; and
  • maintaining compliance with internal policies and procedures.

We may share your personal data within the Artisan Partners group for the purposes described above. In addition, we may also share your personal data outside of the Artisan Partners group as further described below:

  • with our business partners who are contractually obliged to comply with appropriate data protection obligations;
  • with representatives, agents, custodians, intermediaries and/or other third-party product providers appointed by our clients or prospective clients (such as accountants, professional advisors, custody service providers and product providers);
  • with third-party agents and contractors for the purposes of them providing services both to us (for example, APUK’s accountants, professional advisors, IT and communications providers, background screening providers, credit reference agencies and debt collectors) and to clients or prospective clients. These third-parties will be subject to appropriate data protection obligations;
  • with any depository, stock exchange, clearing or settlement systems, counterparties, dealers and others where disclosure of your personal data is reasonably intended for the purpose of effecting, managing or reporting transactions or establishing a relationship with a view to such transactions;
  • to the extent required by law or regulation, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators, auditors or public authorities), or to establish, exercise or defend its legal rights; and
  • if we sell any part of our business or our assets, in which case we may need to disclose your personal data to the prospective buyer for due diligence purposes.

Transfer of personal data

Artisan Partners is a global business. We may transfer data outside the UK and the European Economic Area (EEA), including to Artisan Partners Limited Partnership in the United States and other service providers. Where we transfer your personal data, we will do so in accordance with GDPR and other legal requirements, which may include the following:

  • the country to which we send the data might be approved by the European Commission as offering an adequate level of protection for personal data;
  • the recipient might have signed up to a contract based on “standard contractual clauses” approved by the European Commission, obliging it to protect your personal data;
  • where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme;
  • in other circumstances the law may permit us to transfer your personal data outside of Europe.

Please note that your data may also be disclosed to relevant tax and regulatory authorities as per legal or regulatory requirement that apply to the processing of your personal data.

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us as set out in the “Your rights” section below.

Data protection measures we take

We, our affiliates and our service providers shall apply appropriate information security measures designed to protect data from unauthorized access by third-parties or computer corruption.

Our retention of your personal data

With the exception of certain personal data related to recruitment, we, our affiliates and our service providers may retain your personal data for a period of at least seven years following the point where your business or employment relationship with us has ceased and will ensure that the period for which your personal data are stored is limited to a strict minimum, taking into account particular applicable requirements. Thereafter, we, our affiliates and our service providers will refrain from collecting any further personal data on you and shall take appropriate steps to dispose of any records containing your personal data, to the extent that this is operationally feasible and proportionate.

Personal data related to recruitment shall only be retained for 6 months after the conclusion of the recruitment process for a particular role. If the application is successful, information will be retained in accordance with our internal privacy policy.

Your rights

You have certain rights regarding our use of your personal data as listed below. To exercise these rights or, if you would like to contact us regarding your personal data, please email us.

  • the right to access your data (in an easily readable form);
  • the right to have your data erased;
  • the right to request that we correct your data if it is inaccurate or incomplete;
  • the right to restrict the use of your data;
  • the right to withdraw any consent given to the processing of your data (where applicable);
  • the right to receive information regarding any entities we disclose your data to;
  • the right to lodge a complaint with the relevant Regulatory Agency;
  • the right to object to the processing of your data.

Please note that the rights for you to have your data erased (the "right to be forgotten") or to object to the use of your data that applies in some contexts under GDPR may not always be applicable to the personal data you provide to us, given the specific nature of the purposes for which we use the data, as described above.

Should we wish to use your personal data for other specific purposes (including, if applicable, any purpose that requires your consent), we will contact you.