We appreciate that you, or a third party on your behalf, has provided us with your personal information.  Obtaining personal information from our individual and corporate clients is central to our goal of providing exceptional service.  However, we understand that in receiving this information, you expect us to treat it in an appropriate manner.

This policy is designed to provide you with further details on the type of information that we may collect about you, the purposes we might use that information for and the actions we take to safeguard your information. 

We will gather information from a number of sources.  Typically, it is primarily drawn from applications to open an account with Generation directly or with one of the funds operated by it (a “Generation Fund”). Please note that by investing in a Generation Fund, you authorise that fund to release information about you to Generation.  As a fund investor, you may but will not necessarily be a client of Generation directly.  If you are unclear as to your status as a client of Generation, please contact our General Counsel.

We will also collect information from you if you contact us directly, for example if you submit a query via our website. After an account is established and/or as our business relationship develops, we may gather further information from you as you transact with us or the Generation Funds or make servicing requests of us.

In addition to the information provided directly by you, we may gather information about you from third parties for the purposes of providing our services.  This includes other persons that you may instruct to assist you with your dealings with Generation or a Generation Fund, for example, your professional advisers, custodian or investment manager.  We may also seek information from credit and individual reporting agencies about you.  Third parties may be asked to undertake due diligence about you to assist us in respect of our responsibilities to combat financial crime, to ensure we are in compliance with applicable sanctions regimes, as well as helping us establish and maintain client relationships which we believe are in the best interests of both Generation and its clients.

In accordance with our legal obligations under applicable financial services regulations we will record communications with you, including all telephone calls. We may also monitor your e-mails.  We will do this in a proportionate manner and in accordance with applicable laws and regulations designed to protect your privacy in this sensitive area.  We will not access your information regularly in this way and will only use this information for compliance, internal control or security purposes to help us comply with our legal and regulatory obligations and as evidence of transactions.

We may also collect information from publicly available sources so that Generation can research potential investment opportunities and understand developments in the market. This could include, for instance, information about the management and other personnel at a company which Generation may be interested in investing in. It could also include the personal information of industry experts who provide insight and market analysis to Generation. 

Lastly, we may use close circuit television and recording systems in our offices to protect our staff and physical assets.  The owners of the buildings we occupy may operate similar systems.  As a result, your physical image may be captured by us on our premises.