Privacy Notice


This Notice gives information on how Pacific Assets Trust plc collects, uses and protects the personal data held about investors, clients, intermediaries and other business contacts.

This Notice describes how we will fulfil our obligations under applicable data protection laws, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the General Data Protection Regulation or GDPR).

Information about us

For the purposes of GDPR, the data controller is Pacific Assets Trust plc of 16 Charlotte Square, Edinburgh EH2 4DF (together we, us or our). 

First Sentier Investors (UK) IM Limited is responsible for the operation of this website and investment management (Stewart Investors)).

In addition, our registrar is responsible for maintaining the shareholder register.  As part of the agreement with our registrar, they are required to collect, store and use your personal data only in accordance with our instructions.  References in this Notice to us undertaking to do anything includes a reference to Stewart Investors in their capacity as investment manager, unless we otherwise specify.

Information we may collect

We collect from time to time, personal data on investors, intermediaries and other business contacts from a number of sources, including from: investor application forms; other Stewart Investors forms (including website forms); correspondence, conversations with clients, advisers, intermediaries; business cards; third party service providers to our funds (for example, transfer agents, administrators, distributors, custodians, paying agents); client advisers; other third parties; and from public sources.  This information may be collected directly from investors, intermediaries and business contacts, or indirectly from third parties, as follows:

From you

We may collect from you and process the following personal data, depending on the nature of our business relationship with you:

From third parties

We may collect personal data about you from third parties, depending on the nature of our business relationship with you, in particular:

How we will use the information we collect

The information we collect and use will depend on the nature of our business relationship with you, as follows:

We are entitled to use your personal data in these ways because:

Disclosure of your information

Transfers outside the EEA

We may transfer your personal data to Stewart Investors’ overseas affiliates (including outside the EEA) and/or allow the information to be accessed by their affiliates and their employees outside the EEA as well as within.  It may also be processed by personnel operating outside the EEA who work for us or for one of our third party service providers.

Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA or that the transfer is otherwise compliant with data protection laws.  This can be done in a number of ways, for example:

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a copy of any standard data protection clauses which we have entered into with recipients of your personal data) by contacting or by writing to us at Stewart Investors, 23 St. Andrew Square, Edinburgh, EH2 1BB, Scotland.

How long will we store your data?

Personal data held by us will be kept confidential.  How long we hold your personal data for will vary and will be determined by various criteria, including:

Your rights in relation to your data

If you wish to contact us for any of the reasons below, please e-mail us at by contacting or write to us at Stewart Investors, 23 St. Andrew Square, Edinburgh, EH2 1BB, Scotland.

Other Products and Services

Recording of telephone conversations and electronic communications

Please note that we are required to record telephone conversations (we will do so without a warning) and to keep copies of electronic communications.  We are required to keep copies of these recordings and electronic communications for a period of five years (or up to seven years at the request of a regulator).  Copies may be provided to you upon request by contacting

Changes to our Privacy Notice

This Notice was updated in May 2018.  We reserve the right to change this Notice at any time. We will ensure that any changes to this Notice are added to the Notice available on our website on their effective date. 


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