Privacy Policy
https://www.icevequalvotes.org/ (our website) is provided by The Investor Coalition for Equal Votes (ICEV), a coalition of institutional investors and investor-governed non-profit organizations. The primary data controllers for ICEV activities are Railpen Limited and the Council of Institutional Investors (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website, meaning we are legally responsible for deciding how and for what purposes it is used.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
Given the nature of our website, we do not expect to collect the personal data of anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with our website please let us know so that we can delete that data.
What this policy applies to
This privacy policy relates to your use of our website only.
Throughout our website we may link to other websites owned and operated by certain trusted third parties. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.
Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:
- your name, address and contact information, including email address, telephone number, and company details, if you choose to give this to us
- location data, if you choose to give this to us
- details of any information, feedback or other matters you give to us by phone, email, post or via social media
- your activities on, and use of, our website
- your personal or professional interests, if you choose to give this to us
How your personal data is collected
We collect personal data from you:
- directly, when you enter or send us information, such as when you contact us (including via email), send us feedback or contact us via our website, post material to our website and complete customer surveys or participate in meetings or research; and
- indirectly, such as your browsing activity while on our website (for further information, please see our Cookie Policy).
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, which is called a lawful basis. ICEV’s lawful basis for the use of your personal data is for our legitimate interests or those of a third party, or, in some circumstances, where you have given your consent.
A legitimate interest is when we have a reason to use your personal data that supports our mission and objectives, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
What we use your personal data for
Our reasons
Arranging meetings so that you can participate in the ICEV’s activities
For our legitimate interests
Conducting research with your participation
For our legitimate interests
Enforcing legal rights or defend or undertake legal proceedings
Depending on the circumstances:
- to comply with our legal and regulatory obligations
- in other cases, for our legitimate interests, i.e. to protect our coalition, interests and rights
Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website and for retaining and evaluating information on your recent visits to our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended
Depending on the circumstances:
- your consent as gathered (see our Cookie Policy)
- where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can in supporting our mission and objectives
If you have provided such a consent you may withdraw it at any time (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Communications with you not related to marketing, including about changes to our terms or policies or notices
Depending on the circumstances:
- to comply with our legal and regulatory obligations
- in other cases, for our legitimate interests, i.e. to be as efficient as we can in supporting our mission and objectives
Protecting the security of systems and data used to provide the services
To comply with our legal and regulatory obligations
Statistical analysis to help us understand our participant base
For our legitimate interests
Updating and enhancing our records
to comply with our legal and regulatory obligations
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our operations, e.g. to record and demonstrate evidence of your consents
To comply with our legal and regulatory obligations
Marketing our mission and objectives to existing and former participants
For our legitimate interests, i.e. to promote our aims and forward our purpose with the help of our participants
The audit of our activities where required
For our legitimate interests, i.e. to maintain and demonstrate that we operate at the highest standards
To share your personal data with members of our coalition to ensure that we may operate effectively
Depending on the circumstances:
- to comply with our legal and regulatory obligations
- in other cases, for our legitimate interests, i.e. to promote our aims and forward our purpose with the help of our participants
Marketing
We will use your personal data to send you updates (by email, telephone or post) about our activities, including invitations to meetings and otherwise to participate in our research and activities where you have provided us with your consent to do so. You may withdraw your consent at any time by contacting us (see the section How to contact us’ below).
Who we share your personal data with
We may, in the course of our activities, occasionally share personal data with:
- third parties we use to help us deliver our activities which you may participate in, including third party information technology service providers
- third parties we use to help us run our website, including website hosts and website analytics providers
- the organisations and/or entities who are members of the ICEV
- our professional advisors, including external auditors, lawyers and other advisors
- if compelled to do so: law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
- other parties who may become part of our coalition
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
Transferring your personal data out of the UK
The UK and other countries outside UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.
We may transfer your personal data to organisations and/or entities who are members of the ICEV.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
- the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR.
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
- a specific exception applies under relevant data protection law
Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR.
Your rights
You generally have the following rights, which you can usually exercise free of charge:
Access to a copy of your personal data
The right to be provided with a copy of your personal data
Correction (also known as rectification)
The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)
The right to require us to delete your personal data - in certain situations
Restriction of use
The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data
Data portability
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party - in certain situations
To object to use
The right to object:
- at any time to your personal data being used for direct marketing (including profiling)
- in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
Not to be subject to decisions without human involvement
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
We do not make any such decisions based on data collected by our website
The right to withdraw consents
If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time
You may withdraw consents by contacting us.
Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below).
If you would like to exercise any of those rights, please email us - see below: ‘How to contact us’.
When contacting us please:
- provide enough information to identify yourself, and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioners Office, who may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Changes to this privacy policy
We may change this privacy policy from time to time - when we make significant changes we will take steps to inform you.
How to contact us
If you would like to contact us, please email: contact@icevequalvotes.org
Do you need extra help?
If you would like this policy in another format (for example audio, large print, braille) please contact us using the details set out above.
Join us in our mission to challenge the entrenched and material problem of unequal voting rights
The ICEV Steering Group is the governing body of ICEV. It is responsible for making strategic decisions regarding, and oversight of, the Coalition’s activities. Asset owner members of ICEV are eligible to apply to join the Steering Group, membership of which is decided by a simple majority of existing ICEV asset owner members. ICEV’s chair is responsible for the overall management of the coalition, which includes leading the assessment of potential engagement targets, fielding ICEV member input, scheduling meetings, initiating discussion during engagements and leading on external communications. ICEV’s vice chair is responsible for ICEV member growth and retention, and for the continuity of scheduled activity in the event of the chair’s absence. ICEV members actively help the chair identify prospective engagement partners as well participate in engagements themselves, should they wish to. ICEV members may abstain from participating in any ICEV letter or engagement for any reason.
In line with ICEV’s Antitrust policy, the responsibility lies with each of the individual ICEV members to understand and adhere to all laws and regulations applicable to them. This includes, but is not limited to, relevant antitrust and competition laws. ICEV members explicitly avoid coordinating on company-specific investment decisions, meeting-specific proxy voting decisions or any other business-related decisions. ICEV’s members are responsible for their own investment, voting and business decisions and must always act completely independently to set their own strategies, policies and practices based on their own best interests. ICEV facilitates the exchange of public information, but members must avoid the exchange (including one-way disclosure) of non-public, competitively sensitive information, including with other members and participants in engagements.