LGIM Liquidity Funds plc Privacy Policy

Transcription

1 LGIM Liquidity Funds plc Privacy Policy Protecting your personal information is extremely important to LGIM Liquidity Funds plc (the Fund ) and its management company, LGIM Managers (Europe) Limited (the Management Company ) (together, we or us ) as shareholders in the Fund ( Shareholders ) trust us to look after a huge amount of personal information. The way we, acting as joint data controllers, collect and share your information is equally important. We will collect and process the personal data of living individuals who are: (i) registered Shareholders, (ii) applicants for shares, (iii) beneficial owners of registered Shareholders and applicants for shares, (iv) personal representatives, (v) financial advisors, (vi) directors, officers, employees, agents and (vii) trustees and / or authorised signatories of registered Shareholders and applicants for shares ( Individuals ). Our Shareholders and other Individuals expect us to manage their information privately and securely. If we don t, they ll lose their trust in us. This policy tells you how we collect and process your personal information. Please take a few minutes to read it, and show it to anyone else connected to the policy. WHAT IS PERSONAL INFORMATION? When we talk about personal information we mean any information which we have or obtain, or which an Individual provides to us or one of our service providers, about an Individual that can identify them, like their name, address, address, telephone number and financial details. Any reference to information or data in this policy is a reference to personal information about a living individual. WHAT INFORMATION DO WE HOLD? We, one of our service providers, or another member of the Legal & General group of companies (the Legal & General Group ) may collect and process the following personal information about you: Type of data Description Examples of how we use it Contact Personal Details Transactional Technical Documentary data & national identifiers Who you are Where you live How to contact you Age Gender Family details Visual images & personal appearance Financial Details Bank and/or card details Changes you make to your product or account Amount invested Details on the devices and technology you use Details about you that are stored in documents such as your passport Servicing your product Analysis & profiling Enhancing our product and service offering Analysis & profiling Making sure our products and services are fit for purpose Ensuring that subscriptions, transfers and redemptions can be processed efficiently Making sure our products and services are fit for purpose Identification Prevention of financial crime

2 WHERE DO WE GET OUR INFORMATION FROM? Information you give us directly (e.g when you fill in application forms to subscribe for shares in the Fund, or contact us by phone, etc.). Information we collect about you or receive from other sources. This could be information you provide to us electronically (through our website or an online portal, for example), information we get from your online browsing activity, information from a third party or from publicly available sources such as social media platforms. We may also receive information if you have been dealing with a financial adviser or have been introduced to us by another company (e.g. a bank distributor or other intermediary). For more information on how we use cookies, please refer to our cookie policy. Where we need to process personal data in connection with a registered Shareholder s contract with the Fund or in anticipation of an applicant for shares becoming a registered Shareholder, or where we have a legal obligation to collect certain personal data relating to an Individual (for example in order to comply with anti-money laundering obligations), in situations where you refuse to communicate your personal data or fail to provide such personal data in a form which is satisfactory to us, we may be required to restrict or prevent your request for ownership of shares in the Fund. The Fund, its depositary and/or administrator and/or the Management Company (as the case may be) shall be held harmless and indemnified against any loss arising as a result of the restriction or prevention of the ownership of shares. To carry out our responsibilities resulting from any agreements you ve entered into with us, or in anticipation of an agreement that you may enter into with us, and to provide you with the information, products and services that you have asked from us. To comply with any applicable legal or regulatory requirements (including know your customer and anti-money laundering checks, or to comply with any applicable tax or regulatory reporting or disclosure requirements), including: Where we are ordered to disclose information by a court with appropriate jurisdiction. The recording of telephone calls and electronic communications in order to comply with applicable legal and regulatory obligations. where the use is for a legitimate interest of the Fund / Management Company, including: For day to day operational and business purposes. To take advice from our legal and other advisors. For carrying out board reporting and for management purposes, including quality assurance. To tell you about changes to our services and products. In the event of a merger or proposed merger of the Fund or any sub-fund of the Fund, any other restructuring or reorganisation of the Fund or any sub-fund of the Fund or relating to the assets of the Fund or any sub-fund of the Fund. Where the use or sharing is for a legitimate purpose of another company within the Legal & General Group, or of a thirdparty to which we provide the personal data, including: For day to day operational and business purposes. For investor relationship management. For the calculation and payment of commissions and rebates. For carrying out market research, and statistical analysis and customer profiling to help us to improve our processes and our products and services (e.g. to understand digital behaviours, identify financial attitudes and develop more engaging communications). To define our actuarial, pricing and underwriting strategies. To run our business in an efficient and proper way. This includes testing our systems, managing our financial position, business capability, planning, communications, corporate governance, and audit. Where necessary, to establish, exercise or defend our legal rights or for the purpose of legal proceedings. For any other purpose that you have consented to from time to time. In some cases, we may use systems to make automated decisions (including profiling) based on the personal information we have, or collect from others. These may include: The prevention and detection of fraud. 2

3 Personalising the content and design of communications and online services. Determining when to provide tailored servicing communications (e.g. changes in your personal circumstances or lifestyle), and the appropriate channel(s) to use. USING YOUR INFORMATION IN ACCORDANCE WITH DATA PROTECTION LAWS The applicable Irish data protection law, and, as of 25 May 2018, Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the Data Protection Laws ) require us to meet certain conditions before we re allowed to use your personal information in the way we describe in this privacy policy. We take these responsibilities extremely seriously. To use your personal information, we ll rely on one of the following lawful basis, depending on the activities we re carrying out: Providing our contracts & services to you: We ll process your personal information to carry out our responsibilities resulting from any agreement(s) you ve entered into with us (i.e. administering your shares in the Fund, maintaining the register of Shareholders, processing subscriptions, redemptions (if any) and payments of distributions to you). Complying with applicable laws: We may process your personal information to comply with any legal obligation we re subject to (e.g. for the purpose of complying with applicable anti-money laundering rules and other legal obligations). Legitimate interests: To use your personal data for any other purpose described in this privacy policy, we ll rely on a condition known as "legitimate interests". It s in our legitimate interests to collect your personal data as it provides us with the information that we need to provide our services to you more effectively. We may use your information to: Carry out market research and product development, which can include creating customer demographics and/or profiling. Study and also manage how our customers use products and services from us and our business partners. Manage risk for us and our customers. Consent: To process your personal data for direct marketing purposes, we will seek and rely on your consent, which we will collect through the application form. You have a right to object to the processing of your personal data for marketing purposes, and to withdraw your consent at any time by writing to us. This requires us to carry out an assessment of our interests in using your personal data against the interests you have as a citizen and the rights you have under Data Protection Laws. The outcome of this assessment will determine whether we can use your personal data in the ways described in this privacy policy. We ll always act reasonably and give full and proper consideration to your interests in carrying out this assessment. Please be aware that the personal information you provide to us, and which we collect about you, is required for us to be able to provide our services to you and without it we may not be able to do so. HOW LONG DO WE KEEP YOUR INFORMATION FOR? We ll keep your personal information in accordance with our internal retention policies, and applicable laws. We ll determine the length of time we keep it for based on the minimum retention periods required by law or regulation. We ll only keep your personal information after this period if there s a legitimate and provable business reason to do so, but in any case, your personal data shall not be retained for periods longer than necessary for the purpose of the data processing, subject to applicable statutory periods of limitation. We will use reasonable efforts to keep your data up-to-date. However, each Individual will need to notify us without delay in the event of any change in his / her personal circumstances, or those of the others mentioned above, so that we can keep the data up-to-date. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH? We ll only disclose your information to the following entities: Other companies within the Legal & General Group, third-party suppliers, contractors and service providers, such as the Investment Manager and Distributor (as further described in the Fund s prospectus), for the purposes listed under HOW WE USE YOUR INFORMATION above. The Administrator, as further described in the Fund s prospectus. A copy of the Administrator s privacy notice can be accessed at Any paying agents appointed by us to provide the Fund with services in a jurisdiction in which its shares are marketed. Additionally, we may disclose your personal information to the following third parties ( Recipient(s) ): 3

4 The Fund s Auditor, Depositary and Legal Advisers, as further described in the Fund s prospectus. In the event that we sell or buy any business or assets, in which case we ll disclose your personal data to the prospective seller or buyer of such business or assets. If we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our Shareholders will be one of the transferred assets. If you have been dealing with a financial adviser, we ll provide information about your product and, where appropriate, other information about your dealings with us, to enable the adviser to give you informed advice. In order to enforce or apply the terms of any contract with you. If we re under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime. To protect you and the Fund from financial crime, we may be required to verify the identity of new and sometimes existing Shareholders. This may be achieved by using reference agencies to search sources of information relating to you (an identity search). If this fails, we may need to approach you to obtain documentary evidence of identity. The Recipients may, as the case may be, process personal data as data processors (when processing personal data upon our instructions, to assist us in the context of the aforementioned purposes) or as distinct data controllers (when processing personal data for their own purposes). We may also disclose your personal data to the Irish tax authorities, which in turn may, acting as data controller, disclose it to foreign tax authorities. If you ve been introduced to us by another company (such as a bank, distributor or other intermediary), we may share your information with them to enable them to: Carry out market research and statistical analysis and customer profiling. Assist you with your application process. FRAUD PREVENTION We will check your details with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. We may also share information about you with other organisations and public bodies, including the police and we may check and/or file your details with fraud prevention agencies and databases. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when checking details on applications to subscribe for shares in the Fund. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies. Please contact the Management Company s Financial Crime department if you wish to receive the relevant details of the fraud prevention agencies: Address: Legal & General Investment Management Financial Crime, 3rd Floor, Brunel House, 2 Fitzalan Road, Cardiff CF24 0EB, United Kingdom. Telephone: +44 (0) We may also check the details of other parties related to your contract, including verification of identity. This includes persons connected to you but with whom we do not directly communicate, such as beneficiaries, trustees, settlors, executors or administrators of your estate, parties with power of attorney and any other beneficial owner. TRANSFERRING YOUR DATA OUTSIDE THE EEA The personal data that we collect from you may be transferred to and processed by any of the recipients mentioned above in a country located outside of Ireland. Many of the countries will be within the European Economic Area (the EEA ) and will have data protection laws which are the same as or which are broadly equivalent to those in Ireland. However, some transfers may be to countries which are outside the EEA and which have data protection laws that may not offer an adequate level of protection. We ll take all reasonably necessary steps to make sure that your personal data is treated securely and in accordance with this privacy policy. 4

5 We ll only transfer your personal data to recipients located in countries outside the EEA where we re permitted to do so by the Data Protection Laws, for instance, (a) where the transfer is to a territory that is deemed adequate by the European Commission; (b) where the recipient is subject to an approved certification mechanism and the personal information is subject to appropriate safeguards; or (c) where the transfer is based on standard contractual clauses adopted or approved by the European Commission ( Model Clauses ). If the Fund and / or the Management Company enter into Model Clauses with recipients located outside the EEA, such Model Clauses can be obtained by contacting the Data Protection Officer by any of the means listed below. Unfortunately, sending information via is not completely secure; anything you send is done so at your own risk. Once received, we will secure your information in accordance with our security procedures and controls. YOUR RIGHTS You have rights under the conditions set out by the Data Protection Laws that relate to the way we process your personal data. If you wish to exercise any of these rights, please contact the Data Protection Officer by any of the means listed below. Alternatively, you can also use the Contact Us section of our website. 1. The right to access the personal data that we hold about you. 2. The right to make us correct any inaccurate personal data we hold about you. 3. The right to make us erase any personal data we hold about you. This right will only apply where for example: We no longer need to use the personal data to achieve the purpose we collected it for You withdraw your consent if we re processing your personal data based on that consent Where you object to the way we use your data and there is no overriding legitimate interest which we can rely on to continue processing your data 4. The right to restrict our processing of the personal data we hold about you. This right will only apply where for example: You dispute the accuracy of the personal data we hold You have objected to our processing of the personal data - we will restrict such processing whilst we seek to verify whether our legitimate interests override your interests or fundamental rights You have the right to require us to erase the personal data but would prefer that our processing is restricted instead Where we no longer need to use the personal data to achieve the purpose we collected it for, but you need the data for legal claims. 5. The right to object to our processing of personal data we hold about you. 6. The right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to make us transfer this personal data to another organisation (data portability). 7. The right to withdraw your consent, when we rely on such consent to process your personal data for marketing purposes. In any case where we are relying on your consent to process personal data, you have the right to change your mind and withdraw consent by writing to the Data Protection Officer by any of the means listed below. Where we are relying on a legitimate purpose of the Fund / Management Company, a member of the Legal and General Group or a third-party recipient of the personal data, in order to use and disclose the personal data, you are entitled to object to such use or disclosure of your personal data and if you do so, we will cease to use and process such data for that purpose unless we can show that there are compelling legitimate reasons for it to continue or we need to use the personal data for the purposes of legal claims. CONTACTS AND COMPLAINTS If you have any questions about this privacy policy or wish to exercise any of your rights, please contact the Data Protection Officer by letter/ at the address(es) provided below. Alternatively, you can also use the Contact Us section of our website. If you have any concerns about the way we process your personal data, or are not happy with the way we have handled a request by you in relation to your rights, you also have the right to make a complaint to the Data Protection Commissioner in Ireland at the following address: Office of the Data Protection Commissioner. Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland. 5

6 DATA PROTECTION OFFICER Legal & General Group has appointed a Data Protection Officer to provide independent expert advice and monitor compliance with Data Protection Laws: Name: Liz Gaspar address: Data.Protection@landg.com Address: 1 Coleman Street, London, EC2R 5AA, United Kingdom. Disclaimer Legal & General Investment Management One Coleman Street London EC2R 5AA Authorised and regulated by the Financial Conduct Authority. Legal & General Investment Management does not provide advice on the suitability of its products or services. Ultimate holding company - Legal & General Group plc. 6