Why are you receiving this notice?

The General Data Protection Regulation (“GDPR”) applies to the collection, processing and storage of personal data undertaken by organisations within the European Economic Area (EEA), as well as to organisations outside the EEA that handle personal data relating to the offering of goods and services to, and the monitoring of behaviour of individuals who are in the EEA.

The GDPR has two key purposes: (a) to set out requirements and guidelines for the collection, processing and protection of personal data and (b) to give individuals certain rights in relation to their personal data (such as to access and correct it, and object to further processing, please see further details about the individuals’ rights in this Privacy Notice below).

This Privacy Notice is intended to ensure that prospective investors, clients or similar contacts or, where a prospective investor, client or other similar contact is not an individual, the prospective investor’s, client’s or similar contact’s individual directors, officers, employees, other personnel, and/or owners (“you”, or “your”) are aware of how OFI International, Ltd. (“OFII”, “we”, “us” or “our”), a member of the Invesco Group, may collect personal data, what we use it for and with whom we share it in accordance with the GDPR. Where the prospective investor, client or similar contact is not an individual, please provide a copy of this Privacy Notice to those individual directors, officers, employees, other personnel and/or owners whose personal data we may process.

“Personal data” means any information relating to you by which you can be identified, but does not include data where you can no longer be identified from it such as anonymised aggregated data.

We will be a controller in respect of your relationship with us as a prospective investor, client, or similar contact. A controller is responsible for deciding how to collect, hold and use personal data about you. We may process your personal data ourselves or through others acting as processors on our behalf.

We may provide supplemental privacy notices on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how your personal data is being used. These supplemental notices should be read together with this Privacy Notice.

If you have any questions about this Privacy Notice you can contact emea.privacy@invesco.com.

What information do we collect about you and what do we use it for?

Relevant personal data held by us or on our behalf may include, but is not necessarily limited to, your name, residential address, nationality, country of residence, place of birth, date of birth, tax identification, tax jurisdiction, employment and job history, place of business, email address, other contact details, corporate contact information, signature, regulatory status, correspondence records, passport number, bank account details, certain financial information related within Know-Your-Customer (“KYC”) documents, source of funds and details relating to your investment activity or preferences.

The purposes for which we may collect, store and use personal data about you and the ‘lawful basis’ for processing such data are set out in the table below. The law specifies certain ‘lawful bases’ on which we can rely to use your personal data.

Purpose

Lawful basis for processing

To undertake pre-investment steps including but not limited to:

  • • determining your eligibility to invest or hold a managed account with us;
  • required due diligence; and
  • ascertaining your investment preferences

In order to take steps prior to the contract between you and us/the fund in which you may invest, compliance with applicable legal obligations and our legitimate interests in establishing your preferred investment strategies.

To undertake business development and marketing activities in relation to making suggestions and recommendations to you about products or services that may be of interest to you. This may include direct electronic marketing.

Our legitimate interests in establishing, building, promoting and maintaining a business relationship with you further to our respective business interests.

We only send direct electronic marketing where individuals have consented to this or as otherwise permitted by the law. Individuals can opt-out of receiving such messages at any time by using the opt-out mechanisms that are available in those messages or by contacting us at emea.privacy@invesco.com.

To facilitate the opening of your account, the management and administration of your account on an on-going basis as considered necessary or appropriate for the performance of your contract with us, including without limitation the processing of subscription, redemption, conversion and transfer requests and the payment of distributions.

The performance of your contract with us.

 

To carry out anti-money laundering checks and related actions, including due diligence, considered appropriate to meet any legal, regulatory and commercial obligations relating to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis, in accordance with our anti-money laundering procedures.

Compliance with applicable legal obligations and our legitimate interests in complying with law and regulation applicable to us and our processors, and to manage risks relating to our business.

 

To report tax related information to tax authorities.

Compliance with applicable legal obligations.

To disclose information to other third parties such as auditors, administrators, custodians, brokers, legal advisors, auditors, technology providers and other services providers and regulatory authorities to comply with any legal obligation imposed on us or in order to pursue our legitimate business interests.

Compliance with applicable legal obligations.

Our legitimate interests in conducting our business in a proper manner.

Monitoring and recording calls and other communications related to the processing and verification of instructions, quality and business analysis, compliance with applicable laws and regulations, maintaining our rights and responsibilities directly or through third party delegates.

Our legitimate interests in maintaining relations with our clients and in conducting our business in a proper manner.

Compliance with applicable legal obligations.

To maintain our records.

 

Our legitimate interests in conducting our business in a proper manner.

Compliance with applicable legal obligations.

To provide client relations in respect of your account including provision of periodic reporting, seeking consents for changes to terms and for other corporate governance purposes.

Compliance with applicable legal obligations.

Our legitimate interests in conducting our business in a proper manner. 

In addition to the uses above, please note that we may also process your information where required by law to do so or if we reasonably believe that it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

Special categories of personal data

There are more limited bases for processing special category personal data. This is personal data which reveals or contains racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, genetic data, biometric data (for the purpose of uniquely identifying a natural person), health data, sex life and sexual orientation.

We do not intend to actively collect special category data about you. Whilst we will use reasonable efforts to limit our holding of such data, please be aware that we may hold such data incidentally. For example, where:

  • you volunteer special category data to us or one of our processors, such as if you send us an email containing special category data;
  • documents gathered for legal / regulatory purposes contain special category data, such as a passport copy which references ethnic origin, due diligence search from public sources which includes special category data.

What if you do not provide the personal data requested?

Unless and until you make a decision to invest in one of our investment products or otherwise engage in a business transaction with us (at which point we will send you a copy of any relevant privacy notice) you are not required to provide us with any information.

In some circumstances, if you do not provide us with certain information when requested, we may be limited or restricted in our ability to deal with you and may in some cases be prevented from complying with our legal obligations. Where we require your personal information to comply with anti-money laundering or other legal requirements, failure to provide this information means we may not be able to continue our business relationship.

Change of purpose

We will only use your personal data for the purposes for which we collected it (as identified above in the ‘Purpose’ column), unless we reasonably consider that we need to use it for another purpose which is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

How is information collected?

We typically collect personal data about you when you provide information to us or others acting on our behalf when communicating or transacting with us in writing, electronically, or by phone. For instance, applications, requests for product documentation, or other forms of literature, your transactions and account positions.

In addition, we may receive personal information (as is relevant) about you from third parties, such as:

  • public sources or information vendors;
  • your bank;
  • your legal, financial, tax or other professional advisers;
  • introducers, distributors or other intermediaries who market or provide services to you.

With whom will your personal information be shared?

We may share your personal data with a third party where this is required by law, where it is necessary to perform our contract with you, or where we have another legitimate interest in doing so.

We may need to share your personal data with:

  • other entities within the Invesco Group as part of our ongoing business functions;
  • the administrator
  • introducers, distributors or other intermediaries who market or provide services to you;
  • professional advisers including lawyers, bankers, auditors and insurers to the extent such information is relevant to their performance of their services;
  • regulators;
  • tax authorities;
  • custodians
  • trading counterparties;
  • cloud service providers;
  • parties undertaking anti-money laundering and/or KYC checks; and
  • any of our service providers where such information is relevant to their performance of such services;

We may share your personal data with third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with applicable law or judicial process or if we reasonably believe that disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

We may transfer the personal data we collect about you to entities and parties located in and outside the EU/EEA, and the United Kingdom, including (but not limited to) the U.S. Any such transfer will occur for the purposes outlined in the table above. Countries outside the EEA may not have the same standard of data protection laws as the EEA.

Where this is the case, we will (or we will require a processor to) put in place appropriate safeguards such as the EEA-approved standard contractual clauses to ensure that your personal data is treated in a manner that is consistent with and respects the EEA laws on data protection. If you require further information about this you can request it from emea.privacy@invesco.com.

How long will we retain your information?

We will retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and our legitimate interests in maintaining such personal information in our records. This will normally include any period during which we are dealing or expect to deal with you and what we consider to be a suitable period thereafter for our internal record-keeping purposes. In doing this we will have regard to the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Generally, we will keep information relevant to our dealings with you for 7 years following the last date of activity.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.

Once we no longer require your personal data for the purposes for which it was collected, we will securely destroy your personal data in accordance with applicable laws and regulations.

Accuracy of information

It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data which we hold changes during your relationship with us.

Your rights in relation to your information

You have rights as an individual which you can exercise in relation to the information we hold about you under certain circumstances and subject to applicable laws. These rights are to:

  • request access to your personal data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
  • request rectification of your personal data;
  • request the erasure of your personal data;
  • request the restriction of processing of your personal data;
  • object to the processing of your personal data, including to object to the processing of your personal data for direct marketing purposes;
  • request the transfer of your personal data to another party.

In exercising some of your rights above, in certain circumstances, you may be required to redeem or withdraw from your investment.

If you want to exercise one of these rights please contact us at emea.privacy@invesco.com.

You also have the right to make a complaint at any time to a supervisory authority for data protection issues.

Fees

You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact emea.privacy@invesco.com.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless we now have an alternative legal basis for doing so.

Cookies

When you access our website for the first time, we will place a 'cookie' on your computer. Cookies are small text files that are commonly used by many websites to store information on their users' computers. Cookies only contain information relating to the website that created them and can only return the information to that website.

We use cookies that are essential to operate our website or to enable you to navigate on it, for example, by directing you to the right area of our website depending on what country you have selected or by letting us know that you have accepted our terms and conditions. These cookies are ‘strictly necessary’ cookies and we do not need to obtain your consent to place them on your computer.

We use two types of cookies:

Session cookies: These are temporary and are deleted as soon as you close your browser.

Persistent cookies: These are stored on your computer until they expire, or you remove them. Persistent cookies remember your personal preferences.

You can remove cookies at any time by using the settings on your internet browser. You can configure your internet browser to warn you each time a new cookie is about to be stored on your computer. Please refer to your internet browser's help section for further information. Please note that our website may not function properly if you remove cookies.

Based on your browser, follow these instructions to manage your cookie settings:

Google Chrome - (https://support.google.com/chrome/answer/95647)

Apple Safari - (https://support.apple.com/kb/ph21411)

Mozilla Firefox - (https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences)

Internet Explorer - (https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies)

Microsoft Edge - (https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy)

Opera - (https://www.opera.com/help/tutorials/security/privacy/)

You can find further information about cookies and how to manage your cookie settings on www.allaboutcookies.org or http://www.youronlinechoices.eu/.

Changes to this Privacy Notice

This Privacy Notice was last updated on 24 May 2019. We reserve the right to update this Privacy Notice at any time, and we will make an updated copy of this Privacy Notice available to you (on our website or by other means). We may also notify you in other ways from time to time about the processing of your personal data.

Further information

If you require any further information, please do not hesitate to contact us at

Invesco Global Privacy Office

Perpetual Park, Perpetual Park Drive, Henley-on-Thames, Oxfordshire, RG9 1HH

United Kingdom

emea.privacy@invesco.com.