At Wellington we respect your privacy and we are committed to keeping your personal data secure. This notice (the “Privacy Notice”) explains how we use personal data that Wellington collects or is provided to Wellington.
“Wellington”, “we” or “us” means Wellington Management Company LLP, any of its affiliates, subsidiaries, or any other entities under common control, and funds sponsored by any Wellington affiliate or subsidiary (“Wellington Affiliates”).
About this privacy notice
This Privacy Notice governs the handling of personal data by Wellington in the course of carrying out our investment management and related activities.
Wellington is responsible for ensuring that we use your personal data in compliance with applicable data protection and privacy laws. The Privacy Notice sets out the basis on which any personal data about you will be processed by us.
Personal data that we collect and process about you
The nature of our relationship with you will determine the kind of personal data we might ask for, such information may include (by way of a non-exhaustive list):
- Information about you such as your name, date of birth, contact details, personal email address, home address, professional information or employment related information, educational information or background, passport details, driver’s license details or other similar identification numbers and documents.
- Information classified as ‘sensitive’ personal data such as information about your nationality, place of birth, medical and health related information, disability status, biometric data, or details of political affiliations. In certain jurisdictions, we may classify passport numbers, driver’s license numbers, or other similar identification numbers and documents as ‘sensitive’ data. ‘Sensitive’ personal data is only collected and used where it’s needed to provide the service or product you have requested or to comply with our legal obligations.
- Information if you visit one of our offices such as visual images collected via closed circuit television (CCTV).
- Information that is automatically collected such as details about your use of Wellington websites which may include internet browser history, IP addresses, and access to application forms.
- Information about our contact with you and information we generate internally about our relationship with you. This includes:
- files that we may produce as a record of our relationship with our clients and prospective clients, including, but not limited to, preferences and contact history;
- any personal data that you provide during telephone and email communications with us which we may monitor and record in order to resolve complaints, improve our service and in order to comply with our legal and regulatory requirements;
- commercial information, such as records of the products or services our clients currently use from Wellington or have inquired about obtaining from Wellington.
- Information that we obtain from other sources. This includes:
- information from publicly available sources (including third party agencies such as credit reference agencies; fraud prevention agencies; law enforcement agencies; public databases, registers and records such as Companies House and the FCA Register; and other publicly accessible sources);
- information obtained from the transfer agents or administrators of Wellington Funds distributors or financial intermediaries, platforms, professional advisers including consultants, lawyers and tax advisers, product providers, event organizer’s, and other agents and/or representatives; and
- information obtained from sanctions checking and background screening providers.
Uses of your personal data
Your personal data may be stored and processed by us in the following ways and for the following purposes:
- to manage your relationship and/or account with Wellington;
- to assess clients’ and prospective clients’ applications or contracts for Wellington products and services;
- to keep our records up to date;
- for ongoing review and improvement of the information provided on Wellington’s websites to ensure they are user friendly and to prevent any potential disruptions or cyber-attacks;
- to monitor IT systems in order to protect against cyber threats or malicious activity including abuse and misuse;
- to communicate with clients and prospective clients in order to provide services or information about Wellington and other Wellington products and services;
- to effectively manage and strengthen client and prospective client relationships, understand client and prospective client needs and interests and learn more about our clients and prospective clients in order to develop, improve and manage the products and services we can offer;
- for the management and administration of Wellington’s business; or
- in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures.
We may use your personal data in these ways for a variety of reasons. These include:
- we are performing our contractual obligations;
- we have obtained your consent;
- we have legal and regulatory obligations that we have to discharge;
- we may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or
- the use of your personal data as described is necessary for our legitimate business interests, such as:
- allowing us to effectively and efficiently manage and administer the operation of our business;
- maintaining compliance with internal policies and procedures; and
- enabling quick and easy access to information on Wellington products.
DISCLOSURE OF YOUR INFORMATION TO AFFILIATES AND THIRD PARTIES
We may share your personal data within the Wellington Group for the purposes described above. We may also share your personal data outside of the Wellington Group as further described below or as permitted by law:
- with our business partners (such as broker dealers and counterparties) who will be subject to appropriate data protection obligations;
- with representatives, agents, custodians, administrators, intermediaries and/or other third party product providers appointed by the client, or prospective client or fund (such as accountants, auditors and professional advisors);
- with third party agents and contractors for the purposes of them providing services both to us (for example, Wellington’s accountants, professional advisors, IT and communications providers, background screening providers, credit reference agencies) and to clients, or prospective clients or funds. These third parties will be subject to appropriate data protection obligations; and
- to the extent required by law or regulation, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators, auditors or public authorities), or to establish, exercise or defend our legal rights.
SALE OF PERSONAL DATA
In the course of business, Wellington does not sell or disclose our clients’ personal information to other businesses or third parties for monetary or other valuable consideration. The information we provide to third parties are for the business purposes described in this Privacy Notice.
INTERNATIONAL TRANSFERS OF PERSONAL DATA
Wellington is a global business and as a result we or our third party processors collect and transfer personal data globally and may transfer your personal data to locations outside of your country. Your personal data may also be processed by individuals operating outside your country who work for Wellington or for one of our vendors.
SECURITY OF PERSONAL DATA
Wellington has extensive controls in place to maintain the security of personal data. As a condition of employment, Wellington employees are required to follow all applicable laws and regulations, including in relation to data protection law. Unauthorized use or disclosure of confidential client information by a Wellington employee is prohibited and may result in disciplinary measures. We also maintain a variety of physical, electronic, and procedural safeguards in an effort to protect confidential information.
RETENTION OF PERSONAL DATA
How long we hold your personal data for will vary. The retention period will be determined by the following:
- the purpose for which we are using your personal data – we will need to keep the data for as long as is necessary for that purpose; and
- legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.
RIGHTS UNDER RELEVANT DATA PROTECTION LAW
Where permitted by applicable law and regulation, you have a number of legal rights in relation to the personal data that we hold about you. These rights include, without limitation:
- the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
- where you have actively provided your consent for us to process your personal data, the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so, such as a legal or regulatory obligation. If you decline to provide or withdraw your consent to our use of the data and we are relying on consent as the legal basis for its processing, there are circumstances in which we will not be able to provide you with services or take action on your behalf;
- the right to request that we rectify your personal data if it is inaccurate or incomplete;
- the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
- the right to object to and the right to request that we restrict, our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to continue processing your personal data and/or to refuse that request;
- the right to data portability;
- the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us. We are always open to dialogue to resolve issues short of formal disputes.
DO NOT TRACK NOTICE
At this time, there is no worldwide uniform or consistent industry standard or definition for responding to, processing, or communicating Do Not Track signals. Thus, like many other websites and online services, our Online Services are currently unable to respond to Do Not Track Signals. To find out more about “Do Not Track”, you may wish to visit http://www.allaboutdnt.com. You can visit https://www.wellington.com/en/cookies-tracking-notice/ to view Wellington’s cookies and tracking notice.
FOR CALIFORNIA AND EU/EEA RESIDENTS
California Consumer Privacy Act becomes effective on 1 January 2020
If you wish to exercise any of your rights, please email [email protected] with the phrase “Data Subject Rights” in the subject line. You may also call us at +1-617-951-5000 and request to speak with the Global Privacy Officer. We will review your requests and respond accordingly. The rights herein are not absolute and we reserve all of our rights available to us at law in this regard. Additionally, if we retain your personal information only in de-identified form, we will not attempt to re-identify your data in response to a Data Subject Rights Request.
If you make a request related to personal information about you, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after completing the request. For requests related to particularly sensitive information, we may require additional proof of identification.
If you make a Data Subject Rights request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf.
We will process your request within the time provided by applicable law.
UPDATES TO THIS PRIVACY NOTICE AND ADDITIONAL INFORMATION
This Privacy Notice may be updated periodically to reflect changes in our information practices or as may be required by law.
Fund investors can find additional information regarding our confidentiality and privacy practices disclosed in each fund’s offering memorandum or subscription documentation.
Any material changes or updates to this Privacy Notice will be communicated to you through an appropriate channel depending on the services you receive from us. If you have any questions about our approach to privacy, please contact us at [email protected].
Last updated 20 December 2019