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 the personal data that Wellington collects or is provided to Wellington.
“Wellington”, “we” or “us” means Wellington Management International Limited with its registered office at Cardinal Place, 80 Victoria Street, London, SW1E 5JL or any of its subsidiaries, affiliates and other companies in the Wellington group (the “Wellington Group”) or any fund sponsored by a member of the Wellington Group (a “Wellington Fund”) together (“Wellington”).
This Privacy Notice is directed to individuals whose personal data we or our third party processors handle in the course of carrying on our commercial activities, including a client of Wellington or an investor in any Wellington Fund, or a member, partner, trustee, shareholder, beneficial owner, officer, director, employee or other representative of any client of Wellington or of any investor in any Wellington Fund, including any prospective client or investor (“you”).
The name of the specific Wellington entity which processes your personal data, will depend on which of our services you use. We’ll let you know which entity you have a relationship with when you invest with us.
More information about the companies making up Wellington is provided on our website and you can find out more at www.wellingtonfunds.com.
Wellington Management International Limited is appointed as the European Union (the “EU”) representative in relation to data protection issues for those Wellington Group companies that are located outside of the EU. Where you would like to contact a Wellington Group organization located outside of the EU, you may contact the representative in the manner detailed in the “Contacting Us” section below instead of, or in addition to, directly contacting the Wellington Group organization located outside of the EU.
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 law. 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
Information that you provide to Wellington. This includes information about you that you provide to us. The nature of our relationship with you will determine the kind of personal data we might ask for, though such information may include (by way of a non-exhaustive list):
- basic personal data such as name, address, employment/position in the company, company name, company email address, business phone number, business address; and
- sensitive personal data such as information we handle about your nationality, place of birth, health related information, disability status, or details of political affiliations.
Information that we collect or generate about you. This includes:
- files that we may produce as a record of our relationship with our clients and prospective clients, including 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; and
- details about your use of Wellington websites which may include internet browser history, IP addresses, and access to application forms.
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 organisers, 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 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:
- with our business partners who will be subject to appropriate data protection obligations;
- with representatives, agents, custodians, intermediaries and/or other third party product providers appointed by the client or prospective client (such as accountants 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. 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.
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.
Where Wellington transfers your personal data to another country it is required to do so in a manner consistent with legal requirements. In relation to data being transferred outside of the European Economic Area (the “EEA”), for example, this may be done in one of the following ways:
- the country to which we send your personal data might be approved by the European Commission as offering an adequate level of protection for personal data;
- the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging it to protect your personal data;
- where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
- in other circumstances the law may permit us to otherwise transfer your personal data outside the EEA.
You can obtain more details of the protection given to your personal data when we transfer it outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us as described in “Contacting Us” section below.
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. Unauthorised use or disclosure of confidential client information by a Wellington employee is prohibited and may result in disciplinary measures.
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.
You have a number of legal rights in relation to the personal data that we hold about you. These rights include:
- 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;
- 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; and
- the right to lodge a complaint with the data protection regulator if you think that any of your rights have been infringed by us.
You can exercise your rights by contacting us using the details set out in the “Contacting us” section below.
If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions, comments and requests to [email protected].
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from Wellington, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulator.
UPDATES TO THIS PRIVACY NOTICE
This Privacy Notice may be updated periodically to reflect changes in our information practices or as may be required by law.