Online Privacy Notice and Cookies Policy
Introduction and definitions
In this Online Privacy Notice and Cookies Policy:
“personal data” means personal data as defined under the Law and includes any information about an identified or identifiable natural person. Such information may include, for example, information we collect against an identifier for you (for example, your IP address or cookie ID). We also refer to personal data as “information about you”;
“controller” means controller as defined in applicable data protection legislation;
“Invesco”, “our”, “us” and “we” means Invesco Management S.A; and
“the Law” means applicable data protection legislation, including (where applicable) the General Data Protection Regulation (“GDPR”).
What is the purpose of this Online Privacy Notice and Cookies Policy?
This Online Privacy Notice and Cookies Policy tell you how we will process any personal data that we collect from you, or that you provide to us online. The Law says we must provide you with this information and we hope this will help you to understand how we will keep your personal data safe. You can find more information about how we process your personal data in our privacy notice which also applies to the use of personal data we collect offline.
Who are we?
We are the controllers of your personal data and, as controllers, determine why and how we collect and use your personal data. We are committed to protecting your privacy and personal data as you use our website and web services. We take seriously our responsibility to hold your personal data securely and confidentially.
What kind of personal data do we collect about you and how?
Depending on your interaction with our website, we collect the following categories of personal data from you:
Do we collect personal data about you from third parties?
We may also collect your personal data from third parties, for example (i) from publicly accessible sources, including publicly available online profiles and databases e.g. to establish and verify your identity, to find out your contact details or to liaise with you in relation to our products and services, or (ii) by using third party cookies. Please find more information about how we use third party cookies in our Cookies Policy below.
How do we protect your personal data?
We maintain strict security standards and procedures with a view to preventing unauthorised access to your personal data by anyone, including our staff. We use leading technologies such as (but not limited to) data encryption, firewalls and server authentication to protect the security of your personal data. The staff of Invesco follow strict privacy standards and whenever we hire third parties to provide support services, we require them to observe the same standards and to allow us to audit them for compliance.
How will we use your personal data we collect online?
This section of this Online Privacy Notice and Cookies Policy explains for what purposes we use your personal data we collect online and on which legal bases we rely. Our legal bases for collecting and using your personal data will include:
- to perform our contract with you such as (i) servicing your online account or (ii) providing you with our online valuation service;
- to pursue our legitimate interests which do not override your interests or fundamental rights and freedoms, such as (i) improving our services to you and other website users and developing new products; (ii) providing information to you about our services and products or anything else that we think may be of interest to you (this information may be provided to you in the form of a digital advertisement or via email), and we may identify which products or services we think you are interested in by using cookies on our website which track and analyse how you use our website; and (iii) processing your personal data for administration, assessment and analysis purposes (for example, marketing and product analysis and behaviour scoring);
- to comply with our legal obligations laid down in laws applicable to us; and
- in some circumstances and subject to applicable laws, we will process your personal data where we have obtained your consent. However, we will make it clear to you at the time of collection of your personal data that we are relying on your consent to process your personal data, and you will have the right to withdraw your consent at any time. The withdrawal of your consent shall not affect the lawfulness of processing based on your consent before its withdrawal.
For how long do we keep your personal data?
We only keep your personal data for as long as is necessary to fulfil the purposes for which it has been collected. When determining the appropriate retention period, we consider the risks of the processing, our contractual, legal and regulatory obligations, internal data retention policies and our legitimate business interests as described in this Online Privacy Notice and Cookies Policy.
Who do we share your personal data with?
Where we send direct marketing materials to you, we may send your personal data to third parties with whom we have contracted to provide these materials to you on our behalf and in our name. These third parties act as our processors in relation to their processing of your personal data in this way.
In certain circumstances, we may also share your personal data we collect online, for the purposes set out in this Online Privacy Notice and Cookies Policy, with other third parties such as:
- service providers (e.g. data analysis or web-hosting firms, other information technology service providers), who provide a service to us or you, their service providers, delegates and agents;
- credit reference agencies;
- other entities within Invesco Ltd’s group companies; and
- your financial advisor or other intermediaries.
We also may disclose your personal data to courts, the police, or other law enforcement agencies where we are legally obliged to do so or in our reasonable opinion such disclosure is necessary to comply with applicable laws and legal processes, support an investigation or to protect our rights and interests in relation to any suspected misuse by you of our website or any of our website services.
We endeavour to prevent unauthorised disclosures of your personal data by other people, but we are not responsible for any unauthorised disclosures or other breaches of security or for the actions of others if the personal data was passed to them with your authority or with the authority of anybody other than us or our affiliates.
We may also share your personal data with a potential buyer in connection with any proposed purchase, merger or acquisition of any part of our business.
Where is your personal data transferred?
When we share your personal data with the organisations listed above, it may involve transferring your personal data outside the European Economic Area (EEA) or outside any other country from where you may access our website, to countries where the level of protection of personal data has not been deemed adequate by the European Commission. The absence of an adequacy decision means that the laws of these countries may not guarantee the adequate level protection of your personal data as defined by the Law. However, we will ensure that your personal data is transferred, processed and maintained to the standards required by Law by putting standard data protection clauses in place (as approved by the European Commission) or where we use third parties, we may rely on other appropriate transfer mechanisms they have implemented. You can obtain a copy of the standard data protection clauses at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en and contact us by using the contact details provided below for further information about other appropriate transfer mechanisms we may rely on.
What are your rights in relation to the personal data we hold about you?
Subject to the conditions prescribed in applicable laws, you have the right: (i) to access, rectify or request erasure of your personal data; (ii) to ask us to restrict processing of it; (iii) to request portability of it.
Subject to the conditions prescribed in applicable laws, you have the right (i) to object, on grounds relating to your particular situation, to processing of your personal data which is based on our or a third party’s legitimate interests; and (ii) to object to processing of your personal data for direct marketing purposes.
You can exercise these rights by contacting us using the contact details provided below.
You also have the right to lodge a complaint with a supervisory authority about our use of your personal data in the EU Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes the GDPR.
Can I use the website in an anonymised or pseudonymised manner?
In accordance with applicable data protection legislation, you may choose to use the website in an anonymised or pseudonymized manner. This applies only to the extent that anonymous or pseudonymized use of the website is technically possible and reasonable.
When you access our site for the first time, choose your audience type or register for our site services, we will place a 'cookie' on your computer. Cookies are small text files placed on your computer and are commonly used on the internet 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. In other words, our site cannot read the information contained in cookies created by anyone else's website on your computer. Similarly, only our site can read the information in cookies that it creates. Cookies cannot be used to get or view data from your hard drive.
What purposes are cookies used for?
- track and record the aggregate number of visitors to the website and the sections of the site visited by visitors using cookies;
- analyse our website, for example to collect information that will help us understand visitors' browsing habits on our website;
- compile statistical reports on website activity, e.g. number of visitors and the pages they visit;
- improve the functionality of our website by temporarily storing any information which you may enter in tools, such as calculators or demonstrations on our website; in some cases, remember information about you when you visit our site. We may need to do this to provide some of our services; and
- record your visit to our website, the pages you have visited and the links you have followed. We use this information to make our website more relevant to your interests and identify products or services that may be of interest to you. We may also share this information with third parties for these purposes.
We use two types of cookies:
Session cookies: These are temporary and are deleted as soon as you close your browser; and
Persistent cookies: These are stored on your computer until they expire or you remove them. Persistent cookies store your personal preferences such as your language preferences on multi-lingual sites to make subsequent visits easier. They also remember questions we have asked you previously, such as a request to complete an online survey.
You can find more information about the individual cookies we use, when they expire and the purposes for which we use them in the table below:
Functional cookies enable you to fully navigate around our website. If you choose not to accept these cookies, your experience on our website may be hindered significantly. You can turn off these cookies via your browser settings, please see the "Manage your cookie settings" section below.
These cookies allow us to improve a visitor’s experience of the website; and can make a visit more relevant. You can turn off these cookies via your browser settings, please see the "Manage your cookie settings" section below.
Third party cookies
We work with third parties who, on our behalf, research the use of our website and activities on it. In doing so they may place a cookie on your computer. However, it would not contain any personal data in a format that can be read by anyone else.
We also work with third parties to evaluate the effectiveness of our advertising and promotions on third party websites. Again, the cookie would not contain any personal data in a format that can be read by anyone else.
Managing your cookie settings
You can refuse, accept or 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 so that you can decide whether to accept or reject it. Please refer to your internet browser's help section for further information. Please note that some parts of our website may not function properly if you reject cookies.
Based on your browser, follow these instructions to manage your cookie settings:
Google Chrome - https://support.google.com/chrome/answer/95647
Use of Google Analytics and Google Ads (Remarketing)
The IP address transmitted by your browser within the scope of Google Analytics will not be associated with any other data held by Google.
Cookies related to Google Analytics and Google Ads (see cookies: ‘_ga’ & ‘_gid’) are used to capture data around how our customers engage with our website, such as pages they visited, interactions they had on the pages, and information about what type of device they are using. We combine this data and analyse it so we can improve the performance of our services and refine the products we provide. We may also use this information and combine it with profile data to help us understand which of our products, services and offers may be relevant for you – with this information, we may tailor our marketing ads, and aspects of our websites to individual visitors based on your usage.
You can prevent the storage of cookies by selecting the appropriate settings of your browser software as described above; however, please note that if you do this, you may not be able to use the full functionality of this website.
You can also prevent the data (including your IP address) generated by the cookie relating to your use of this website from being collected and processed by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout.
This website uses Google Analytics with the extension "_anonymizeIp()". This means that only truncated IP addresses will be further processed so as to prevent them from being linked to a specific user.
Use of Adobe Analytics
Cookies related to Adobe Analytics (see cookies: ‘AMCV_*AdobeOrg’ & ‘AMCVS_*AdobeOrg’) allow us to analyse how our customers engage with our website, such as pages they visited, interactions they had on the pages, and information about what type of device they are using. We combine this data and analyse it so we can improve the performance of our services and refine the products we provide. We may also use this information and combine it with profile data to help us understand which of our products, services and offers may be relevant for you – with this information, we may tailor our marketing ads, and aspects of our websites to individual visitors based on your usage.
Revisions to this Online Privacy Notice and Cookies Policy
This Online Privacy Notice and Cookies Policy was last updated on 2 December 2020. We reserve the right to revise this Online Privacy Notice and Cookies Policy at any time by posting a revised version of it online.
How can you contact us?
If you have any questions about this Online Privacy Notice and Cookies Policy, please contact us via email at firstname.lastname@example.org or in writing at the addresses provided below:
Invesco Management S.A.
37A Avenue JF Kennedy,
Issued and approved in Malta by Invesco Management S.A., President Building, 37A Avenue JF Kennedy, L-1855 Luxembourg, regulated by the Commission de Surveillance du Secteur Financier, Luxembourg.