Aegon Asset Management

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https://www.aegonam.com/

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IMPORTANT DISCLOSURE: FOR NON-US PROFESSIONAL INVESTORS ONLY

This site is intended only for non-US professional investors or US-based fiduciaries representing non-US investors eligible to invest in Aegon Asset Management’s (the “Company”) UCITS funds. This site, and the funds described herein, are not suitable for individual investors.

The following information regarding the Company’s funds is for informational purposes only and does not constitute an offer for shares, products or services and should not be interpreted as an offer to sell, an invitation to acquire an investment, or a solicitation of an offer to buy for any persons who are prohibited from receiving such information under their domiciled local laws.

Aegon Asset Management Investment Company (Ireland) Plc is structured as an umbrella type open-ended investment company with variable capital consisting of a number of different sub-funds (“Funds”) and is authorized in Ireland pursuant to European Communities (Undertakings for Collective Investment in Transferable Securities) UCITS Regulations and the Central Bank UCITS Regulations (“UCITS Regulations"). Aegon Asset Management Europe ICAV is structured as an umbrella type open-ended investment ICAV with variable capital consisting of Funds and is authorized in Ireland as a UCITS pursuant to the UCITS Regulations.

These Funds are registered in Ireland and are available only to residents of those jurisdictions where allowed by law. Investors that do not meet these requirements will be denied access by the Company.

By checking the box, you have read and understand the important legal information above that pertains to Aegon Asset Management's UCITS funds and agree to these terms and conditions.

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https://www.aegonam.com/de/search/

This privacy statement is applicable to the processing by Aegon Asset Management Pan Europe (‘Aegon AM PE’) of all personal data relating to (potential) customers, suppliers and business partners as well as visitors of our websites.

Protecting your personal data

At Aegon AM PE we are committed to protecting and respecting your privacy. Our aim is to be transparent about how we deal with personal data. This privacy statement details how Aegon AM PE, appointed suppliers and the Aegon group of companies process your personal data.

Please note that all investment products are provided by one of our affiliated Aegon Asset Management companies and not Aegon AM PE itself. Please see section 7.1 ‘Sharing your personal data within the Aegon group’ for details of the legal entities within Aegon Asset Management.

You can print this privacy statement by right-clicking on the page and selecting Print.

Controller for the processing of your personal data

Aegon Asset Management Pan-Europe B.V., having its registered office in The Hague, Aegonplein 50 (2591 TV), with branches located in Frankfurt and Madrid, is the controller or co-controller for the processing of all personal data within the scope of this privacy statement. The applicable data controller location will be based on which branch you initially provided your personal data to and/or maintain your service relationship with. We are part of Aegon Asset Management, the asset management arm of Aegon, a global life insurance, pensions and asset management company.

Contact us

If you have any questions about this privacy statement or the information we collect about you, please contact Account Management or our Data Protection Office:

Aegon Asset Management Pan-Europe

Frankfurt Zweigniederlassung

Neue Mainzer Strasse 66-68

60311 Frankfurt am Main

Germany

Aegon Asset Management Pan-Europe

Edificio Cristalia

Vía de los Poblados 3, 28033

Madrid

Spain

E-mail Data Protection Office

More information on your rights as a data subject are contained below under ‘Your Rights’

Purposes for processing personal data

The most common processing activity we conduct which involve the collecting and processing of personal data include:

Conducting checks and assessments prior to doing business
The administration of the service we have agreed to provide.
Servicing our customers and prospective customers.
To develop our products and services
Managing third party and supplier relationships.
Internal management reporting and support functions
Managing relationships with governments and supervisory authorities
Marketing to our customers and prospects
Cookies

More information on these processing activities are contained below.

How and what personal data we obtain about you

Common purposes for processing

Conducting checks and assessments prior to doing business

This will include Anti-Money Laundering checks as well as screening personal data against known sanctions and politically exposed persons (“PEP”) lists. This processing is conducted to detect and prevent financial crime. It is also necessary for us to meet our legal and regulatory obligations[1] as a company. In the event of other checks these will be conducted to execute an agreement. We conduct the screening check automatically using a third-party system provided by FinScan which compares personal data against a number of official sanctions and PEP lists. The results of this check will be considered by a member of our staff in determining whether we can proceed with conducting business/providing a service or not.

This processing may require the collecting and sharing of (sensitive) personal data including copies of identification documents, with other entities within Aegon Asset Management, the Aegon group of companies and appointed suppliers and their appropriate affiliates. Data may also need to be shared with supervisory authorities in certain circumstances.

More information can be found in the section titled 'Sharing your personal data’.

The administration of the service we have agreed to provide.

This includes processing your instructions and account transactions, settling those transactions, assessing investments and markets, administering external investment managers, managing investment portfolios, monitoring investment portfolios and managing risks associated with an account or product, including areas of regulatory compliance. This processing is imperative to us providing the requested service and executing the agreement between us.

Servicing our customers and prospective customers.

This includes managing existing and prospective customer relationships, handling complaints, managing any incidents/issues encountered, detecting fraud, sharing client reporting and providing online services including our websites. This processing is required for us to provide the service requested by yourself. Some of the processing will be based on a legal obligation. We may communicate with prospects and customers by phone, mail, e-mail, personal contact and fax where appropriate (see the section below titled ‘Being in Contact with Aegon AM PE’).

To develop our products and services.

This includes reviewing our existing offering of products and services, making required improvements and launching new products/services. Personal data may also be processed when we develop our appropriate business strategies and systems internally. Where these processes include personal information, they are conducted in the legitimate interest of Aegon AM PE to ensure we provide the best products and services for our customers. We are committed to ensuring that the impact to the data subjects involved is minimal, the approach adopted is reasonable and that the least intrusive approach is followed. The data may be shared with other entities within the Aegon group of companies. More information can be found in the section titled 'Sharing your personal data’.

Please note that all investment products are provided by one of our affiliated Aegon Asset Management companies and not Aegon AM PE itself.

Managing third party and supplier relationships.

Personal data will be processed in order to assess and obtain services provided by a third party company, to manage the relationship between the companies (including where they act as our data processor) and reporting and performance analysis on these relationships. These processes may also require sharing personal information with other entities within the Aegon group of companies as well as consulting publicly available records. These processes are conducted to ensure appropriate execution of the agreement between the parties and between us and our customers, as well as being in the legitimate interests of AIM to be able to utilise third party services when providing its products and services to customers in the best way possible.

Where appropriate, these processes may include the use of any sensitive data provided on copies of ID documents.

More information can be found in the section titled 'Sharing your personal data’.

Internal management reporting and support functions

Including the provision of legal and regulatory support and advice (both internal and external), internal auditing, strategy development and providing and maintaining IT solutions. Most of these processes are conducted to execute activities vital to the internal management and improvement of our business and are imperative to the performance of our agreements with customers and suppliers, however some will be conduct to meet our legitimate interests as a company. Where this is the case, we are committed to ensuring that the impact to the data subjects involved is minimal, the approach adopted is reasonable and the least intrusive approach is followed. Others will be conducted to fulfil a legal or regulatory obligation. Personal data may be shared with other entities within the Aegon group of companies, including Aegon Global Technology Services who act as a data processor of any personal data handled or processed when providing IT and technology solutions. Personal data may also be shared with third parties including external law firms, accountants and auditors.

More information can be found in the section titled 'Sharing your personal data’.

Managing relationships with governments and supervisory authorities

This includes responding to requests and providing regular and ad hoc reporting. These processes are conducted to fulfil a legal and regulatory obligation of the company. Where personal data, including sensitive personal data, needs to be processed in order to fulfil these obligations it will be conducted in line with this privacy statement including when processing involves third parties and entities within the Aegon Asset Management, appointed suppliers and the Aegon group of companies.

More information can be found in the section titled 'Sharing your personal data’.

Marketing to our customers and prospects

This will include the execution and analysis of marketing campaigns and strategies, promoting products and services provided by affiliated Aegon Asset Management companies, running and contributing to promotional events and the use of ad hoc competitions and promotions.

We will ensure that we obtain the necessary consent in order to send you marketing information and news about our products and services that may be of interest to you, as well as invite you to relevant events. We may also send you marketing about products and services that we feel are reasonably similar to those already acquired as an existing customer. Marketing communications will be conducted using various channels such as mail, phone and email.

When running or contributing to promotional events we may need to collect personal information in relation dietary and access needs, but this information will only be used for the purposes confirmed at the time of collection.

Your personal data will only be shared with external third parties for marketing purposes where you have agreed to do so. We will not sell your personal information to other organisations for marketing purposes.

Please remember that you can withdraw your consent or opt-out of marketing communications at any time by contacting us (see section 'Your Rights').

The withdrawal of consent to specific processing of personal data, including for the purposes of marketing, does not affect the processing based on consent before the withdrawal. It will also not affect the provision of any other products and services or the processing of personal data unrelated to the process for which you have withdrawn consent.

We may conduct marketing related analytics which includes the processing of personal data based on our legitimate interest to ensure we provide customers with appropriate marketing information that is relevant to them. When doing this we will ensure that aggregated information is used where possible and where personal data is processed the least intrusive method is used and that we feel the recipient would reasonably expect this type of processing. This analytics may include additional (personal) information obtained from third parties where we consider the use of this data as fair and legal. Data subjects may object to this at any time by contacting us.

Cookies

We also collect information using cookies. Cookies are small files of information which save and retrieve information about your visit to this website – for example, how you entered our site, how you navigated through the site, and what information was of interest of you.

Read more about how we use cookies in our Cookie Statement.

Being in contact with Aegon AM PE

Sharing your personal data

Sharing your personal data within the Aegon group

As a global organization, personal data we collect may be transferred internationally throughout Aegon’s worldwide organization. Your personal data will be exchanged within the Aegon group of companies (meaning all subsidiaries and affiliates of Aegon N.V.), including the Aegon Asset Management group (the entities within the Aegon group that are responsible for asset management activities) including Aegon Asset Management UK plc, Aegon Investment Management B.V. (including where trading as TKP Investments), Aegon Magyarország Befektetési Alapkezelő Zártkörűen Működő Részvénytársaság (Aegon Asset Management Central and Eastern Europe), Aegon Asset Management Value Hub B.V, Aegon Asset Management (Asia) Limited, Aegon USA Investment Management LLC, and Aegon USA Realty Advisors LLC and.

We share your data for the purposes mentioned in this statement and to have a complete overview of our contacts and contracts within the Aegon group. We may also share your data to offer you a complete package of services and products. This will be handled in line with the description above on how we provide marketing to customers and prospects.

If your personal data is transferred within the Aegon group to a country where the local regulation does not reach the EU adequate level of protection of personal data Aegon AM PE will take measures to ensure that your personal data is adequately protected, such as entering into EU standard Contractual Clauses with these parties.

Aegon AM PE employees are authorized to access personal data only to the extent necessary to perform their job.

Sharing your personal data with third parties

We work with carefully selected providers that carry out certain functions on our behalf and cooperate with relevant authorities. The following types of third parties have or could be granted access to your personal data where relevant for the processing described above.

Governments
Supervisory authorities – including Deutsche Bundesbank, Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin), Der Hessische Beauftragte für Datensschutz und Informationsfreiheit, Amtsgericht Frankfurt am Main, Industrie und Handelskammer Frankfurt am Main, Finanzamt Frankfurt am Main (Tax), Bundesagentur für Arbeit, Comisión Nacional Mercados de Valores, SEPBLAC (AML), Agencia Tributaria (Tax)
Technology suppliers
Client Relationship Management (CRM) tool providers – including SalesForce
Accountants
Auditors
External legal counsel
Mailing houses
Event organisers

When third parties are given access to your personal data, Aegon AM PE will take the required contractual, technical and organizational measures to ensure that your personal data is only processed to the extent that such processing is necessary. The third parties will only process your personal data in accordance with applicable law.

If your personal data is transferred to a third party recipient in a country where the local regulation does not reach the EU adequate level of protection of personal data Aegon AM PE will take measures to ensure that your personal data is adequately protected, such as entering into EU Standard Contractual Clauses with these parties.

In other cases, your personal data will not be supplied to third parties, except:

to the extent that we are required to do so by law, by a government body or by a law enforcement agency, or for crime prevention purposes (including financial crime protection and credit risk reduction);
when protecting your interests or the interests of other individuals or for reasons of substantial public interest;
in connection with any legal proceedings (including prospective legal proceedings);
in order to establish or defend our legal rights;
in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets and for the purposes of effecting any sale or purchase; or
if we, or substantially all of our assets, are acquired by a third party, we may disclose your personal data to that third party in connection with the acquisition.

The use of your personal data by data processors

When a third party processes your personal data solely following our instructions, it acts as a data processor. We enter into an agreement with such a data processor concerning the processing of personal data. In this agreement we include obligations to safeguard that your personal data is solely provided to the data processor to provide specific services to us and the data is afforded a sufficient level of protection.

Retention of personal data

Security

Your rights

Changes to this privacy statement

Making a complaint

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