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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.
For use in China - Qualified Investors only
This website is intended only for qualified investors and is not intended for the use of or distribution to the public in China or elsewhere.
Aegon Private Fund Management (Shanghai) Co., Ltd is regulated by the China Securities Regulatory Commission (CSRC) and the Asset Management Association of China (AMAC). However, the contents of this document have not been reviewed by CSRC or AMAC.
The information in this website is based on our understanding of the current and historical positions of the markets. The views expressed is provided for reference only and should not be interpreted as recommendations or advice.
Past performance is not a guide to future performance. The value of investments and the income from them may go down as well as up and is not guaranteed.
The content of this website is accurate at the time of writing but can be subject to change without notification. Although this information is composed with great care and we strive to ensure accuracy, completeness and correctness of the information, imperfections due to human errors may occur, as a result of which presented data and calculations may differ.
Therefore, no rights may be derived from the provided data and calculations.
This is a marketing communication. Please refer to the Legal documents of the Fund(s), such as the KIID and/or prospectus, before making any final investment decisions.
I confirm that I am a Professional Investor based in Austria.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
If you are a retail investor, we recommend that you seek qualified financial advice before making any investment decisions.
You can get the current prospectuses, accounts, important information for investors and fund prices at https://www.fundinfo.com. Please click the accept button and select the county in which you live and identify yourself as a private investor.
Risk notice - Capital risk. The value of investments can go down as well as up and is not guaranteed.
This is a marketing communication. Please refer to the Legal documents of the Fund(s), such as the KIID and/or prospectus, before making any final investment decisions.
I confirm that I am a Professional Investor based in Belgium.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
If you are a retail investor, we recommend that you seek qualified financial advice before making any investment decisions.
You can get the current prospectuses, accounts, important information for investors and fund prices at https://www.fundinfo.com. Please click the accept button and select the county in which you live and identify yourself as a private investor.
Risk notice - Capital risk. The value of investments can go down as well as up and is not guaranteed.
This is a marketing communication. Please refer to the Legal documents of the Fund(s), such as the KIID and/or prospectus, before making any final investment decisions.
I confirm that I am a Professional Investor based in Denmark.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
This is a marketing communication. Please refer to the Legal documents of the Fund(s), such as the KIID and/or prospectus, before making any final investment decisions.
I confirm that I am a Professional Investor based in Finland.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
This is a marketing communication. Please refer to the Legal documents of the Fund(s), such as the KIID and/or prospectus, before making any final investment decisions.
I confirm that I am a Professional Investor based in France.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
If you are a retail investor, we recommend that you seek qualified financial advice before making any investment decisions.
You can get the current prospectuses, accounts, important information for investors and fund prices at https://www.fundinfo.com. Please click the accept button and select the county in which you live and identify yourself as a private investor.
Risk notice - Capital risk. The value of investments can go down as well as up and is not guaranteed.
This is a marketing communication. Please refer to the Legal documents of the Fund(s), such as the KIID and/or prospectus, before making any final investment decisions.
I confirm that I am a Professional Investor based in Germany.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
If you are a retail investor, we recommend that you seek qualified financial advice before making any investment decisions.
You can get the current prospectuses, accounts, important information for investors and fund prices at https://www.fundinfo.com. Please click the accept button and select the county in which you live and identify yourself as a private investor.
Risk notice - Capital risk. The value of investments can go down as well as up and is not guaranteed.
I confirm that I am a Professional Investor based in Guernsey.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
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Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
I confirm that I am a Retail Investor based in the Guernsey.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
This is a marketing communication. Please refer to the Legal documents of the Fund(s), such as the KIID and/or prospectus, before making any final investment decisions.
I confirm that I am a Professional Investor based in Jersey.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
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Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
I confirm that I am a Retail Investor based in the Jersey.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
This is a marketing communication. Please refer to the Legal documents of the Fund(s), such as the KIID and/or prospectus, before making any final investment decisions.
I confirm that I am a Professional Investor based in Ireland.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
I confirm that I am a Retail Investor based in the Ireland.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
This is a marketing communication. Please refer to the Legal documents of the Fund(s), such as the KIID and/or prospectus, before making any final investment decisions.
I confirm that I am a Professional Investor based in Italy.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
This is a marketing communication. Please refer to the Legal documents of the Fund(s), such as the KIID and/or prospectus, before making any final investment decisions.
I confirm that I am a Professional Investor based in Luxembourg.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
If you are a retail investor, we recommend that you seek qualified financial advice before making any investment decisions.
You can get the current prospectuses, accounts, important information for investors and fund prices at https://www.fundinfo.com. Please click the accept button and select the county in which you live and identify yourself as a private investor.
Risk notice - Capital risk. The value of investments can go down as well as up and is not guaranteed.
This is a marketing communication. Please refer to the Legal documents of the Fund(s), such as the KIID and/or prospectus, before making any final investment decisions.
I confirm that I am a Professional Investor based in Malta.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
I confirm that I am a Retail Investor based in the Malta.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
This is a marketing communication. Please refer to the Legal documents of the Fund(s), such as the KIID and/or prospectus, before making any final investment decisions.
I confirm that I am a Professional Investor based in the Netherlands.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
If you are a retail investor we recommend that you take qualified financial advice before making any investment decisions. You can obtain the latest prospectus, accounts, Key Investor Information and fund prices at www.aegon.nl.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
This is a marketing communication. Please refer to the Legal documents of the Fund(s), such as the KIID and/or prospectus, before making any final investment decisions.
I confirm that I am a Professional Investor based in Norway.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
This is a marketing communication. Please refer to the Legal documents of the Fund(s), such as the KIID and/or prospectus, before making any final investment decisions.
I confirm that I am a Professional Investor based in Portgual.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
I confirm that I am a Retail Investor based in the Portugal.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
This is a marketing communication. Please refer to the Legal documents of the Fund(s), such as the KIID and/or prospectus, before making any final investment decisions.
I confirm that I am a Professional Investor based in Spain.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
If you are a retail investor, we recommend that you seek qualified financial advice before making any investment decisions.
You can get the current prospectuses, accounts, important information for investors and fund prices at https://www.fundinfo.com. Please click the accept button and select the county in which you live and identify yourself as a private investor.
Risk notice - Capital risk. The value of investments can go down as well as up and is not guaranteed.
This is a marketing communication. Please refer to the Legal documents of the Fund(s), such as the KIID and/or prospectus, before making any final investment decisions.
I confirm that I am a Professional Investor based in Sweden.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
I confirm that I am a Retail Investor based in the Sweden.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
This Website and all information contained herein is intended for exclusive use of qualified investors as defined in the Federal Act on Collective Investment Schemes of 23 June 2006 (the “CISA”) and in its implementing ordinance, which have their residence or registered office in Switzerland (the “Qualified Investors”), excluding opt up Qualified investors.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
If you are not a Qualified Investor or are an opt up Qualified Investor under CISA with residence or registered office in Switzerland, we recommend you consult a financial adviser before making any investment decisions.
You can get the current prospectuses, accounts, important information for investors and fund prices at https://www.fundinfo.com. Please click the accept button and select the county in which you live and identify yourself as a private investor.
Risk notice - Capital risk. The value of investments can go down as well as up and is not guaranteed.
I confirm that I am a Professional Investor based in the United Kingdom.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
I confirm that I am a Professional Investor based in the United Kingdom.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
I confirm that I am a Individual Investor based in the United Kingdom.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
I confirm that I am a Institutional Investor based in the United States.
Entry to the website is subject to your understanding of certain terms and important information which are available below:
By accepting entry to this website you confirm that you have read these terms and important information.
Risk Warning
Capital at risk. The value of investments may go up or down and is not guaranteed.
This privacy statement applies to the processing by Aegon USA Investment Management, LLC and Aegon USA Realty Advisors, LLC (collectively, “we” or “the Companies”) of personal data of its clients, customers and potential customers, suppliers/vendors, and business partners as well as visitors of our websites.
The Companies are committed to protecting and respecting your privacy. We believe that transparency and honesty about what we do with your personal data is crucial for maintaining strong relationships with our clients. We would like to inform you through this privacy statement about how we process and use your personal data. Should you have questions or desire more information specifically about your rights as a data subject, please see the section below titled ‘Your Rights’.
More information on these processing activities can be found below.
You can print this privacy statement by right-clicking on the page and selecting Print.
The Companies are the controller or co-controller of all personal data that fall within the scope of this privacy statement. The Companies, which have their registered office in Cedar Rapids, IA, US, are part of Aegon Asset Management, the asset management arm of the Aegon group, a global life insurance, pensions and asset management company.
If you have any questions about this privacy statement or the information we collect about you, please contact Client Services or our Data Protection Office.
Aegon USA Investment Management, LLC [or] Aegon USA Realty Advisors, LLC
Attn. US Data Protection Officer
6300 C Street SW
Cedar Rapids, IA 52499
More information on your rights as a data subject are contained below under ‘Your Rights’
The most common processing activity we conduct which involve the collecting and processing of personal data include:
More information on these processing activities is contained below.
You or someone representing you, for example a financial advisor, consultant, an employer or the business you work for, may give us information about you by completing forms (paper versions or through a website), concluding contractual arrangements or by contacting us by phone, post, email or otherwise. We may also receive your personal information from a third party where they have obtained your consent or have another valid legal basis to share such information. Alternatively, you may have provided the information to us directly.
For the processing activities described below, the personal data that is gathered and processed may include:
Where sensitive personal data is collected and processed as part of any of the activities below, this will be stated in the relevant processing descriptions. Sensitive personal data processed may include the following:
When collecting and processing personal data, the Companies will only process the minimum amount of personal data relevant to the specific purpose it is collected for. We will only use the data for the original purpose for which it was collected (stated below) or a further purpose which you have consented to or that is compatible with the original purpose for which it was collected and that is likely to be in line with your expectations regarding the processing of that data.
If certain elements of personal data are not provided, then we may not be able to conduct all relevant processing required (including meeting regulatory requirements) and as such not be able to provide the full range of products and services.
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 fraudulent behaviour. It is also necessary for us to meet our legal obligations as a company. We conduct the screening check automatically using a third-party system provided by FinScan which compares personal data against a number of official sanctions lists. For lending activities, your personal data may also be checked with a credit rating company as part of the loan approval process. The results of these checks will be considered by a member of our staff in determining whether to 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. Data may also need to be shared with supervisory and governmental authorities in certain circumstances.
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, 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 queries and complaints, managing any incidents/issues encountered, providing account reporting, detecting fraud and providing online services including our websites. This processing is required for us to provide the service agreed under our agreement and ensure the integrity of any account you have with us. Customer relationships may be maintained by phone, mail, e-mail, personal contact and fax where appropriate (see the section below titled 'Being in contact with us').
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 internally. Where these processes include personal information they are conducted in the legitimate interest of the Companies 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’.
Managing third party and supplier relationships.
Personal data may be processed 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 clients, as well as being in the legitimate interests of the Companies to be able to utilise third party services when providing its products and services to clients in the best way possible.
Where appropriate, these processes may include the use of any sensitive data provided on copies of identification documents.
More information can be found in the section titled 'Sharing your personal data’
Internal management reporting and support functions.
This includes the provision of legal and regulatory support and advice (both internal and external), internal auditing, strategy development and providing and maintaining IT solutions. Also includes processing required to effectively manage data including scanning, classification and labelling. Most of these processes are conducted to execute activities vital to the internal management of our business and are imperative to the performance of our agreements with clients, customers and suppliers, however some will be conducted in order 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 that the least intrusive approach is followed. Other processing may 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 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, technology providers 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 in line with this privacy statement including when processing involves third parties and entities within 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, surveys and strategies, promoting products and services provided by the Companies and affiliated Aegon Asset Management companies, running and contributing to promotional events and the use of ad hoc competitions and promotions.
We may use the personal data we have to send you marketing information and news about our products and services that may be of interest to you, unless you have opted out of marketing.
We may conduct marketing with our customers (including business partners) based on our legitimate interest to share product and service information with them for them to take it into account when providing a related service. When doing this we will ensure that the least intrusive method is used and that we feel the recipient would reasonably expect to receive marketing of this type. Business partners will be able to opt out of marketing from us at any point and this will be respected.
Marketing communications will be conducted using various channels such as mail, phone and email.
Please remember that you can withdraw your consent or request to opt-out of marketing communications at any time by contacting us (see section 'Your Rights'). The withdrawal of consent, or your objection to the specific processing of personal data, including for the purposes of marketing, does not affect the processing conducted before the withdrawal. It will also not affect the provision of other products and services 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. Data subjects may object to this at any time by contacting us. These analytics may include additional (personal) information obtained from third parties where we consider the use of this data fair and legal.
Cookies
We also collect information using cookies and related website tracking technology. Cookies are small files 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 website Cookie Statement and SEISMIC Cookie and Tracking Statement.
In order to conduct the processing activities stated in this statement and allow us to verify the content of calls, telephone lines are recorded whenever you contact or are contacted by certain members of our investment and portfolio management teams or trading and settlements teams. This will be conducted using the same legal basis as confirmed for the specific processing activity unless stated otherwise.
All emails or electronic communications sent to or from any member of our staff will be retained and may be monitored to complete the respective processing activities or achieve the processing purposes stated in this statement. Only the appropriate staff members are authorized to monitor or review email or message content in line with their job role.
As a global organization, personal data we collect may be transferred internationally throughout Aegon’s worldwide organization. Your personal data may be exchanged between each of the Companies as well as within the Aegon group of companies (meaning all subsidiaries and affiliates of Aegon N.V.), including the other companies in 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., Aegon Asset Management (Asia) Limited, Aegon Privacy Fund Management (Shanghai) Co. Ltd and Aegon Asset Management Hungary B.V.
We share your data for the purposes mentioned above 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. Sharing of data within the Aegon group of companies will be conducted in line with applicable regulatory requirements, including appropriate technical and organizational measures.
Our employees are authorized to access personal data only to the extent necessary to serve the mentioned above and to perform their job.
Disclosing your personal data to 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.
When third parties are given access to your personal data, we will implement such contractual, technical and organizational measures as may be legally required 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.
In other cases, your personal data will not be supplied to third parties, except:
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.
We will keep your personal data following the conclusion of our relationship and/or the processes mentioned above. This is to ensure that we comply with our record retention obligations, as set out in our internal record retention policy and determined by the appropriate supervisory and governmental authorities (including financial regulators) or other regulatory and legislative requirements. Any personal data retained after the conclusion of the relationship will be kept confidential and we will not use the information for any purpose other than to meet our legal obligations.
Each of the Companies is a U.S. Registered Investment Adviser, required to maintain certain books and records pursuant to Rule 204-2 of the Investment Advisers Act of 1940. We regularly review the applicable record retention obligations to ensure we keep personal data for the minimum time we are legally obliged to and delete information that is no longer required to be kept.
We have implemented appropriate functional, technical, physical and organizational measures designed to protect the personal data that we have under our control from:
All our employees and service providers who have access to personal information, are obliged to protect it and keep it confidential.
Of course, no network or system (including the internet) is entirely secure, and despite the measures described above, we cannot guarantee the security of networks and systems we operate or use, or that are operated on our behalf (including the security of email or other transmissions of data).
You have a number of rights with respect to personal data about you that we collect and process, including:
To exercise any of these rights, please contact our Data Protection Office.
While we will strive to honor requests you may make to exercise your rights, in considering each request we must take into account other conflicting obligations we may have as well as the rights of other data subjects. As a result, there is a chance that your request may be only partially fulfilled or in limited circumstances rejected. If this is the case an explanation will be provided to you.
If you wish to exercise your rights in relation to the processing of your personal data conducted by one of our processors or associated co-controllers then please contact us in the first instance.
If you are a California resident, please refer to our California Consumer Privacy Act Disclosure & Statement of Rights for more privacy-related disclosures and additional information about your privacy rights and our privacy practices.
Through this website, we do not purposefully market any products or services to, or knowingly gather or solicit data from, children under thirteen (13) years of age. By using this Site you represent that you are not under thirteen (13) years of age. If you are under the age of thirteen (13), please do not transmit to us any of your personal data.
If you believe we have not processed your personal data in accordance with our data protection obligations, and that you have been affected by our non-compliance, you can make a complaint to us by contacting our Data Protection Office via information provided in "Contact us".
From time to time we may make changes to this privacy statement. If we make any changes to this privacy statement and the way in which we use your personal data we will post these changes on this page and where the changes are significant we will do our best to notify you.
This privacy statement was last updated in December 2022.