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Last updated and effective: November 2023
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, its affiliates listed on Annex 1, and funds sponsored by any Wellington affiliate or subsidiary (“Wellington Affiliates”).
For the purposes of applicable data protection law, Wellington is a data controller in respect of your personal data.
This Privacy Notice governs and explains the handling and processing of personal data by Wellington while 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 nature of our relationship with you will determine the kind of personal data we might ask for from you directly or collect where permitted by law. In some cases, the collection and processing of certain of your personal data is obligatory and failure to collect that information (including where you fail to supply it) may result in us not being able to provide services or products to you. Information we may collect includes:
Your personal data may be stored and processed by us in the following ways and for the following purposes:
We may use and/or disclose your personal data in these above described ways for a variety of reasons (subject to requirements under applicable local laws), namely:
We may share your personal data amongst the Wellington Affiliates listed in Annex 1 for the purposes described above. We may also share your personal data outside of Wellington as further described below or as permitted by law:
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.
Wellington is a global business and as a result we or our external service providers collect and transfer personal data globally and may transfer your personal data to locations outside of your country or jurisdiction, including all countries of the Wellington Affiliates (see Annex 1), as well as the countries listed in Annex 2. Your personal data also may be processed by individuals operating outside of your country or jurisdiction who work for Wellington or for one of our external service providers. Wellington shall ensure that in case of transfer and processing of personal data outside the EEA, Switzerland, the UK and the Dubai International Financial Centre (in respect of which the laws of those jurisdictions apply), such processing is carried out only where allowed by an adequacy decision of the European Commission, Switzerland, the UK Information Commissioner’s Office (“ICO”) and/or the Dubai International Financial Centre (DIFC) and/or Wellington has provided for appropriate safeguards which provide you with enforceable data subject rights and effective legal remedies. This can be done in various ways, for instance:
In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA, Switzerland,the UK and/or the Dubai International Financial Centre (DIFC). In all cases, however, we will ensure that any transfer of your personal data is compliant with applicable data protection laws.
You can obtain more details of the protection given to your personal data when it is transferred outside the UK, Switzerland,EEA and/or the Dubai International Financial Centre (including a sample copy of the standard contractual clauses) by contacting us in accordance with the relevant contact details provided in the link below under Section 12 “Questions and contacting us”.
For transfer of personal data outside of the original location of collection for any other country or jurisdiction, it will be protected and transferred in a manner consistent with the applicable legal requirements. You can obtain more details of the protection given to your personal data by contacting us in the manner described in the section entitled “Questions and contacting us”.
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 laws. We limit access to personal data to authorized employees, representatives and service providers who require access for the purposes described in this Privacy Notice. Unauthorized use or disclosure of personal data or 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 aimed at protecting personal data and confidential information.
We hold Personal Data on our systems (or those of our service providers) for the duration needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine retention periods include:
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 may include:
You can exercise your rights by contacting us in the manner described in the section 12 entitled “Questions and Contacting Us”. The appropriate way to contact us, as well as the rights that may be applicable to you will, to some extent, be determined by the country that you are resident in.
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 [allaboutdnt.com]. You can visit https://www.wellington.com/en/cookies-tracking-notice/ to view Wellington’s cookies and tracking notice.
If you wish to exercise any of your rights, wish to raise a complaint on how we have handled your personal data, our data security measures or to raise a subject access request, please do so by email to PrivacyInquiries@wellington.com with the phrase “Data Subject Rights” in the subject line. You may also contact us at Global Privacy Office, Wellington Management, Cardinal Place, 80 Victoria Street, London SW1E 5JL.
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. We will process your request within the time provided by applicable law.
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.
If the personal data you provide to us is incomplete or inaccurate, we may be unable to provide you with the services you are seeking or take action on your behalf.
You may access the personal data we hold about you, upon making a written request. We will respond to your request within a reasonable period. We may charge you a reasonable fee for processing your request (but not for making the request for access). We may decline a request for access to personal data in circumstances prescribed by the Privacy Act 1988 (Cth) (Privacy Act), and if we do, we will give you a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons), including details of the mechanisms available to you to make a complaint.
If, upon receiving access to your personal data or at any other time, you believe the personal data we hold about you is inaccurate, incomplete or out of date, please notify us immediately. We will take reasonable steps to correct the data so that it is accurate, complete and up to date. If we refuse to correct your personal data, we will give you a written notice that sets out our reasons for our refusal (unless it would be unreasonable to provide those reasons), including details of the mechanisms available to you to make a complaint.
If you wish to make a complaint about a breach of the Privacy Act, the Australian Privacy Principles (APPs) or a privacy code that applies to us, please contact us using the details below and we will take reasonable steps to investigate the complaint and respond to you.
If after this process you are not satisfied with our response, you can submit a complaint to the Office of the Information Commissioner. To lodge a complaint, visit the ‘Complaints’ section of the Information Commissioner’s website, located at http://www.oaic.gov.au/privacy/privacy-complaints, to obtain the relevant complaint forms, or contact the Information Commissioner’s office.
If you have any queries or concerns about our privacy notice or the way we handle your personal data, please contact our Privacy Officer at: firstname.lastname@example.org with the phrase “Data Subject Rights” in the subject line. You may also contact us at Global Privacy Office, Wellington Management, Cardinal Place, 80 Victoria Street, London SW1E 5JL.
For more information about privacy in general, you can visit the Office of the Information Commissioner’s website at www.oaic.gov.au.
For purposes of compliance with California law, this Privacy Notice is also a Notice at Collection. California residents may also call us at +1-617-951-5000 during normal business hours Eastern Standard Time and request to speak with our Privacy Officer.
If you are a resident of Canada, Wellington Management Canada ULC controls the personal data collected in accordance with this Privacy Notice. Personal data is maintained on Wellington’s servers or those of its service providers and is accessible by its authorized employees, representatives, and service providers as necessary for the purposes described in this Privacy Notice. Wellington collects personal data with consent except as otherwise permitted or required by law.
If you wish to exercise any of your rights or have any questions in relation to how your personal data is processed by Wellington Management Canada ULC, please contact our Privacy Officer via email at PrivacyInquiries@wellington.com
12.4 Dubai residents
If you are a resident based in the Emirate of Dubai (including within the DIFC), Wellington Management (DIFC) Limited controls the personal data collected in accordance with this Privacy Notice.
If you wish to exercise any of your rights or have any questions in relation to how your personal data is processed by Wellington Management (DIFC) Limited, please contact our Privacy Officer via email at PrivacyInquiries@wellington.com, If you are unhappy with the response you receive from us you may contact the DIFC Commissioner of Data Protection. For more information, please search their website at difc.ae/data-protection
For those whose personal data is collected and handled by Wellington Management Japan Pte. Ltd., if you wish to exercise any of your rights as a Principal under Act on the Protection of Personal Information of Japan or have any questions in relation to how your personal data is processed by Wellington Management Japan Pte. Ltd., please email: #TokyoCompliance@wellington.com
Please note that Wellington Management Japan Pte. Ltd. discloses “Declaration of Personal Information Protection” in Japanese at https://www.wellington.com/jp-jp/professional/policies/privacy-policy.
To the extent permitted by law, if you wish to exercise any of your rights or any questions in relation to how your personal data is processed by Wellington Management Singapore Pte. Ltd., please email:
Ammin Ali: AlAli@wellington.com, copying PrivacyInquiries@wellington.com, with the phrase “Data Subject Rights” in the subject line. This would assist us in attending to your matter speedily by passing it on to the relevant staff in our organisation to handle. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. We reserve the right, or may, charge a reasonable fee for the processing of any data access request.
We will strive to deal with any issue you may raise speedily and fairly.
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 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 this notice, please contact us at PrivacyInquiries@wellington.com.
Wellington Management Company LLP
|280 Congress Street
Boston, Massachusetts 02210 USA
Wellington Alternative Investments LLC
|280 Congress Street
Boston, Massachusetts 02210 USA
Wellington Global Administrator, Ltd
2 Church Street
Hamilton HM 11
Wellington Management International Limited
80 Victoria Street
London SW1E 5JL UK
Wellington Management Europe GmbH
|Bockenheimer Landstraße 43 - 47
60325 Frankfurt am Main
Wellington Luxembourg S.à r.l.
|33, Avenue de la Liberté
Wellington Management Hong Kong Limited
|14th Floor, One Taikoo Place
979 King's Road
Wellington Management Japan Pte. Ltd.
|Palace Building 7F 1-1-1 Marunouchi
Chiyoda-ku Tokyo 100-0005 Japan
Wellington Management Australia Pty Ltd
|Governor Macquarie Tower
1 Farrer Place
Sydney NSW 2000
Wellington Management Singapore Pte. Ltd.
|One Marina Boulevard #28-00
Wellington Management Switzerland GmbH
Wellington Management Canada ULC
|1200 Waterfront Centre
200 Burrard Street, P.O. Box 48600
Vancouver, BC V7X 1T2
Wellington Trust Company, NA
|280 Congress Street
Boston, Massachusetts 02210 USA
|Wellington Management (DIFC) Limited
Level 15, Gate District Gate Building,
Dubai International Financial Centre,
United Arab Emirates
List of Countries / Jurisdictions where Wellington may transfer personal data