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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, any of its affiliates, subsidiaries, or any other entities under common control, or funds sponsored by any Wellington affiliate or subsidiary (“Wellington Affiliates”).
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 and privacy laws. 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
The nature of our relationship with you will determine the kind of personal data we might ask for, such information may include (by way of a non-exhaustive list):
USES OF YOUR PERSONAL DATA
Your personal data may be stored and processed by us in the following ways and for the following purposes:
We may use your personal data in these ways for a variety of reasons. These include:
DISCLOSURE OF YOUR INFORMATION TO AFFILIATES AND 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 or as permitted by law:
SALE OF PERSONAL DATA
In the course of business, 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.
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 we transfer personal data to another country, it will be protected and transferred in a manner consistent with legal requirements. For example, any personal data that is transferred from Singapore to another country will be protected at a standard that is comparable to that under Singapore’s Personal Data Protection Act 2012.
You can obtain more details of the protection given to your personal data by contacting us in the manner described in the section entitled “For Singapore Residents” 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. Unauthorized use or disclosure of 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 in an effort to protect confidential information.
RETENTION OF PERSONAL DATA
How long we hold your personal data for will vary. The retention period will be determined by the following:
RIGHTS UNDER RELEVANT DATA PROTECTION LAW
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 include, without limitation:
You can exercise your rights by contacting us in the manner described in the section entitled “For Singapore Residents” below. Please note that your withdrawal of consent for the collection, use and/or disclosure of your personal data could result in us being unable to provide any services to you.
DO NOT TRACK NOTICE
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. You can visit https://www.wellingtonfunds.com/en-gb/institutional/cookie-policy. to view Wellington’s cookies and tracking notice.
FOR CALIFORNIA AND EU/EEA RESIDENTS
California Consumer Privacy Act becomes effective on 1 January 2020
If you wish to exercise any of your rights, please email PrivacyEnquiries@wellington.com with the phrase “Data Subject Rights” in the subject line. You may also call us at +1-617-951-5000 and request to speak with the Global Privacy Officer. 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.
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.
We will process your request within the time provided by applicable law.
FOR SINGAPORE RESIDENTS
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 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.
UPDATES TO THIS PRIVACY NOTICE AND ADDITIONAL INFORMATION
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 or updates 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 our approach to privacy, please contact us at PrivacyEnquiries@wellington.com.
Last updated 1 January 2021
List of Wellington entities
|Wellington Management Company LLP||Wellington Funds (US) LLC|
|Wellington Alternative Investments LLC||Wellington Management Funds LLC|
|Wellington Funds Services LLC|
|Wellington Global Administrator, Ltd||Wellington Management Funds (Luxembourg)|
|Wellington Management International Limited||Wellington Luxembourg S.à r.l.|
|Wellington Management Europe GmbH||Wellington Management Funds (Luxembourg) II SICAV|
|Wellington Management Europe GmbH,Succursale di Milano||Wellington Management Funds (Luxembourg) III SICAV|
|Wellington Management Hong Kong Ltd||Wellington Alternative Investments GP Late Stage Growth Luxembourg Sàrl|
|Wellington Management Funds (Ireland) plc||Wellington Management Singapore Pte Ltd|
|Wellington Management Japan Pte Ltd||Wellington Management Switzerland GmbH|