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, and funds sponsored by any Wellington affiliate or subsidiary (“Wellington Affiliates”).
1. ABOUT THIS PRIVACY NOTICE
This Privacy Notice governs and explains the handling and processing 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.
2. 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 includes:
- Information about you: your name, date of birth, contact details, personal email address, home address, professional information or employment related information, educational information or background, passport details, driver’s license details or other similar identification numbers and documents.
- Information if you visit one of our offices: visual images collected via closed circuit television (CCTV).
- Information that is automatically collected: details about your use of Wellington websites which may include internet browser history, IP addresses, and access to application forms.
- Information about our contact with you and information we generate internally about our relationship with you:
- files that we may produce as a record of our relationship with our clients and prospective clients, including, but not limited to, preferences and contact history;
- any personal data that you provide during telephone and email communications with us which we may monitor and record in order to resolve complaints, improve our service and in order to comply with our legal and regulatory requirements;
- any personal data that you may voluntarily submit to us via psychometric testing and the related testing results (for example, answers to a range of questions about your preferences in relation to how you typically relate to others;
- commercial information, such as records of the products or services our clients currently use from Wellington or have inquired about obtaining from Wellington.
- Information that we obtain from other sources:
- information from publicly available sources (including third party agencies such as credit reference agencies; fraud prevention agencies; law enforcement agencies; public databases, registers and records such as Companies House and the FCA Register; and other publicly accessible sources);
- information obtained from the transfer agents or administrators of Wellington Funds distributors or financial intermediaries, platforms, professional advisers including consultants, lawyers and tax advisers, product providers, event organizers, and other agents and/or representatives; and
- information obtained from sanctions checking and background screening providers.
- Information classified as ‘sensitive’ personal data: information about your nationality, place of birth, medical and health related information, disability status, biometric data, or details of political affiliations.
3. USES OF YOUR PERSONAL DATA
Your personal data may be stored and processed by us in the following ways and for the following purposes:
- to manage your relationship and/or account with Wellington;
- to assess clients’ and prospective clients’ applications or contracts for Wellington products and services;
- to keep our records up to date;
- for ongoing review and improvement of the information provided on Wellington’s websites to ensure they are user friendly and to prevent any potential disruptions or cyber-attacks;
- to monitor IT systems in order to protect against cyber threats or malicious activity including abuse and misuse;
- to communicate with clients and prospective clients in order to provide services or information about Wellington and other Wellington products and services;
- to effectively manage and strengthen client and prospective client relationships, understand client and prospective client needs and interests and learn more about our clients and prospective clients in order to develop, improve and manage the products and services we can offer;
- for the management and administration of Wellington’s business; or
- in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures.
- to provide personalized computer-generated reports from completion by respondents of our psychometric assessment questionnaires, via our vendor’s web-based platform, Core Strengths and to provide feedback on your underlying motivations, to enable you to understand why you behave as you do and how you relate to others.
4. LEGAL GROUNDS
We may use your personal data in these ways for a variety of reasons. Namely:
- we are performing our contractual obligations with you (i.e. Art. 6 para. 1 lit. b) GDPR);
- we have obtained your consent (i.e. Art. 6 para. 1 lit. a) GDPR);
- we have legal and regulatory obligations that we have to discharge (i.e. Art. 6 para. 1 lit. c) GDPR);
- we may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings (i.e. Art. 6 para. 1 lit. f) GDPR); or
- the use of your personal data as described is necessary for legitimate business interests (i.e. Art. 6 para. 1 lit. f) GDPR), such as:
- allowing us to effectively and efficiently manage and administer the operation of our business;
- maintaining compliance with internal policies and procedures; and
- enabling quick and easy access to information on Wellington products.
5. DISCLOSURE OF YOUR INFORMATION TO AFFILIATES AND THIRD PARTIES
We may share your personal data within Wellington for the purposes described above. . Please find a list of the Wellington Affiliates [Annex 1]. We may also share your personal data outside of the Wellington as further described below or as permitted by law:
- with our business partners (such as broker dealers and counterparties) who will be subject to appropriate data protection obligations;
- with representatives, agents, custodians, administrators, intermediaries and/or other third party product providers appointed by the client, or prospective client or fund (such as accountants, auditors and professional advisors);
- with third party agents and contractors for the purposes of them providing services both to us (for example, Wellington’s accountants, professional advisors, IT and communications providers, background screening providers, credit reference agencies) and to clients, or prospective clients or funds. These third parties will be subject to appropriate data protection obligations; and
- to the extent required by law or regulation, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators, auditors or public authorities), or to establish, exercise or defend our legal rights.
6. 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.
7. INTERNATIONAL TRANSFERS OF PERSONAL DATA
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. Your personal data may also be processed by individuals operating outside of your country 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 EU/EEA and the UK (which are not subject to the Commission’s adequacy decisions), such processing is carried out only where allowed by an adequacy decision of the European Commission and/or Wellington has provided for appropriate safeguards which provide you with enforceable data subject rights and effective legal remedies.
8. 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.
9. RETENTION OF PERSONAL DATA
We hold Personal Data 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:
- The duration of our contractual relationship with our client and the provision of related services;
- The legal obligations to which we are subject – laws or regulation may set a minimum period for which we have to keep your personal data.
10. 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:
- the right to obtain information regarding the processing of your personal data and access to your personal data which we process at the time of your request;
- where you have actively provided your consent for us to process your personal data, the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so, such as a legal or regulatory obligation. If you decline to provide or withdraw your consent to our use of the data and we are relying on consent as the legal basis for its processing, there are circumstances in which we will not be able to provide you with services or take action on your behalf;
- the right to request that we rectify your personal data if it is inaccurate or incomplete;
- subject to the conditions and scope set forth in Art. 17 para. 1 GDPR and sec. 35 of the German Federal Data Protection Act (“BDSG”) the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
- subject to the conditions and scope set forth in Art. 18 GDPR the right to request that we restrict, our processing of your personal data;
- subject to the conditions and scope set forth in 21 GDPR, the right to object to the processing of your personal data by us;
- subject to the conditions and scope set forth in Art. 20 GDPR, the right to port and/or get your data portability by us to another data controller;
- the right to lodge a complaint with the data protection supervisory authority competent at the place of your residence, working place or place of an alleged infringement of data protection laws, if you think that our processing of your personal data has infringed upon any applicable data protection regulations. We are always open to dialogue to resolve issues short of formal disputes.
The competent supervisory authority for any processing of personal data by Wellington within Germany is: The Hessian Commissioner for Data Protection and Freedom of Information P.O. Box 3163 65021 Wiesbaden, email : firstname.lastname@example.org .
11. 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.wellington.com/en/cookies-tracking-notice/ to view Wellington’s cookies and tracking notice.
12. FOR CALIFORNIA AND, EU/EEA AND UK RESIDENTS (AS APPLICABLE)
If you wish to exercise any of your rights, please email 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. California residents may also call us at +1-617-951-5000 during normal business hours Eastern Standard Time 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.
13. 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 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.
Last updated 16 September 2021
List of Wellington entities
A. US entities
Wellington Management Company LLP
|Wellington Funds (US) LLC
Wellington Alternative Investments LLC
|Wellington Management Funds LLC
Wellington Funds Services LLC
B. Non-US entities
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 Management Funds (Luxembourg) III SICAV
Wellington Management Funds (Ireland) plc
|Wellington Alternative Investments GP Late Stage Growth Luxembourg Sàrl
Wellington Management Japan Pte Ltd
|Wellington Management Switzerland GmbH
Wellington Management Australia Pty Ltd