Privacy and cookie policy
EMEA Privacy & Cookie Policy Privacy Statement
1. Your data controller
This Privacy Notice relates solely to information supplied by
you to us via our websites. Threadneedle Asset Management Holdings
Limited registered in England and Wales under company number
03554212 and whose registered office is at Cannon Place, 78 Cannon
Street, London EC4N 6AG ("Threadneedle"). Any reference to
Threadneedle shall also include reference to or any of the
Threadneedle group of companies including its holding companies,
subsidiaries and affiliates. The data controller in respect of any
Personal Data provided is Threadneedle Asset Management Holdings
Limited and other Controllers identified in section 14. In this
privacy statement "we", "us" and "our" means Threadneedle and is
addressed to individuals outside our organisation with whom we
interact, including visitors to our websites (our "Sites"),
customers, Personnel of corporate customers, investors and vendors,
and other recipients of our services (together, "you"). Defined
terms used in this Policy are explained in Section 14. We shall
respect the privacy of your Personal Data, treat it as confidential
and keep it secure, subject to the provision of applicable laws
below.
2. Processing your Personal Data
This Privacy Policy covers the information about you ("Personal
Data") that Personal Data you supply to us through this website or
otherwise any other additional Personal Data that you provide to
us.
Collection of Personal Data: We collect Personal Data about you,
subject to applicable law, from a variety of sources as
follows:
- We obtain your Personal Data when you provide it to us (e.g.,
where you contact us via email or telephone, or by any other
means).
- We collect your Personal Data in the ordinary course of our
relationship with you (e.g., in the course of managing your
transactions or your investment in our funds).
- We collect Personal Data that you manifestly choose to make
public, including via social media (e.g., we may collect
information from your social media profile(s), to the extent that
you choose to make your profile publicly visible).
- We receive your Personal Data from third parties who provide it
to us (e.g., your employer; your customers; credit reference
agencies; law enforcement authorities; etc.).
- We receive your Personal Data from third parties, where you
purchase any of our products or services through such third
parties.
- We collect or obtain Personal Data when you visit any of our
Sites or use any features or resources available on or through a
Site. When you visit a Site, your device and browser may
automatically disclose certain information (such as device type,
operating system, browser type, browser settings, IP address,
language settings, dates and times of connecting to a Site and
other technical communications information), some of which may
constitute Personal Data.
Creation of Personal Data: We may also create Personal Data
about you, such as records of your interactions with us, and
details of your accounts, subject to applicable law.
Relevant Personal and Special Category Data: The categories of
Personal Data about you that we may Process, subject to applicable
law, are as follows:
- Personal details: given name(s); preferred name; nickname(s),
gender; date of birth / age; marital status; Social Security
Number; Passport number(s); other Government(s) issued numbers (tax
identification number, Green Card(s) number(s) including Driving
Licence number); nationality; lifestyle and social circumstances;
images of Passports; images of Driving Licences; images of Gun
Licence(s); images of signatures; authentication data (passwords,
mother maiden name, challenge/response questions and answers, PINs,
face recognition, voice recognition) and photograph, visual images,
personal appearance and behaviour.
- Family details: names and contact details of family members and
dependents.
- Contact details: address; telephone number; fax number; email
address; and social media profile details.
- Employment details: industry; role; business activities; names
of current and former employers; work address; work telephone
number; work fax number; work email address; and work-related
social media profile details.
- Education history: details of your education and
qualifications.
- Financial details: billing address; bank account numbers;
credit card numbers; cardholder or accountholder name and details;
instruction records; transaction details; and counterparty
details.
- Views and opinions: any views and opinions that you choose to
send to us, or publish about us on (including on social media
platforms).
- Electronic Identifying Data: IP address cookies, logs, online
identifiers, device IDs, geolocation.
Processing your Special Category Data: We do not seek to collect
or otherwise Process your Special Category Data, except where:
- The Processing is necessary for compliance with a legal
obligation (e.g., to comply with our diversity reporting
obligations);
- The Processing is necessary for the detection or prevention of
crime (including the prevention of fraud) to the extent permitted
by applicable law;
- You have manifestly made your Special Category Data
public;
- The Processing is necessary to protect the vital interests of
any individual; or
- We have, in accordance with applicable law, obtained your prior
explicit consent prior to Processing your Special Category Data (as
above, this legal basis is only used in relation to Processing that
is entirely voluntary - it is not used for Processing that is
necessary or obligatory in any way); or
- Processing is necessary for reasons of substantial public
interest and occurs on the basis of an applicable law that is
proportionate to the aim pursued and provides for suitable and
specific measures to safeguard your fundamental rights and
interests.
We only Process Criminal Offences Data, and national
identification numbers, to the extent required or permitted by
applicable law.
Purposes for which we may Process your Personal Data, and legal
bases for Processing: The purposes for which we may Process
Personal Data, subject to applicable law, and the legal bases on
which we may perform such Processing, are:
Processing activity |
Legal basis for Processing |
AML/KYC: fulfilling our regulatory compliance
obligations, including 'Know Your Client' checks; and confirming
and verifying your identity (including by using credit reference
agencies); and screening against government, supranational bodies
(including but not limited to the European Union and the United
Nations Security Council) and/or law enforcement agency sanctions
lists as well as internal sanctions lists and other legal
restrictions. |
- The Processing is necessary for compliance with a legal
obligation; or
- The Processing is necessary in connection with any contract
that you may enter into with us, or to take steps prior to entering
into a contract with us; or
- We have a legitimate interest in carrying out the Processing
for the purpose of protecting against fraud (to the extent that
such legitimate interest is not overridden by your interests,
fundamental rights, or freedoms); or
- We have obtained your prior consent to the Processing (this
legal basis is only used in relation to Processing that is entirely
voluntary - it is not used for Processing that is necessary or
obligatory in any way).
|
Client on-boarding: request for proposals (RFPs),
on-boarding new clients; and compliance with our internal
compliance requirements, policies and procedures. |
- The Processing is necessary in connection with any contract
that you may enter into with us, or to take steps prior to entering
into a contract with us; or
- We have a legitimate interest in carrying out the Processing
for the purpose of on-boarding new clients (to the extent that such
legitimate interest is not overridden by your interests,
fundamental rights, or freedoms).
|
Credit worthiness: conducting credit reference
checks and other financial due diligence |
- The Processing is necessary in connection with any contract
that you may enter into with us, or to take steps prior to entering
into a contract with us; or
- We have a legitimate interest in carrying out the Processing
for the purpose of on-boarding new clients (to the extent that such
legitimate interest is not overridden by your interests,
fundamental rights, or freedoms).
|
Provision of products and services to you:
administering relationships and related services; performance of
tasks necessary for the provision of the requested services;
communicating with you in relation to those services. |
- The Processing is necessary in connection with any contract
that you may enter into with us, or to take steps prior to entering
into a contract with us; or
- We have a legitimate interest in carrying out the Processing
for the purpose of providing services to you (to the extent that
such legitimate interest is not overridden by your interests,
fundamental rights, or freedoms); or
- We have obtained your prior consent to the Processing (this
legal basis is only used in relation to Processing that is entirely
voluntary - it is not used for Processing that is necessary or
obligatory in any way).
|
Marketing / Prospecting: communicating with you
via any means (including via email, telephone, text message, social
media, post or in person) subject to ensuring that such
communications are provided to you in compliance with applicable
law; and maintaining and updating your contact information where
appropriate. |
- We have a legitimate interest in carrying out the Processing
for the purpose of conducting marketing and prospecting (to the
extent that such legitimate interest is not overridden by your
interests, fundamental rights, or freedoms); or
- We have obtained your prior consent to the Processing (this
legal basis is only used in relation to Processing that is entirely
voluntary - it is not used for Processing that is necessary or
obligatory in any way).
|
Operation of our Sites: operation and management
of our Sites; providing content to you; displaying advertising and
other information to you; and communicating and interacting with
you via our Sites. |
- The Processing is necessary in connection with any contract
that you may enter into with us, or to take steps prior to entering
into a contract with us; or
- We have a legitimate interest in carrying out the Processing
for the purpose of providing services to you (to the extent that
such legitimate interest is not overridden by your interests,
fundamental rights, or freedoms); or
- We have obtained your prior consent to the Processing (this
legal basis is only used in relation to Processing that is entirely
voluntary - it is not used for Processing that is necessary or
obligatory in any way).
|
IT operations: management of our
communications systems; operation of IT security; and IT security
audits. |
- The Processing is necessary for compliance with a legal
obligation; or
- We have a legitimate interest in carrying out the Processing
for the purpose of managing and operating our IT systems and
ensuring the security of those systems (to the extent that such
legitimate interest is not overridden by your interests,
fundamental rights, or freedoms).
|
Health and safety: health and safety assessments
and record keeping; and compliance with related legal
obligations. |
- The Processing is necessary for compliance with a legal
obligation; or
- We have a legitimate interest in carrying out the Processing
for the purpose of providing a safe and secure environment at our
premises (to the extent that such legitimate interest is not
overridden by your interests, fundamental rights, or freedoms);
or
- The Processing is necessary to protect the vital interests of
any individual.
|
Financial management: sales;
finance; corporate audit; and vendor management. |
- We have a legitimate interest in carrying out the Processing
for the purpose of providing a safe and secure environment at our
premises (to the extent that such legitimate interest is not
overridden by your interests, fundamental rights, or freedoms);
or
- We have obtained your prior consent to the Processing (this
legal basis is only used in relation to Processing that is entirely
voluntary - it is not used for Processing that is necessary or
obligatory in any way).
|
Research: conducting market or customer
satisfaction research; and engaging with you for the purposes of
obtaining your views on our products and services. |
- We have a legitimate interest in carrying out the Processing
for the purpose of providing a safe and secure environment at our
premises (to the extent that such legitimate interest is not
overridden by your interests, fundamental rights, or freedoms);
or
- We have obtained your prior consent to the Processing (this
legal basis is only used in relation to Processing that is entirely
voluntary - it is not used for Processing that is necessary or
obligatory in any way).
|
Security: physical security of our premises
(including records of visits to our premises and CCTV recordings);
and electronic security (including login records and access
details, where you access our electronic systems). |
- The Processing is necessary for compliance with a legal
obligation; or
- We have a legitimate interest in carrying out the Processing
for the purpose of ensuring the physical and electronic security of
our business and our premises (to the extent that such legitimate
interest is not overridden by your interests, fundamental rights,
or freedoms).
|
Investigations: detecting, investigating and
preventing breaches of policy, and criminal offences, in accordance
with applicable law. |
- The Processing is necessary for compliance with a legal
obligation; or
- We have a legitimate interest in carrying out the Processing
for the purpose of detecting, and protecting against, breaches of
our policies and applicable laws (to the extent that such
legitimate interest is not overridden by your interests,
fundamental rights, or freedoms).
|
Legal compliance: compliance with
our legal and regulatory obligations under applicable
law. |
- The Processing is necessary for compliance with a legal
obligation.
|
Legal proceedings: establishing, exercising and
defending legal rights. |
- The Processing is necessary for compliance with a legal
obligation; or
- We have a legitimate interest in carrying out the Processing
for the purpose of establishing, exercising or defending our legal
rights (to the extent that such legitimate interest is not
overridden by your interests, fundamental rights, or
freedoms).
|
Improving our products and services: identifying
issues with existing products and services; planning improvements
to existing products and services; and creating new products and
services. |
- We have a legitimate interest in carrying out the Processing
for the purpose of improving our products or services (to the
extent that such legitimate interest is not overridden by your
interests, fundamental rights, or freedoms); or
- We have obtained your prior consent to the Processing (this
legal basis is only used in relation to Processing that is entirely
voluntary - it is not used for Processing that is necessary or
obligatory in any way).
|
Risk Management: Audit, compliance, controls and
other risk management. |
- The Processing is necessary for compliance with a legal
obligation; or
- We have a legitimate interest in carrying out the Processing
for the purpose of managing the levels of risk to which our
business is exposed (to the extent that such legitimate interest is
not overridden by your interests, fundamental rights, or
freedoms).
|
Fraud prevention: Detecting, preventing and
investigating fraud. |
- The Processing is necessary for compliance with a legal
obligation; or
- We have a legitimate interest in carrying out the Processing
for the purpose of detecting, and protecting against, fraud (to the
extent that such legitimate interest is not overridden by your
interests, fundamental rights, or freedoms).
|
3. Sharing of your Personal Data
We may use external third parties such as those described below
to process your Personal Data on our behalf in accordance with
these purposes.
If applicable, where you have notified us of your adviser, the
Personal Data provided may be shared with such adviser. You must
notify us in writing if you no longer wish us to share your
Personal Data with your adviser or of any change to your adviser.
Your adviser should have its own arrangements with you about its
use of your Personal Data. The Personal Data provided may also be
shared with other organisations in order for us to comply with any
legal or regulatory requirements (e.g., audit reporting and
anti-money laundering checks). In addition, we may share your
Personal Data with the companies within the Threadneedle group for
the purposes set out in this privacy statement.
Additionally Threadneedle may communicate your Personal Data to
such authorised individuals and entities as are listed below,
including but not limited to those parties for which you
subsequently give us permission, or is under either a legal
obligation or any other duty to do so. For the purposes detailed
above, your information may be disclosed to:
- any other branches or companies within our group of
companies;
- any regulatory, supervisory, governmental or quasi-governmental
authority with authority and jurisdiction over us;
- any agent, contractor or third party service provider,
professional adviser or any other person under a duty of
confidentiality to Columbia Threadneedle Investments;
- any credit reference agency and, in the event of default, any
debt collection agency;
- any actual or potential participant or sub-participant in,
assignee, novatee or transferee of, our rights and/or obligations
in relation to you; and,
- any financial institution with which we have or propose to have
dealings
See also under 'Overseas transfers' below.
4. Business changes
If we or the Threadneedle group undergoes a group reorganisation
or is sold to a third party, the Personal Data provided to us may
be transferred to that reorganised entity or third party and used
for the purposes highlighted above.
5. Overseas transfers
We may transfer your Personal Data to countries located outside
of the European Economic Area (the EEA), including to the United
States and India. This may happen when our servers, suppliers
and/or, service providers are based outside of the EEA. We may
transfer your information under certain circumstances (e.g., where
it is necessary to perform our contract with you). The data
protection laws and other laws of these countries may not be as
comprehensive as those that apply within the EEA - in these
instances we will take steps to ensure that your privacy and
confidentiality rights are respected.
Where we transfer your Personal Data to other countries, we do
so on the basis of:
- European Commission's adequacy decisions;
- suitable Standard Contractual Clauses; or
- other valid transfer mechanisms.
If you want to receive more information about the safeguards
applied to international transfers of personal data, please use the
contact details provided in the "Contact Information" section
below.
6. Your rights
With limited exceptions, you are entitled, in accordance with
applicable law, to object to or request restriction of processing
of your Personal Data, and to request access to, rectification,
erasure and portability of your Personal Data. This service is
provided free of charge unless requests are manifestly unfounded or
excessive. In these circumstances, we reserve the right to charge a
reasonable fee or, refuse to act on the request. You can write to
us at Threadneedle Investment Services Limited, PO Box 10033,
Chelmsford, Essex CM99 2AL or alternatively see Contact Information
in section 13 below.
If any of the information that we hold about you is wrong,
please tell us and we will put it right.
Subject to any applicable local laws and regulations, if you
prefer not to be kept informed of our products and services, please
let us know.
You may lodge a complaint with a Data Protection Authority if
you consider our processing of your Personal Data may infringe
applicable law.
7. Third Party Information
If you provide us with information about another person, you
confirm you already have explicit confirmation that such other
person has appointed you to act for them to consent to the
processing of their Personal Data by us. This means that you have
informed them of our identity and the purpose for which their
Personal Data will be processed, namely to verify their name and
address and otherwise only in connection with you. You agree to
keep us, and any Threadneedle group company or relevant third party
fully indemnified for your not having complied with this
paragraph.
8. Data Security
We maintain reasonable security measures to safeguard Personal
Data from loss, interference, misuse, unauthorised access,
disclosure, alteration or destruction. You are responsible for
ensuring that any Personal Data that you send to us are sent
securely.
We also maintain reasonable procedures to help ensure that such
data is reliable for its intended use and is accurate, complete and
current.
9. Data Accuracy
We take reasonable steps designed to ensure that:
- your Personal Data that we Process are accurate and, where
necessary, kept up to date; and
- any of your Personal Data that we Process that are inaccurate
(having regard to the purposes for which they are Processed) are
erased or rectified without delay. From time to time we may ask you
to confirm the accuracy of your Personal Data.
10. Data Minimisation
We take reasonable steps designed to ensure that your Personal
Data that we Process are limited to the Personal Data reasonably
required in connection with the purposes set out in this
Notice.
11. Data Retention
We take every reasonable step to ensure that your Personal Data
are only Processed for the minimum period necessary for the
purposes set out in this Notice. The criteria for determining the
duration for which we will retain your Personal Data are as
follows:
(1) we will retain copies of your Personal Data in a form that
permits identification only for as long as:
a. we maintain an ongoing relationship with you (e.g., where you
are a recipient of our services, or you are lawfully included in
our mailing list and have not unsubscribed); or
b. your Personal Data are necessary in connection with the
lawful purposes set out in this Notice, for which we have a valid
legal basis (e.g., where your personal data are included in a
contract between us and your employer, and we have a legitimate
interest in processing those data for the purposes of operating our
business and fulfilling our obligations under that contract; or
where we have a legal obligation to retain your Personal Data),
plus:
(2) the duration of:
a. any applicable limitation period under applicable law (i.e.,
any period during which any person could bring a legal claim
against us in connection with your Personal Data, or to which your
Personal Data may be relevant); and
b. an additional twelve (12) month period following the end of
such applicable limitation period (so that, if a person bring a
claim at the end of the limitation period, we are still afforded a
reasonable amount of time in which to identify any Personal Data
that are relevant to that claim),
and:
(3) in addition, if any relevant legal claims are brought, we
may continue to Process your Personal Data for such additional
periods as are necessary in connection with that claim.
During the periods noted in paragraphs (2)a and (2)b above, we
will restrict our Processing of your Personal Data to storage of,
and maintaining the security of, those data, except to the extent
that those data need to be reviewed in connection with any legal
claim, or any obligation under applicable law.
Once the periods in paragraphs (1), (2) and (3) above, each to
the extent applicable, have concluded, we will either:
- permanently delete or destroy the relevant Personal Data;
- archive your Personal Data so that it is beyond use; or
- anonymize the relevant Personal Data.
12. Cookies
A "cookie" is a small piece of encoded information sent by a web
server to be stored on your web browser (Internet Explorer, Chrome,
Firefox, Safari, etc.) so that it can remember something about you
such as username, password, references at a later date. Cookies
have three functions: security, log in and responsibility
discharge.
A cookie also ensures that there is a unique identification when
you visit the ColumbiaThreadneedle.com website and helps us to
determine what page you may see next time you visit the website.
This process enables us to provide you with personalised
information and simplify your user experience.
We use persistent cookies that do not expire at the end of a
user session. The cookie stored on your web browser does not
contain any Personal Data and is encrypted and only our web server
can read it.
Specifically cookies may:
- allow us to recognise the PC you are using when you return to
our website so that we can understand your interest in our website
and tailor website content and advertisements to match your
interests;
- identify you after you have logged in by storing a temporary
reference number in the cookie so that our web server can conduct a
dialogue with you while simultaneously dealing with other
customers. (Your browser keeps this type of cookie until you log
off or close down your browser when these types of cookie are
normally deleted. No other information is stored in this type of
cookie);
- allow you to carry information across pages of our website and
avoid having to re-enter that information;
- allow you access to stored information if you register for any
of our on-line services;
- enable us to produce statistical information (anonymous) which
helps us to improve the structure and content of our website;
and/or,
- enable us to evaluate the effectiveness of our advertising and
promotions.
To learn more about cookies and how to manage them, visit aboutcookies.org.
Our use of cookies
On our website we use cookies to improve our service and to help
manage your visit. The list below shows all of the cookies that are
set by this website and third-party services we use.
Cookies for improving service
Google Analytics sets cookies to help us accurately estimate the
number of visitors to the website, what pages you visit, how long
you are on the site, how you got here and what you click on. We use
this to improve the user experience. We do not collect or store
your Personal Data (e.g. your name or address) so this information
cannot be used to identify who you are.
The following cookies are set by Google Analytics:
Name |
Typical Content and Description |
Expires |
_utma |
Randomly generated
number
This cookie keeps track of the number of times a visitor has been
to the site, when their first visit was, and when their last visit
occurred. |
2 years |
_utmb |
Randomly generated
number
This cookie takes a timestamp of the exact moment in time when a
visitor enters a site. |
30 minutes |
_utmc |
Randomly generated
number
This cookie takes a timestamp of the exact moment in time when a
visitor leaves a site. |
When you close your
browser |
_utmz |
Randomly generated number
and information on how the site was reached (e.g. direct or via a
link, organic search or paid search).
This cookie keeps track of where the visitor came from, what
search engine you used, what link you clicked on, what keyword you
used, and where they were in the world when you accessed our
website. |
6 months |
_utmt |
Used to throttle request
rate |
10 minutes |
_utmv |
Used to store visitor-level
custom variable data. |
2 years |
_dc_gtm_UA-608432-13 |
Google Tag Manager: used to
manage all scripts on the website |
10 minutes |
The information generated by the cookie about the use of the
website will normally be stored on a Google server in the United
States. However, if you are located within the EU or the European
Economic Area, your IP address will be shortened by Google
beforehand. In exceptional cases only, your full address will be
transmitted to a Google server in the United States and shortened
there. On our behalf, Google will use this information for the
purpose of compiling reports on website activity and providing
other services relating to website activity and internet usage. The
IP address transmitted from your browser as part of Google
Analytics will not be associated with any other data held by
Google. You may prevent web usage data (including your IP address)
generated by the cookie from being transmitted to Google and
processed there if you download and install this Browser-Plugin.
Cookies for managing your visit
We use a number of cookies to remember your selections and
preferences that you've made when looking at the information on
this site. These cookies inform us whether you're a returning
visitor, whether you have accepted our disclaimer and website terms
and conditions, what investor type you are and what's your language
preference.
The following cookies are set by us:
Name |
Typical Content |
Expires |
sessionId |
Randomly generated letters
and numbers |
When you close your
browser |
sessionlastupdated |
Randomly generated
number |
When you close your
browser |
__RequestVerificationToken_Lw__ |
Randomly generated letters
and numbers |
When you close your
browser |
.ASPXAUTH |
Used to determing if a user
is authenticated |
When you close your
browser |
AWSELB |
Randomly generated letters
and numbers |
When you close your
browser |
RPM_vref |
Randomly generated letters
and numbers |
When you close your
browser |
RPM_vrref |
Randomly generated letters
and numbers |
When you close your
browser |
culture |
Dependant on your language
preference: en-GB, fr-FR, de-DE, it-IT, es-ES, NL-nl or pt-PT |
1 year |
Global-disclaimer |
Accepted |
1 year |
private-disclaimer |
Accepted |
1 year |
Intermediary-disclaimer |
Accepted |
1 year |
Institutional-disclaimer |
Accepted |
1 year |
Distribution
partner-disclaimer |
Accepted |
1 year |
Investor type |
Dependant on your investor
type preference: private, intermediary, institutional or
distribution partner |
1 year |
Turning off Cookies
If you do not wish to have a cookie stored on your computer, you
should disable them in your browsers security options using your
browsers anonymous usage setting (called "Incognito" in Chrome,
"InPrivate" for Internet Explorer, "Private Browsing" in Firefox
and Safari etc.). If you do this we will not place cookies on your
computer. Please note that by deleting our cookies or disabling
future cookies you may not be able to access certain areas or
features of our site and the site will not work as well as if you
had permitted our use of cookies.
13. Contact Information
You can raise any issues regarding the processing of your
Personal Data by contacting our Data Protection Officer at any
time:
DPO@columbiathreadneedle.com
Cannon Place, 78 Cannon Street, London EC4N 6AG
14. Controllers
Threadneedle Asset
Management Holdings Ltd |
Cannon Place, 78 Cannon
Street, London EC4N 6AG |
Threadneedle Asset
Management Limited |
Cannon Place, 78 Cannon
Street, London EC4N 6AG |
Threadneedle International
Limited |
Cannon Place, 78 Cannon
Street, London EC4N 6AG |
Threadneedle Investment
Services Ltd |
Cannon Place, 78 Cannon
Street, London EC4N 6AG |
Threadneedle Management
Services Limited |
Cannon Place, 78 Cannon
Street, London EC4N 6AG |
Threadneedle Pension
Trustees Limited |
Cannon Place, 78 Cannon
Street, London EC4N 6AG |
Threadneedle Pensions
Limited |
Cannon Place, 78 Cannon
Street, London EC4N 6AG |
Threadneedle Portfolio
Services Limited |
Cannon Place, 78 Cannon
Street, London EC4N 6AG |
Threadneedle Property
Investments Ltd |
Cannon Place, 78 Cannon
Street, London EC4N 6AG |
Threadneedle Unit Trust
Manager Limited |
Cannon Place, 78 Cannon
Street, London EC4N 6AG |
Threadneedle Management
Luxembourg SA |
44, rue de la Vallée L-2661
Luxembourg Grand Duchy of Luxembourg |
Columbia Threadneedle SICAV
SIF |
44, rue de la Vallée L-2661
Luxembourg Grand Duchy of Luxembourg |
Threadneedle Property Unit
Trust Luxembourg Feeder SA SICAV SI |
44, rue de la Vallée L-2661
Luxembourg Grand Duchy of Luxembourg |
Threadneedle International
Investments GmbH |
Claridenstrasse 41, 8002
Zürich Switzerland |
Threadneedle (Lux) |
44, rue de la Vallée L-2661
Luxembourg Grand Duchy of Luxembourg |
Columbia Threadneedle
Investments (ME) Limited |
Gate Village 5, Level 2,
Dubai International Financial Centre, P.O.Box 482005 Dubai, United
Arab Emirates |
15. Defined Terms
Controller |
The
entity that decides how and why Personal Data is Processed. In many
jurisdictions, the Controller has primary responsibility for
complying with applicable data protection laws. |
Data Protection
Authority |
An independent public
authority that is legally tasked with overseeing compliance with
applicable data protection laws. |
Personal Data |
Information that is about
any individual, or from which any individual is
identifiable1. |
Process or Processed or
Processing |
Anything that is done with
any Personal Data, whether or not by automated means, such as
collection, recording, organisation, structuring, storage,
adaptation or alteration, retrieval, consultation, use, disclosure
by transmission, dissemination or otherwise making available,
alignment or combination, restriction, erasure or destruction. |
Personnel |
Any current, former and
prospective directors, officers, consultants, employees, temporary
staff, individual contractors, interns, secondees and other
personnel. |
Processor |
Any person or entity that
Processes Personal Data on behalf of the Controller (other than
employees of the Controller). |
Special Category Data |
Personal Data about race or
ethnicity, political opinions, religious or philosophical beliefs,
trade union membership, physical or mental health, sexual life, or
any other information that may be deemed to be sensitive under
applicable law. |
Criminal Offences Data |
Personal data about any
actual or alleged criminal offences or penalties. |
1 It should be noted that the concept of personal
data in the data protection laws of Austria and Switzerland
includes information about corporate bodies as well as
individuals.