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This Privacy Notice (“Notice”) applies to: Merian Global Investors (UK) Limited (and its branches), Merian Investment Management Limited, Merian Global Investors (Asia Pacific) Limited, Merian Global Investors (Singapore) Pte. Limited, Merian Global Investors (Switzerland) GmbH, Merian Global Investors Series Plc, Merian Global Investors Series III ICAV, MGI Arbea Fund Limited, MGI Arbea Master Fund Limited and Merian Chrysalis Investment Company Limited, each of which shall be a separate data controller for the purposes of the DP Legislation (as applicable) (as defined below). References in this notice to “Merian Global Investors”, “we”, “us” and “our” are to the individual entity which collects your personal data.
We are committed to protecting your privacy and ensuring that your personal data is collected and used appropriately, lawfully and transparently.
This Notice explains:
Who We Are
Merian Global Investors provides cross-border investment solutions, asset management and discretionary management services on a global basis.
Merian Global Investors (UK) Limited is subject to UK law and the Data Protection Act 2018 (“DPA”) as well as EU Regulation 2016/679 (“GDPR”) and the Data Protection (Bailiwick of Guernsey) Law 2017 (the “DP Law” and together with the DP and the GDPR, the “DP Legislation”). In addition, other Merian Global Investors entities are subject to other laws and regulations, including data protection laws in their respective jurisdictions.
Please read this Notice carefully as it describes the types of personal data we may collect from you or that you may provide and the legal basis and practices for Merian Global Investors’ processing of your personal data is set out in this Notice. This Notice forms part of, and should be read in conjunction with, www.merian.com (“Website”) Terms and Conditions of use.
What Personal Data We Collect
Personal data means information by which you may be personally identified directly or indirectly. We collect certain personal data about you when you use our Website, contact us about products and services, complete a fund application form, or register to receive one of our mailings. The type of personal data we collect will depend on the purpose for which it is collected and will include:
We will collect personal data directly from you. We ask for personal data at the start of our relationship (e.g. when you complete a fund application form) and in subsequent communications in order to check your identity. This is a legal requirement in some jurisdictions and is important to help safeguard you and us against potential crime. If you do not provide us with your personal data, it is possible that we may not be able to provide our services or products to you.
We also collect personal data about you from other sources such as external third parties. Where we provide our services or products to trusts, we collect personal data on the beneficiaries and trustees. Where we provide our services to companies we may collect personal data on directors, shareholders and beneficial owners of the company. We will also collect information from third parties in order to verify your identity.
We also collect information from your use of our Website via cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. To learn more about how information is collected through cookies, please visit our Cookies Policy.
We may collect so called ‘sensitive’ or ‘special categories’ of personal data, such as details about your: dietary requirements, health (for example, so that we can make reasonable accommodations for you in our products and services, or where you may visit our offices) and sexual orientation (for example if you provide us with details of your spouse or partner). The types of personal data and special categories of personal data that we collect may vary depending on the nature of the services that we provide to you. In some rare circumstances, we also gather other special categories of personal data about you because you volunteer that data to us or we are required to gather that data as a result of legal requirements imposed on us.
How We Use Your Personal Data (Purpose of Processing) and on What Legal Basis
We are not allowed to process personal. information if we do not have a valid legal ground for doing so. Therefore, we will only process your personal data for the following purposes:
To perform our contract with you and to support and maintain that relationship. This includes the following:
To comply with legal and regulatory requirements. These requirements include the following:
For specific business purposes which are in our legitimate interests without affecting your rights and freedoms. This includes the following:
You have the right to object to us processing your personal data for such business purposes and in certain circumstances we will ask for your consent.
To the extent that we process any sensitive personal data relating to you for any of the purposes outlined above, we will do so because either (i) the processing is necessary to carry out our obligations under employment, social security or social protection law; (ii) the processing is necessary for the establishment, exercise or defence of legal claims; (iii) you have given your explicit consent; or (iv) you have manifestly made the information public.
If provision of your personal information is a legal or contractual requirement or a requirement necessary to enter into a contract with us, and you choose not to provide it, we may not be able to perform some of the tasks we need to in order to provide certain products or services to you.
If you do choose to provide your consent you can withdraw it at any time by contacting us.
Information for marketing purposes
We use your information to identify products, services and events that we think may be of interest to you. We will only send you marketing messages where you have consented to such contact, or in the case of products and services, where these are similar to those that we have already provided to you.
You have the right to ask us not to send you marketing messages by post, telephone or e-mail or any combination of these at any time. You can also let us know at any time that you wish to change your mind and to start receiving such messages. You can do this:
If you choose to unsubscribe, we will cease to send you such communications as mentioned above.
Who We Share Your Personal Data with and Why
We share your personal data with trusted third parties, who perform tasks for us and help us to provide our products and/or services to you, and with other agencies where required by law, court order or regulation. These include:
Where appropriate, before disclosing personal data to a third party, we contractually require the third party to take adequate precautions to protect that data and to comply with applicable law.
We keep your personal data only for as long as is necessary for the purpose for which it was collected, or for legal or regulatory reasons. Personal data will be securely disposed of when it is no longer required, in accordance with our data retention and disposal policies, which can be made available on request.
When determining the relevant retention periods, we will take into account factors including:
How We Keep Your Personal Data Secure
We are committed to ensuring the confidentiality of the personal data that we hold and continue to review our security controls and related processes to ensure that your personal data remains secure.
We operate internationally, and as part of the services we offer you, the personal data you provide to us may be transferred to countries outside the country in which the personal data was first provided, including countries outside of the European Economic Area, such as Hong Kong and SingaporeWhere these countries do not have data protection laws equivalent to ours, we will ensure that third parties receiving the personal data have provided adequate safeguards and agree to treat your personal data with the same level of protection as in the country in which the personal data was first provided. You may request additional information in this respect by exercising your rights as set out below.
When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal data is kept secure and prevented from unauthorised or accidental access, processing, copying, modification, erasure, loss or use.
Under applicable data protection law, you have the right to ask us:
You also have the right to:
If you wish exercise any of these rights, please contact us using the details below. The various rights are not absolute and each is subject to certain exceptions or qualifications.
More information about your data protection rights can be found by contacting the Information Commissioner’s Office or relevant local supervisory authority (see details below).
Changes to our privacy notice
We may modify or amend this privacy notice from time to time.To let you know when we make changes to this privacy notice, we will amend the revision date at the end of this page. The new modified or amended privacy notice will apply from that revision date. Therefore, we encourage you to periodically review this notice to be informed about how we are protecting your information.
Right to complain
If you are unhappy with the way we handled your personal information or any privacy query or request you have raised with us you also have a right to complain to a data protection authority in the place where you live or work, or in the place where you think an issue in relation to your data has arisen. A list of national data protection authorities can be found here. You can also use the addresses below to raise a complaint about how we have handled your personal data.
How to Contact Us
If you have questions about this Notice, need further information about our privacy practices, or wish to give or withdraw your consent to the receipt of marketing information, change your preferences to receive marketing communications or update or correct your personal data, please contact us through your usual Merian Global Investors contact or as set out below.
The Data Privacy Team
Merian Global Investors (UK) Limited
Millennium Bridge House
2 Lambeth Hill
For Merian Global Investors (Singapore) Pte. Limited and Merian Global Investors (Asia Pacific) Limited:
Data Protection Officer
5/F Two Chinachem Central
26 Des Voeux Road Central
If you are not satisfied with our response you can lodge a complaint with the applicable local supervisory authority as set out below:
For Merian Global Investors (UK) Limited and Merian Investment Management Limited
The Information Commissioner’s Office on their helpline 0303 123 1113 or at www.ico.org.uk/concerns/
For Merian Global Investors (UK) Limited, Italian Branch:
Garante per la protezione dei dati personali (Italian Regulatory Authority)
Piazza di Monte Citorio 121
For Merian Global Investors Series Plc, Merian Global Investors Series II ICAV, Merian Global Investors Series III ICAV:
Data Protection Commission
T: +353 (0761)104800/Local 1890 252231 or as otherwise instructed on its website www.dataprotection.ie
For Merian Global Investors (Asia Pacific) Limited:
The Office of the Privacy Commission for Perosnal Data, Hong Kong
12/F, 248 Queen’s Road East
T: +852 2827 2827
F: +852 2877 7026
For Merian Global Investors (Singapore) Pte. Limited:
Personal Data Protection Commission
460 Alexandra Road
#10-02 PSA Building
T: +65 6377 3131
F: +65 6273 7370
For Merian Global Investors (Switzerland) GmbH:
The Swiss Federal Data Protection and Information Commissioner
Last updated: 20 November 2018