This Privacy policy sets out details on how Personal Data (as defined below in Section 1) relating to you will be handled by the Comgest Group¹ (“Comgest” or “we”) as controllers of the Personal Data.

Comgest may collect, hold, use and transfer information which may constitute Personal Data under the EU General Data Protection Regulation (“GDPR”), and the laws of other countries (mainly Hong Kong, Singapore, Japan and United States).

This Privacy policy is disclosed pursuant to the information obligations set out in the GDPR and any local regulations supplementing it. This Privacy policy describes what data we collect about you, how we collect that data, for what purposes we use it, the legal basis for processing, to whom we may disclose the data, how you can exercise your rights, additional terms applicable only to specific jurisdictions and other information necessary to ensure fair and transparent processing of your Personal Data.  This Privacy policy covers both online and offline data collection.

Please note that Comgest has a separate privacy policy applicable to employees and job applicants. Please refer to Comgest’s career page for more information.

KEY INFORMATION SUMMARY

• Comgest Group, as data controller, collects and uses Personal Data that you provide as part of your interaction with us, together with additional Personal Data that we collect when you register as a client and throughout the course of providing services to you.
• The Personal Data we collect is used primarily for performing our obligations under client service contracts, providing you with marketing and communication material and for managing our website. 
• All purposes and legal bases for such processing are detailed in this Privacy policy. You have rights with respect to your Personal Data, which are described in Section 6 of this Privacy policy.  To obtain further information or ask any questions regarding these rights, or if you have any queries regarding Comgest’s processing of your Personal Data, please use the contact details set out in the “Contact” section of this Policy.  

1. PERSONAL DATA WE COLLECT AND FOR WHAT PURPOSES

We undertake to collect and process Personal Data”, i.e., information that either directly identifies you or could be used in combination with other information to identify you, in accordance with the principle of minimization, limiting the collection of Personal Data to that which is strictly necessary for the purposes of processing.

Personal Data that we collect includes:

• Contact information: We collect such Personal Data to communicate with you. We may use the information you provide to send you requested information, respond to your inquiry, verify your relationship with Comgest and take other actions as necessary to respond to your request. Information includes your first and last names, gender (Ms./Mr.), mailing address, telephone number, email address, job title, and other information you provide to us online and/or offline.
• Preferences & Interests: This information helps us understand your interest in our services and particular investment products described on our website.  It may include contact and investment product preferences, languages, and marketing preferences.
• Transaction & Service history: Such Personal Data is necessary to provide the services you have requested and validate any instructions authorized.  This includes service requests and instructions, transactions completed and correspondence records, as well as potential complaints.
• Security: We use this information to secure our website, network systems and other IT assets.  This may include any information we use to verify your identity, information concerning your IP address, geographic location, resources you have accessed and ancillary data (e.g., login credentials, usernames and passwords).
• Cookies: We use cookies and other tracking technologies on our website and in the presentations, we may send you by email.  Please refer to Section 9 below for more details and to our Cookie Policy available on the Comgest website (www.comgest.com).
• Compliance and investigations: WWe process Personal Data to respond to all Comgest legal, regulatory or tax obligations.  In particular, as part of KYC (Know Your Customer) and AML (Anti-Money Laundering including the fight against terrorism financing and the application of financial sanctions) mandatory processing, Comgest may implement controls prior to initiating any business relationship and throughout such relationship, and assist regulatory authorities on surveillance, detection and verification of transactions.  This may also include, to the extent permitted by law recordings of any correspondence and communications between us (including incoming and outgoing phone calls, e-mails, instant messaging, social networks and any other types of communications).

If you do not provide us with such information, we may not be able to perform our contract with you.  Where you do not provide us with the necessary data, we will inform you what the effect will be on our relationship.

2. WHAT ARE COMGEST’S LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA?

To process your Personal Data lawfully, we will be relying on one of the following legal bases:

• Performance of a Contract: Comgest must process your Personal Data in order to enter into and perform its contract with you or in order to take steps at your request prior to entering into a contract; 
• Processing is necessary for us to comply with our relevant legal and regulatory obligations: For example, processing may occur when we are creating a customer record, managing IT security, disclosing required data to a government, judiciary or regulatory authority, responding to data subjects’ request to exercise their rights under GDPR, complying with AML or fulfilling similar regulatory obligations;
• Processing is necessary to exercise or preserve our legitimate business interests and our interests are not overridden by your interests, fundamental rights or freedoms: For example, processing may occur when we are assessing new investment or business opportunities, managing legal matters etc.; or
• Processing is based on your prior consent: In such case, we will request your consent for a specific use of your personal data (for example, in order to provide you with marketing and communications material or prior to setting a specific category of cookies (see Section “Cookies and other trackers”)).

3. SOURCES OF PERSONAL DATA

Your Personal Data is primarily provided to us directly by you (for example, through the contact form on our website, through emails you send or through verbal information). From time to time, we may receive Personal Data about you from third party sources, for example other clients and business partners or other publicly available registers and databases.

In some circumstances, your Personal Data may be collected indirectly for example, via telephone logs and recordings and email and Internet access logs, if and to the extent permitted by applicable laws.

4. THIRD PARTY RECIPIENTS OF YOUR PERSONAL DATA

We may disclose your Personal Data, where permitted by applicable law and on a need-to-know basis, to entities within the Comgest Group, our relevant service providers and/or other third parties including:

• Entities within the Comgest Group (Client Relationship Management administrator, teams in charge of Investor Relations, Marketing and Reporting, System administrators, Compliance, Legal, Information Technology and Audit teams);
• To companies that assist us in marketing or client servicing;
• To third parties, providing us with IT services, such as hosting, supporting and maintaining our systems or website;
• To governmental or regulatory authorities, tax administrations or courts so as to comply with our legal obligations and/or as part of regulatory audits or inspections, amicable settlements, or pending or forthcoming judicial proceedings,
• Comgest’s insurers, IT administrators, lawyers, auditors, consultants and other professional advisors;
• To companies that help us maintain, process or service your transactions or account(s), including companies that perform administrative, accounting, transfer agency, custodial or brokerage services for us.

Where these third parties act as a data processor they carry out their tasks on our behalf and upon our instructions for the abovementioned purposes.

5. WILL COMGEST TRANSFER YOUR PERSONAL DATA OUTSIDE OF THE EU/EEA?

We may share your data within the Comgest Group based on the Comgest Intra-group data transfer agreement or with vendors, as indicated above, where necessary to provide you with our services, some of which are located outside the EU/EEA  Should your data be transferred outside the EU/EEA in countries which do not offer the same level of protection for your Personal Data then we will take measures to ensure that your Personal Data receives the same level of protection as if it remained within the EU/EEA.  Such measures may include (without limitation) transferring the Personal Data to a recipient (a) in a country that the European Commission has decided provides adequate protection for Personal Data, (b) that has implemented binding corporates rules in accordance with applicable data protection law, or (c) that has executed standard contractual clauses adopted by the European Commission.

We will ensure that your Personal Data is treated securely and in accordance with this Privacy policy and any applicable privacy rules.
Transfers of Personal Data in accordance with this Section 5 are based on the same legal grounds as applicable for the respective purposes of processing as set forth in Sections 1 and 2 above.

For transfers outside of the EU/EEA, you have a right to obtain further information on how to obtain a copy of such data and details of the mechanism under which your Personal Data is transferred outside of the EU/EEA. Please use the contact details set out in the “Contact” section of this Policy.

6. WHAT ARE YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA?

You have a number of rights in relation to your Personal Data, which are set out below.

• The right to request access to Personal Data that Comgest maintains about you, as well as the right to request rectification of any Personal Data that is inaccurate, incorrect or incomplete;
• The right to erasure of your Personal Data to the extent permitted by law 
• The right to restrict our processing of your Personal Data (that is, allow only its storage) under specific circumstances; where your Personal Data is subject to restriction, we will only process it with your consent or for the establishment, exercise or defense of legal claims or for regulatory purposes;
• In the event your Personal Data is processed on the basis of your consent, you have the right to withdraw consent at any time.  You can withdraw your consent, inter alia, by clicking the ‘Manage my Subscriptions/Unsubscribe’ link in any communication you receive or by disabling cookies (as described in the Cookie Policy), without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to object to processing:
  • When the processing is made for direct marketing purposes, you have a right to object to that processing at any time. If you object, Personal Data must no longer be processed for such purposes.
  • When the processing is based on legitimate interest grounds, you also have the right to object to that processing at any time.  If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the Personal Data for the establishment, exercise or defense of legal claims.

For Personal Data collected in the EU/EEA/UK and/or collected by Comgest European entities:

• You have the right to receive all such Personal Data which you have provided to Comgest in a structured, commonly used and machine-readable format, and also to require us to transmit it to a third party where this is technically feasible and under specific circumstances;
• You also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your Personal Data infringes applicable law.  For instance, the French supervisory authority may be contacted at https://www.cnil.fr/fr/agir or by regular mail at CNIL – 3 Place de Fontenoy – TSA 80715 – 75334 Paris – Cedex 07.  A list of the other European data protection supervisory authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080
• For French residents, you also have the right to give general or specific instructions on how your Personal Data may be retained, deleted or communicated after your death;

To exercise any of these rights, please use the contact details set out in the “Contact” section of this Policy.

7. HOW SECURE IS THE PERSONAL DATA YOU PROVIDE?

We implement physical, technical and administrative security standards designed to protect your Personal Data from loss, misuse, alteration, unauthorized access, destruction or damage.

We take steps to limit access to your Personal Data to those individuals who need to have access to it for one of the purposes listed in Section 1.

However, no Internet transmission is ever fully secure or error free.  In particular, Personal Data sent using email or our website (e.g., via the contact form) may not be secure.  You should take special care before deciding to send us information via email or our website.

8. FOR HOW LONG DOES COMGEST RETAIN YOUR PERSONAL DATA?

We retain your Personal Data for no longer than is necessary for the purposes for which the Personal Data are processed, which will in many cases be for the period during which we have a business relationship with you.

We may retain your Personal Data for longer periods of time corresponding to:

• regulatory requirements,
• a statute of limitation, 
• to establish, exercise or defend legal claims, or 
• as otherwise permitted or required by law.

This is done to ensure that we have an accurate record of your dealings with us in the event of any complaints or claims, or where we are required to do so in accordance with legal, tax and/or accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request.

If you would like to know in detail how long we hold specific Personal Data for, use the contact details set out in the “Contact” section of this Policy.

 

9. COOKIES AND OTHER TRACKERS

 

9.1 COMGEST WEBSITES

 

If you use Comgest’s website www.comgest.com we may collect technical information through the use of cookies. The type of information collected varies by category. There are three main categories:

• Strictly necessary cookies:  These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but then some parts of the site will not work. These cookies do not store any personally identifiable information.
• Performance cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.
• Functional cookies:  These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages (e.g. videos). If you do not allow these cookies then some or all of these services may not function properly.

Please refer to the Cookie Policy on our website for further information on the cookies we use.

Also, as detailed in the Cookie Policy, we provide you with the opportunity to selectively accept or refuse certain categories of cookies in your web browser through our Cookie Manager application.

If you accept cookies of the performance category, we will be able to combine the information we collect about your usage of our website during that session with other information we know about you, such as any searches you conduct on our website or information you request during your web session. We will use this combined information to assess the appeal and usefulness of the information and tools offered on our websites as well as to identify Comgest products and services that may be of interest to you.

We also gather anonymous information related to browsing habits of users with the purpose of managing and improving our website.

If you use a Comgest website and follow a link from it to another website, different privacy policies may apply. Prior to submitting any Personal Data to a website, you should read the privacy policy applicable to that website.

 

9.2 PRESENTATIONS SENT TO YOU BY EMAIL (SEISMIC)

To help us improve our services, when sending you presentations by email we use the "LiveSend" software solution from Seismic Software, Inc. (Seismic Software, Inc, 12390 El Camino Real, San Diego, CA 92130, USA). 

LiveSend uses a tracking procedure in which cookies are set. 

The legal basis for this is the consent of the user pursuant to Article 6(1) of GDPR. The cookies are only set after consent has been given. LiveSend provides us with information about which content the user has viewed, when and for how long. The purpose is to present our content in the best possible way and to analyze user behavior so that we can continuously improve our products and services and provide users with targeted information. 

Recipients of the data are employees from Comgest’s marketing, sales and IT departments as well as IT service providers used. 

You can also read a presentation without giving consent to the LiveSend function. Accordingly, no usage behavior will then be tracked, and you can still read a presentation to its full functional extent. 

You can also withdraw your consent to the use of the cookies at any time by clicking My Privacy Settings in the LiveSend link.

We have concluded a processing agreement together with standard contractual clauses with the company Seismic Software Inc. Please note that Seismic Software, Inc. is also part of the EU US Data Privacy Framework Program. You can find more information about the company Seismic Software, Inc. as well as the privacy policy of that data processor at: https://seismic.com/privacy-policy/

 

 

10. ADDITIONAL TERMS

THE BELOW LOCAL PRIVACY STATMENTS ARE IN ADDITION TO THE PRIVACY POLICY and shall prevail in the event of any inconsistency between such Privacy Statements and this Privacy policy.

10.1 Japan

Please find the full privacy policy applicable to data collected by Comgest Asset Management Japan Ltd at the following link: https://www.comgest.co.jp/privacypolicy/.

Please note that Comgest Asset Management Japan Ltd has a separate privacy policy for employees and job applicants. Please find the full privacy policy for employees and job applicants at the following link: https://www.comgest.co.jp/privacy/.

10.2 USA

As registered entities with the Securities and Exchange Commission, Comgest US LLC and Comgest Asset Management International Limited maintain this Privacy policy in compliance with Regulation S-P.

11.CONTACT

The Chief Information Security Officer is responsible for all personal data matters at Comgest. If you wish to exercise your rights or have questions regarding this Policy, please contact:

The Chief Information Security Officer
Comgest - 17 Square Edouard VII, 75009 Paris – France

Or send an email to dataprivacy@comgest.com

 

 

¹Comgest Global Investors, S.A.S. is the holding company for the Comgest Group which includes six asset management companies: Comgest, S.A. (Paris), Comgest Far East Ltd (Hong Kong), Comgest Asset Management International Ltd (CAMIL)(Dublin), Comgest Asset Management Japan Ltd (Tokyo), Comgest Singapore Pte Ltd (Singapore) and Comgest US LLC (Boston). Comgest also has the following service locations: Comgest Deutschland GmbH (Düsseldorf), Comgest Benelux B.V. (Amsterdam), Comgest Australia Pty Ltd (Sydney), as well as offices of CAMIL in London, Milan, Brussels and Vienna.

Last update: November 2024
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