Introduction and definitions
“personal data” means personal data as defined under the Law and includes any information about an identified or identifiable natural person. Such information may include, for example, information we collect against an identifier for you (for example, your IP address or cookie ID). We also refer to personal data as “data about yourself”, “personal information”, “your information”, “personal details” and “information about you”;
“controller” means controller as defined in applicable data protection legislation;
“Invesco”, “our”, “us” and “we” means Invesco Investment Management Limited; and
“the Law” means applicable data protection legislation, including (where applicable) the General Data Protection Regulation (“GDPR”).
What is the purpose of this Online Privacy Notice and Cookies Policy?
Who are we?
We are the controllers of your personal data and, as controllers, determine why and how we collect and use your personal data. We are committed to protecting your privacy and personal data as you use our website and web services. We take seriously our responsibility to hold your personal data securely and confidentially.
What kind of personal data do we collect about you and how? Depending on your interaction with our website, we collect the following categories of personal data from you:
Do we collect personal data about you from third parties?
We may also collect your personal data from third parties, for example (i) from publicly accessible sources, including publicly available online profiles and databases e.g. to establish and verify your identity, to find out your contact details or to liaise with you in relation to our products and services, or (ii) by using third party cookies. Please find more information about how we use third party cookies in our Cookies Policy.
How do we protect your personal data?
We maintain strict security standards and procedures with a view to preventing unauthorised access to your personal data by anyone, including our staff. We use leading technologies such as (but not limited to) data encryption, firewalls and server authentication to protect the security of your personal data. The staff of Invesco follow strict privacy standards and whenever we hire third parties to provide support services, we require them to observe the same standards and to allow us to audit them for compliance.
How will we use your personal data we collect online?
This section of this Online Privacy Notice and Cookies Policy explains for what purposes we use your personal data we collect online and on which legal bases we rely. Our legal bases for collecting and using your personal data will include
For how long do we keep your personal data?
We only keep your personal data for as long as is necessary to fulfil the purposes for which it has been collected. When determining the appropriate retention period, we consider the risks of the processing, our contractual, legal and regulatory obligations, internal data retention policies and our legitimate business interests as described in this Online Privacy Notice and Cookies Policy.
Who do we share your personal data with?
Where we send direct marketing materials to you, we may send your personal data to third parties with whom we have contracted to provide these materials to you on our behalf and in our name. These third parties act as our processors in relation to their processing of your personal data in this way.
In certain circumstances, we may also share your personal data we collect online, for the purposes set out in this Online Privacy Notice and Cookies Policy, with other third parties such as:
We also may disclose your personal data to courts, the police, or other law enforcement agencies where we are legally obliged to do so or in our reasonable opinion such disclosure is necessary to comply with applicable laws and legal processes, support an investigation or to protect our rights and interests in relation to any suspected misuse by you of our website or any of our website services.
We endeavour to prevent unauthorised disclosures of your personal data by other people, but we are not responsible for any unauthorised disclosures or other breaches of security or for the actions of others if the personal data was passed to them with your authority or with the authority of anybody other than us or our affiliates.
We may also share your personal data with a potential buyer in connection with any proposed purchase, merger or acquisition of any part of our business.
Where is your personal data transferred?
When we share your personal data with the organisations listed above, it may involve transferring your personal data outside the European Economic Area (EEA) or outside any other country from where you may access our website, to countries where the level of protection of personal data has not been deemed adequate by the European Commission. The absence of an adequacy decision means that the laws of these countries may not guarantee the adequate level protection of your personal data as defined by the Law. However, we will ensure that your personal data is transferred, processed and maintained to the standards required by Law by putting standard data protection clauses in place (as approved by the European Commission) or where we use third parties, we may rely on other appropriate transfer mechanisms they have implemented (e.g. EU-US Privacy Shield, binding corporate rules). Please contact us using the contact details provided below to obtain a copy of our standard data protection clauses or further information about other appropriate transfer mechanisms we may rely on. For example, we transfer your personal data to the United States for analysis purposes by employing the Google Analytics technologies. The personal data transferred to Google is protected under the terms of their EU-US Privacy Shield Certification (for more information see here: https://www.privacyshield.gov/Individuals-in-Europe).
What are your rights in relation to the personal data we hold about you?
Subject to the conditions prescribed in applicable laws, you have the right: (i) to access, rectify or request erasure of your personal data; (ii) to ask us to restrict processing of it; (iii) to request portability of it.
Subject to the conditions prescribed in applicable laws, you have the right (i) to object, on grounds relating to your particular situation, to processing of your personal data which is based on our or a third party’s legitimate interests; and (ii) to object to processing of your personal data for direct marketing purposes.
You can exercise these rights by contacting us using the contact details provided below.
You also have the right to lodge a complaint with a supervisory authority about our use of your personal data in the EU Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes the GDPR.
Can I use the website in an anonymised or pseudonymised manner?
In accordance with applicable data protection legislation, you may choose to use the website in an anonymised or pseudonymized manner. This applies only to the extent that anonymous or pseudonymized use of the website is technically possible and reasonable.
Our Cookies Policy
How will your site recognise who I am?
When you access our site for the first time, choose your audience type or register for our site services, we will place a 'cookie' on your computer. Cookies are small text files placed on your computer and are commonly used on the internet by many websites to store information on their users' computers. Cookies only contain information relating to the website that created them, and can only return the information to that website. In other words, our site cannot read the information contained in cookies created by anyone else's website on your computer. Similarly, only our site can read the information in cookies that it creates. Cookies cannot be used to get or view data from your hard drive.
What purposes are cookies used for?
We use two types of cookies:
Session cookies: These are temporary and are deleted as soon as you close your browser; and
Persistent cookies: These are stored on your computer until they expire or you remove them. Persistent cookies store your personal preferences such as your language preferences on multi-lingual sites to make subsequent visits easier. They also remember questions we have asked you previously, such as a request to complete an online survey.
You can find more information about the individual cookies we use, when they expire and the purposes for which we use them in the table below: