Privacy Notice

Last updated and effective: November 2023

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, its affiliates listed on Annex 1, and funds sponsored by any Wellington affiliate or subsidiary (“Wellington Affiliates”).

For the purposes of applicable data protection law, Wellington is a data controller in respect of your personal data.

1.  About this Privacy Notice

This Privacy Notice governs and explains the handling and processing of personal data by Wellington while 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 from you directly or collect where permitted by law. In some cases, the collection and processing of certain of your personal data is obligatory and failure to collect that information (including where you fail to supply it) may result in us not being able to provide services or products to you. Information we may collect 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, to the extent permitted by law;
• 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, and  
  • 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 with your consent or where permitted by law:
  • information from publicly available sources (including third party agencies such as credit reference agencies; fraud prevention agencies; law enforcement agencies; public databases, corporate registers and records such as UK Companies House and the UK FCA Register, the EU Central Register of Beneficial Owners, and the Singapore Accounting and Corporate Regulatory Authority; 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 we obtain with your consent or where permitted by law: 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; and
• to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures.

4. Legal Grounds

We may use and/or disclose your personal data in these above described ways for a variety of reasons (subject to requirements under applicable local laws), namely:

• we are performing our contractual obligations with you;
• we have obtained your consent;
• we have legal and regulatory obligations that we have to discharge;
• we are permitted by law to do so;
• to protect your vital interests or those of another person;
• we need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or
• the use and/or disclosure of your personal data as described is necessary for legitimate business interests, 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 amongst the Wellington Affiliates listed in Annex 1 for the purposes described above. We may also share your personal data outside of 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 and to clients, or prospective clients or funds (for example, Wellington’s accountants, professional advisors, IT and communications providers, background screening providers, credit reference agencies, printers). 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 or any commissioner of data protection, auditors or public authorities), or to establish, exercise or defend our legal rights.

6. Sale of personal data

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 or jurisdiction, including all countries of the Wellington Affiliates (see Annex 1), as well as the countries listed in Annex 2. Your personal data also may be processed by individuals operating outside of your country or jurisdiction 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 EEA, Switzerland, the UK and the Dubai International Financial Centre (in respect of which the laws of those jurisdictions apply), such processing is carried out only where allowed by an adequacy decision of the European Commission, Switzerland, the UK Information Commissioner’s Office (“ICO”) and/or the Dubai International Financial Centre (DIFC) and/or Wellington has provided for appropriate safeguards which provide you with enforceable data subject rights and effective legal remedies. This can be done in various ways, for instance:

• the country to which we send the personal information may be approved by the EU Commission, Switzerland,the UK Government or the Dubai International Financial Centre (DIFC) or
• the recipient might have signed up to a contract based on standard contractual clauses, such as “model contractual clauses” approved by the European Commission, Switzerland,the ICO or the Dubai International Financial Centre (as appropriate), obliging them to protect your personal data.

In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA, Switzerland,the UK and/or the Dubai International Financial Centre (DIFC). In all cases, however, we will ensure that any transfer of your personal data is compliant with applicable data protection laws.

You can obtain more details of the protection given to your personal data when it is transferred outside the UK, Switzerland,EEA and/or the Dubai International Financial Centre (including a sample copy of the standard contractual clauses) by contacting us in accordance with the relevant contact details provided in the link below under Section 12 “Questions and contacting us”.

For transfer of personal data outside of the original location of collection for any other country or jurisdiction, it will be protected and transferred in a manner consistent with the applicable legal requirements. You can obtain more details of the protection given to your personal data by contacting us in the manner described in the section entitled “Questions and contacting us”.

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 laws. We limit access to personal data to authorized employees, representatives and service providers who require access for the purposes described in this Privacy Notice. Unauthorized use or disclosure of personal data or 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 aimed at protecting personal data and confidential information.

9. Retention of personal data

We hold Personal Data on our systems (or those of our service providers) 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; and
• 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 may include:

• the right to access your personal data currently in our possession or which may have been used or disclosed by us within the last 12 months;
• 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 set out in relevant local legislation, such as 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;
• the right to request that we restrict, our processing of your personal data;
• the right to object to the processing of your personal data by us;
• the right to request for us to preserve a copy of your personal data currently in our possession;
• the right to port and/or get your data ported by us to another data controller;
• the right to object to any decision being taken solely by automated means, which produces legal consequences concerning you or other seriously impactful consequences;
• the right to be informed of a data breach, to the extent such a data breach is notifiable under applicable law;
• the right to lodge a complaint with the data protection supervisory authority competent at the place of your residence (details of which are provided below), 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; and
• the right not to be discriminated against when you exercise your rights.

You can exercise your rights by contacting us in the manner described in the section 12 entitled “Questions and Contacting Us”. The appropriate way to contact us, as well as the rights that may be applicable to you will, to some extent, be determined by the country that you are resident in.

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 [allaboutdnt.com]. You can visit https://www.wellington.com/en/cookies-tracking-notice/ to view Wellington’s cookies and tracking notice.

12.  Questions and contacting us 

If you wish to exercise any of your rights, wish to raise a complaint on how we have handled your personal data, our data security measures or to raise a subject access request, please do so by email to 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.

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. We will process your request within the time provided by applicable law. 

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.

12.1 Australian residents

If the personal data you provide to us is incomplete or inaccurate, we may be unable to provide you with the services you are seeking or take action on your behalf.

You may access the personal data we hold about you, upon making a written request.  We will respond to your request within a reasonable period. We may charge you a reasonable fee for processing your request (but not for making the request for access). We may decline a request for access to personal data in circumstances prescribed by the Privacy Act 1988 (Cth) (Privacy Act), and if we do, we will give you a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons), including details of the mechanisms available to you to make a complaint.

If, upon receiving access to your personal data or at any other time, you believe the personal data we hold about you is inaccurate, incomplete or out of date, please notify us immediately. We will take reasonable steps to correct the data so that it is accurate, complete and up to date. If we refuse to correct your personal data, we will give you a written notice that sets out our reasons for our refusal (unless it would be unreasonable to provide those reasons), including details of the mechanisms available to you to make a complaint.

If you wish to make a complaint about a breach of the Privacy Act, the Australian Privacy Principles (APPs) or a privacy code that applies to us, please contact us using the details below and we will take reasonable steps to investigate the complaint and respond to you.

If after this process you are not satisfied with our response, you can submit a complaint to the Office of the Information Commissioner. To lodge a complaint, visit the ‘Complaints’ section of the Information Commissioner’s website, located at http://www.oaic.gov.au/privacy/privacy-complaints, to obtain the relevant complaint forms, or contact the Information Commissioner’s office.

If you have any queries or concerns about our privacy notice or the way we handle your personal data, please contact our Privacy Officer at: 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.

For more information about privacy in general, you can visit the Office of the Information Commissioner’s website at www.oaic.gov.au.

12.2 California residents

For purposes of compliance with California law, this Privacy Notice is also a Notice at Collection. California residents may also call us at +1-617-951-5000 during normal business hours Eastern Standard Time and request to speak with our Privacy Officer. 

12.3 Canadian residents

If you are a resident of Canada, Wellington Management Canada ULC controls the personal data collected in accordance with this Privacy Notice. Personal data is maintained on Wellington’s servers or those of its service providers and is accessible by its authorized employees, representatives, and service providers as necessary for the purposes described in this Privacy Notice. Wellington collects personal data with consent except as otherwise permitted or required by law. 

If you wish to exercise any of your rights or have any questions in relation to how your personal data is processed by Wellington Management Canada ULC, please contact our Privacy Officer via email at PrivacyInquiries@wellington.com

12.4  Dubai residents

If you are a resident based in the Emirate of Dubai (including within the DIFC), Wellington Management (DIFC) Limited controls the personal data collected in accordance with this Privacy Notice.

If you wish to exercise any of your rights or have any questions in relation to how your personal data is processed by Wellington Management (DIFC) Limited, please contact our Privacy Officer via email at PrivacyInquiries@wellington.com,  If you are unhappy with the response you receive from us you may contact the DIFC Commissioner of Data Protection. For more information, please search their website at difc.ae/data-protection

12.5  EU/EEA, Swiss and UK residents (as applicable) 

• If you wish to raise a concern about Wellington’s handling of your personal data you should first contact Wellington’s Global Privacy Office  via the email address PrivacyInquiries@wellington.com, with the phrase “Data Subject Rights” in the subject line. This would assist us in attending to your matter speedily by passing it on to the relevant staff in our organisation to handle. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. We reserve the right, or may, charge a reasonable fee for the processing of any data access request. If you are unhappy with the response you receive from us, you can contact the competent supervisory authority for any processing of personal data:
• if you are located in the UK, you can contact the Information Commissioner’s Office at www.ico.org.uk or contact their helpline on 0303 123 1113;
• if you are located in the EEA, the relevant supervisory authority, the name and contact details for which can be found at https://edpb.europa.eu/about-edpb/about-edpb/members_en#member-gr. 
• if you are located in Switzerland, you can contact the Office of the Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, CH-3003 Berne, +41 58 462 43 95, info@edoeb.admin.ch.

12.6 Japanese residents

For those whose personal data is collected and handled by Wellington Management Japan Pte. Ltd., if you wish to exercise any of your rights as a Principal under Act on the Protection of Personal Information of Japan or have any questions in relation to how your personal data is processed by Wellington Management Japan Pte. Ltd., please email: #TokyoCompliance@wellington.com

Please note that Wellington Management Japan Pte. Ltd. discloses “Declaration of Personal Information Protection” in Japanese at https://www.wellington.com/jp-jp/professional/policies/privacy-policy.

12.7 Singapore residents

To the extent permitted by law, if you wish to exercise any of your rights or any questions in relation to how your personal data is processed by Wellington Management Singapore Pte. Ltd., please email:

Ammin Ali: AlAli@wellington.com, copying PrivacyInquiries@wellington.com, with the phrase “Data Subject Rights” in the subject line. This would assist us in attending to your matter speedily by passing it on to the relevant staff in our organisation to handle. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. We reserve the right, or may, charge a reasonable fee for the processing of any data access request.

We will strive to deal with any issue you may raise speedily and fairly.

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.  

ANNEX 1