Privacy Notice

PRIVACY POLICY

If you are located in the EU (or are a client or prospect of a Wellington affiliate located in the EU), please click here for additional information provided pursuant to the EU General Data Protection Regulation.

Wellington Management (“we” or “our” or “us”) takes its responsibilities under Hong Kong’s Personal Data (Privacy) Ordinance (the “PDPO”) seriously. We respect the privacy of our clients and the confidentiality of information pertaining to our clients. We also recognise the importance of the personal data that you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. Please read this policy to understand what personal data is collected or process by us, and for what purposes it is usedfor our Website located at 17/F Two International Finance Centre, 8 Finance Street, Central, Hong Kong. (“Website”).

By providing your personal data to us, you acknowledge and agree that you have fully read and understood this policy, and are consenting to the collection, use and disclosure of your personal data as described in this policy.

Information we collect

The PDPO defines “personal data” to mean data relating directly or indirectly to a living individual from which it is practicable for the individual to be directly or indirectly identified. It must also be in a form in which “access to” or “processing of” the data is practicable.

We may collect personal data about you when you use our Website(s), such as your name and email on RFPs, questionnaires, and other forms we receive from you, as well as from personal contacts such as correspondence, e-mail, telephone calls, or meetings. We may also receive personal data about you from third parties, such as your accountants, lawyers, financial consultants, and/or other service providers.  Failure to provide personal data may result in Wellington Management being unable to provide you with the services or information requested.

It also is possible to receive information from web browsers and apps regarding certain of your online activities using cookies, or other common tracking technologies.When you visit this Website, a Wellington Management group company server will record your IP address together with the date, time, page visited and duration of your visit. Please note that the Wellington Management group uses cookies on this section of the Website. A cookie is a small piece of information sent by a web server to store on a Web browser so it can later be read back from that browser. Cookies are small pieces of software that are issued to your computer or device and that store and sometimes track information about your use of the site. The Wellington Management group also uses cookies to collect general usage and volume statistical information that does not include personally identifiable information. Some cookies may remain on the user’s computer after they leave this Website (these are known as persistent cookies). For more information about cookies including how to set your internet browser to reject cookies, please go to www.allaboutcookies.org.

By using this Website, you agree that the Wellington Management group can place cookies on your device which collect the data and for the purposes described above If you delete cookies relating to this Website, we will not remember things about you, you will be treated as a first-time visitor the next time you visit this Website and we will not be able to tailor your experience of this Website.

The Wellington Management group has engaged one or more third party service providers to track and analyze usage and volume statistical information from visitors to this Website. The service provider(s) set cookies on behalf of the Wellington Management group.  The Wellington Management group may re-associate the information provided by the technologies directly above with other personal information we hold about you.  By using this Website, you agree that third parties can place cookies on your device as described above.

If you would prefer not to accept cookies from us, you may set your browser accordingly. If you choose to disable cookies in your browser, you may not be able to access all pages on our Website.

Information sharing

Wellington Management seeks to provide seamless services to all clients. To facilitate that process, and to comply with any laws, government or regulatory requirements applicable to Wellington Management and its group, personal data regarding client accounts may be shared broadly between affiliates within the Wellington Management group of companies. For example, an affiliate may share information with other affiliates in order to facilitate portfolio management or provide client liaison services to a particular client or in order to identify potential client needs for additional investment management services. By disclosing your personal data to us via our Website, you consent to our disclosing your personal data to our affiliates and the Wellington Management group of companies.

Wellington Management generally does not share personal data with unaffiliated third parties for marketing purposes, except as necessary to perform the investment management services it has been hired to provide. For example, Wellington Management may share non-public client information with brokers and custodian banks in order to buy and sell securities and record those purchases and sales accurately. As a general rule, Wellington Management does not engage in joint marketing arrangements with unaffiliated third parties that involve the sharing of non-public information regarding Wellington Management’s clients. Wellington Management does not provide client information to unaffiliated third parties for their own marketing purposes.

Wellington Management does not disclose your personal data except as required or permitted by law. In the event that Wellington Management is involved in a merger, acquisition, reorganization or sale of assets, or bankruptcy, your information may be transferred or sold as part of that transaction.

We may collect, use, disclose or process your personal data for other purposes that do not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless the processing of your personal data without your consent is permitted by the PDPO or by law.

You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by contacting Wellington Management at #hkcompliance@wellington.com. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal, including us being unable to provide any services to you. Do note that your withdrawal of consent will not affect our ability to collect, use or disclose your personal data for a specific purpose without your consent, if the PDPO or a provision in applicable law permits us to.

Security policies

The Wellington Management group uses technical, administrative, and procedural measures in an attempt to safeguard your personal and other information from unauthorized access or use. No such measure is ever wholly effective though, so we do not guarantee that your personal and other information will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures the Wellington Management group uses to safeguard such information. Users are responsible for maintaining the secrecy of their own passwords. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us by contacting your relationship team member.

Data access and correction

For Hong Kong residents – your rights under PDPO: Under and in accordance with the terms of the PDPO, any individual:

(i) may check whether Wellington Management holds personal data about him/her and may request access to such information;

(ii) may request Wellington Management to correct any personal data relating to him/her which is inaccurate;

(iii) may request Wellington Management to specify its policies and practices in relation to personal data and to be informed of the kind of personal data held by Wellington Management; and

(iv) may object to the use of his/her personal data for marketing purposes; Wellington Management will not use his/her personal data for these purposes if he/she communicates his/her objection to Wellington Management.

If you would like to have a copy of your personal data being held by us, or to update and/or correct the personal data which you have previously provided to us, please write to Wellington Management at 17F, Two International Finance Centre, 8 Finance Street Central, Hong Kong.

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.

Retention period

Your personal data will be retained by us for a period of 2 years after you last accessed our Website, or we have last corresponded with you and your personal data will be erased after such retention period.

Security

Wellington Management endeavours to prevent unauthorised disclosures of your personal information 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 information was passed to them with your authority.

Changes to this Privacy Policy

Wellington Management reserves the right to change, modify, add, or remove portions of this policy at any time for any reason. We suggest that you review this policy periodically for changes. The current version of this policy can be accessed from the link on our homepage, at the bottom of our Website pages. We will post a message on our Website home page whenever an amendment is made to this policy so that you will know when to check. You acknowledge that by accessing our Website after we have posted changes to this Privacy Policy, you are agreeing to the terms of the policy as modified.

With respect to any expansion of the purposes of using your personal data received by us from the purposes as stated in this policy, prior notice will be given to you and you have the right to decline acceptance of such expansion however in such circumstances our provision of continuing services to you may be limited.

Complaints

If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPO, we welcome you to contact us with your complaint or grievance by writing to Wellington Management at 17F, Two International Finance Centre, 8 Finance Street Central, Hong Kong.

Where you are sending an email in which you are submitting a complaint, your indication at the subject header that it is a PDPO complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “PDPO Complaint”.

We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.

Transfer of data to other countries

Wellington Management is a global business and as a result we or our third party processors collect and transfer personal data globally and may transfer your personal data to locations outside of your country. Your personal data may also be processed by individuals operating outside your country who work for Wellington Management or for one of our vendors.   Where Wellington Management transfers your personal data to another country, it is required to do so in a manner consistent with legal requirements.