A Fund managed by Swiss Life Asset Managers UK Limited
A Fund managed by Swiss Life Asset Managers UK Limited
A Fund managed by Swiss Life Asset Managers UK Limited
This policy is issued by Swiss Life Asset Managers UK Limited ("Swiss Life Asset Managers UK"), a company incorporated in England and Wales under number 04846209, authorised and regulated by the Financial Conduct Authority ("FCA") with FRN 229228 and its registered office is at 55 Wells Street, London, W1T 3PT.
This policy summarises how Swiss Life Asset Managers UK use, share and store the data collected from you when you visit Swiss Life Asset Managers UK website or associated fund website, when you become an investor in a fund managed by Swiss Life Asset Managers UK, when you become a tenant in a property owned by one of our funds or when you apply for a job with Swiss Life Asset Managers UK. This privacy policy applies to Swiss Life Asset Managers UK site and all products and services offered by Swiss Life Asset Managers UK and by entering our site you are agreeing to the policies described herein.
Swiss Life Asset Managers UK is committed to safeguarding the personal information which you may provide to us and to the extent that Swiss Life Asset Managers UK collects any personal information, Swiss Life Asset Managers UK will hold it in confidence in accordance with the Data Protection Act 1998 and the General Data Protection Regulation (GDPR) (EU) 2016/679 which came into force on 25 May 2018.
Information you share with us
You may be asked to voluntarily provide certain personal information details about you such as your name, address, telephone number, email address and other information in connection with Swiss Life Asset Managers UK customer or tenant registration procedures and job application process. Swiss Life Asset Managers UK will use this information for the administration and servicing of your investments, performing its obligations under lease contracts, evaluating job applications and other related activities and to ensure compliance with its obligations under the UK regulatory regime. Swiss Life Asset Managers UK may disclose the information to its agents and service providers.
Please note that by submitting personal information you are consenting to such information being processed for the purposes referred to above. You agree that Swiss Life Asset Managers UK has the right to use and store such data on its internal systems and to transfer it to its associated companies and third- party agents and service providers where applicable, whether inside or outside the European Union to countries having an adequate level of data protection.
Information we collect from you
The Swiss Life Asset Managers UK site collects both behavioural data (information about how you use our site); and technical data (information about the device you use to access our site). Swiss Life Asset Managers UK uses the Google Analytics service provided by Google Inc. (“Google”) to collect this data.
Examples of behavioural data collected:
Examples of technical data collected:
The site does not collect any data that makes you personally identifiable. The information obtained via Google Analytics is anonymised and cannot be attributed to any one individual. Google Analytics is set to retain data for a duration of 38 months.
Google provides a method to opt out of their Google Analytics service completely. Opting out will prevent Google Analytics from collecting your data from any site that uses their service.
Why we collect this information
This information provides us with a better understanding of how our site is being used. This understanding informs any improvements we undertake and ensures that the site and its content continue to best serve the needs of our visitors.
How we keep data safe
Swiss Life Asset Managers UK adheres to the following practices to help keep the data that we process safe:
Cookies
We use cookies and similar technologies to offer you a better browsing experience, analyse site traffic and personalise content. Continuing to use our site will imply that you consent to our use of cookies. Please refer to our cookie policy for further information.
Provision of Information to Third Parties
A Data Processor is a third party with which we are required to share personal detail in the provision of investment and property management services. Swiss Life Asset Managers UK will only share personal information in the following circumstances:
Swiss Life Asset Managers UK does not collect or compile personal data or information obtained through the Website for dissemination or sale to outside parties.
We may share your personal information with third party organisations:
We require all third parties with whom we share your personal information to respect the security of your data and to treat it in accordance with the law. We do not allow such third parties to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Your Rights and Your Personal Data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
How long we keep your Data
We are required under the Markets in Financial Instruments Directive II (MIFID II) rules to retain all client related information for up to 7 years, after which time it will be destroyed. Personal information that we use for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information. After you stop being a client, we may keep your data for up to 7 years for one of these reasons:
CVs in respect of unsuccessful applicants are deleted promptly following completion of the job application process.
Marketing
We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’.
The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.
We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you. You can ask us to stop sending you marketing messages by contacting us at any time. If at any point you believe the information we process on you is incorrect you can request to see this information and have it corrected or deleted. If you wish to raise a complaint on how we have handled your personal data, you can contact us on the details below to have the matter investigated.
Hotjar
We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link.
You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.
Privacy policy changes
We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. For clarity, we shall include the date of the most recent revision at the bottom of the page. The amended privacy policy shall be effective as from that date. We therefore recommend that you refer back to this periodically.
Your rights
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.
Data controller
For the purpose of the Data Protection Act (1998) and the General Data Protection Regulations (GDPR) (EU) 2016/679 the Data Controller Swiss Life Asset Managers UK Limited.
Contact us
Swiss Life Asset Managers UK is not required to appoint a Data Protection Officer. For more information about our privacy policies or if you have any questions, we welcome your comments. Please contact Graham Langlay-Smith on graham.langlay-smith@swisslife-am.com, by telephone 020 7495 1929 or by mail:
Swiss Life Asset Managers UK Limited
55 Wells Street,
London,
W1T 3PT