United StatesWho We Are
This privacy notice is issued by Impax Asset Management Group plc on behalf of itself and its subsidiaries, as identified below (and together, “Impax” or “we”), which act as the data controllers and is addressed to individuals outside our organization who we interact with, including clients, investors, visitors to our websites and vendors.
Impax gather and process your personal data in accordance with this privacy notice and in compliance with relevant data protection requirements. This notice provides you with the necessary information regarding your rights and obligations, and explains how, why and when we collect and process your personal data.
Information That We Collect
We collect personal data from a variety of sources:
- Provided directly by you;
- Collected in the course of providing you with investment management services;
- Provided by third parties such as clients, registrars, employers or where you purchase our products or services through such third party;
- Third party public or private compliance databases;
- We may also create personal data about you, such as records of your interactions with Impax;
- Collected when you visit our website.
The personal data that we collect about you may include:
- Name;
- Personal identification documentation and related information including date of birth, home address, personal identification numbers and nationality;
- Contact information including telephone numbers and email addresses;
- Where requested, proof of address, address history and employment details;
- Financial details including bank account numbers, transaction details;
- Electronic data including internet protocol (IP) address, cookies, logs, online identifiers; and
- Any other personal information that you provide to us or that we obtain through your interactions with us including your feedback on our services.
We may also process special category data (e.g. racial or ethnic origin, political opinions, religious or philosophical belief, trade union membership, genetic or biometric data, health, sex life or sexual orientation) to the extent required or permitted by applicable law including:
- Whether you have committed criminal acts;
- Whether you may be a politically exposed person (PEP).
How We Use Your Personal Data And Legal Bases For Using Your Personal Data
Our processing of your personal data is necessary: (i) for the performance of contracts which you will be a party and in order to take steps at your request prior to you entering into those contracts; (ii) for the purposes of legitimate interests pursued by us; and (iii) for compliance with our legal obligations. We have set out more detail below in relation to the legal bases on which we rely for the specific processing we conduct:
| Processing activity | Legal basis for processing |
|---|---|
| Entering into, and providing services associated with investment management and contacting you regarding said services | Processing is necessary in connection with: (a) any contract that you may enter into with us, or the steps taken prior to entering into a contract with us; and (b) our legitimate interest in providing you with services. |
| Carrying out “Anti-Money Laundering”, “Know Your Client” and other compliance and risk management checks | Processing is necessary for compliance with legal obligations |
| Carrying out IT operations | We have a legitimate interest in carrying out Processing for the purpose of managing our IT systems and ensuring the security of those systems |
| Contacting you about new or existing products and services, to obtain feedback via client satisfaction surveys or providing you with other information that we think is relevant using the contact information that you have provided | We have a legitimate interest in being able to improve and market our products/services |
| Operating our Website including providing content to you and interacting with you | We have obtained your prior consent to the Processing which is entirely voluntary |
Where we collect special categories of data, we will generally rely on obtaining specific consent in order to process such information, although it may be necessary for us to use certain information in order to comply with our legal obligations as a regulated entity. Where we do rely on consent for processing, you may withdraw such consent at any time, by contacting us using the contact details set out in the “How to contact us” section below. Please note, however, that in certain circumstances it may be still lawful for us to continue processing this information even where consent has been withdrawn, if one of the other legal bases described above is applicable.
Your Rights
Under applicable data protection legislation, you have the following rights in relation to your personal data:
- the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
- the right to require us to rectify any inaccuracies in your personal data;
- the right to require us to erase your personal data in certain situations;
- the right to request that we no longer process your personal data for particular purposes;
- the right to object to our use of your personal data or the way in which we process it; and
- the right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.
If we receive a request from you to exercise any of the above rights we will comply with our legal obligations in relation to such request. We may ask you to verify your identity before acting on the relevant request; this is to ensure that your personal data is protected and kept secure.
Sharing and Disclosing Your Personal Data
We may disclose your personal data to other entities within the Impax Asset Management Group. In addition, we may disclose your personal data to our external third-party service providers, including:
- Providers of services which may identify or prevent financial crime;
- Counterparty banks;
- Custodians;
- Technology providers;
- Market research and analysis service providers;
- Government, legal, tax and regulatory, or similar authorities; and
- Accountants, auditors, financial and tax advisors, lawyers and other outside professional advisors.
We consider that disclosing your personal data to the above entities/third-parties is within our legitimate interests to be able to provide you with our products and services. We will ensure that if we share information with, or provide access to, third parties, any such disclosure or access is at all times in compliance with data protection legislation including implementing appropriate contractual terms to govern any such disclosure and/or processing of your personal data.
We may also disclose your personal data to third parties in order to respond to legal requirements, enforce our policies and protect our rights. We may share your personal data with other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.
International Transfer of Personal Data
Because of the international nature of our business, we may need to transfer your personal data within the Impax Asset Management Group, and to third parties as noted above, in connection with the purposes set out in this notice. For this reason, we may transfer your personal data to other countries that may have different laws or data protection requirements, including data protection laws of a lower standard, to those that apply in the country in which you are located.
Where we transfer your personal data to other countries, we do so on the basis of:
- European Commission’s or the United Kingdom Secretary of State’s adequacy decisions;
- our intra-group data transfer agreements;
- suitable standard contractual clauses; or
- other valid transfer mechanisms.
If you want to receive more information about the safeguards applied to international transfers of personal data, please use the contact details provided below.
Keeping Your Personal Data secure
We take your privacy very seriously and have implemented appropriate technical and organizational measures designed to protect and secure your personal data and prevent it from being accidentally lost, used or accessed in an unauthorized way.
You are responsible for ensuring that any personal data that you send to us is sent securely.
We also have procedures in place to deal with any suspected information security breach. We will notify you, and any applicable regulator, of any suspected breach where we are legally required to do so.
How Long We Keep Your Personal Data
We only retain personal data for as long as is necessary for the purposes set out in this notice, or as may be required by law. We will retain your personal data for as long as we provide services to you and may keep that data for a further 6 years if necessary for legitimate business purposes.
Please note that in certain circumstances, we may hold your data for a longer period if we believe in good faith that the law or relevant regulators require us to preserve your data.
Marketing
Occasionally, we would like to contact you with details regarding products, services, events or newsletters that we provide. We will process your personal information for these purposes given our legitimate interest in undertaking marketing activities. You have the right at any time to stop us from contacting you for marketing purposes by using the opt-out/unsubscribe options or by contacting us directly.
CCPA
Our Services are designed for businesses and are not intended for personal, family, or household use. Accordingly, we treat all personal information covered by this Privacy Policy as pertaining to individuals acting as business representatives, rather than in their personal capacity.
Cookies
A cookie is a small file that is placed on your device when you visit our website with your consent. It records information about your device, your browser and, in some cases, your preferences and browsing habits. We may process your personal data using cookies, in accordance with our Cookie Policy.
How to Complain
We only process your personal data in compliance with this privacy notice and in accordance with relevant data protection laws. We hope that we can resolve any query or concern you raise about our use of your information. If, however you wish to raise a complaint regarding our processing of your personal data, or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: +44 (0)303 123 1113.
Changes to our Privacy Notice
This privacy notice was published on 24 February 2023.
We may change this privacy notice from time to time to reflect changes in our practices with respect to the processing of personal data, or changes in applicable law. All amended terms will automatically take effect immediately on posting. Please read this privacy notice carefully, and regularly check this page to review any changes we might make. Where we make material changes in relation to how we process your personal data, we shall update this privacy notice and notify you of such changes by way of notification on this website.
How to contact us
If you have and questions or concerns about this privacy notice or any other issues relating to the processing of personal data by Impax Asset Management Group plc, please contact:
- your regular client relationship manager
- our Information Security Officer by email iso@impaxam.com
- or write to us at:
Information Security Officer
Impax Asset Management
Seventh Floor
30 Panton Street
London
SW1Y 4AJ
United Kingdom
Controllers Details
| Data Controller Entity | Business Address | Controller For: |
|---|---|---|
| Impax Asset Management (Group) Plc | Seventh Floor 30 Panton Street London SW1Y 4AJ | Investors in Impax PLC Vendors Website visitors |
| Impax Asset Management Limited | Seventh Floor 30 Panton Street London SW1Y 4AJ | Clients investing in our funds Vendors |
| Impax Asset Management (AIFM) Limited | Seventh Floor 30 Panton Street London SW1Y 4AJ | Clients investing in our funds Vendors |
Use of cookies
We would like to set and access cookies and similar technologies on your device to obtain information about how you access and use our website (Site) and to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site.
A cookie is a small text file which is placed onto your browser or the hard drive of your computer or onto your electronic device when you access our site.
The cookies we use on this Site can be categorised in accordance with the categories found in the ICC UK cookie guide. These are:
- Strictly necessary cookies – enable core functionality such as security, network management, and accessibility. They also make our Site easier to use by accelerating its display through load balancing. You can disable these by changing your browser settings, but this may affect how the Site functions. You cannot disable these using our cookies tool.
- Functional cookies – these cookies are set to provide enhanced functionality and make our Site easier to use, by remembering your preferences, including the preferences you have indicated on our cookies tool.
- Analytical cookies – these are used so we can collect information about how people access and use the Site to help us improve your experience of our Site.
- Advertisement cookies – these cookies may be set through our Site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store information about your actual identity (such as your name), but they do store information based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience advertising, but it will be less targeted to you.
Cookies can also be categorised in accordance with how long they are saved on your device: “session cookies” are short-term cookies that are only saved on the device’s memory for the duration of a user’s visit to the Site, whereas “persistent cookies” remain saved in the device’s memory for a set period of time, even after the browser session has ended. The expiry period for each cookie is set out below
You can find more information about the individual cookies we use and the purposes for which we use them in the table below.
Consent
In most cases we will need your consent in order to use cookies on this Site. The exception is where the cookie is strictly necessary for the Site to load and for you to navigate it. These cookies enable core functionality such as security, network management, and accessibility. You can disable these by changing your browser settings (see Refusing and Restricting Cookies section below on how to do this), but please be aware that this may affect how the Site functions. You cannot disable these using our cookies tool.
You can give consent to other cookies we place, or withdraw any consent you have previously given, through our cookies tool or your browser settings – for more detail, please see the Refusing or Restricting Cookies section below.
Please note that, in order to refuse cookies that are set by third parties, you must use your browser settings or visit the third party site and follow the instructions in their cookie notice. See more information about the use of third party cookies on our Site below.
| Cookie | Duration | Category | Description |
|---|---|---|---|
| share_class | 1 year | necessary | This cookie is set by Impaxam.com. The purpose of the cookie is to determine the user’s selected Share class type. |
| investor_type | 6 months | necessary | This cookie is set by Impaxam.com. The purpose of the cookie is to determine the user’s selected Investor type. |
| investor_label | 6 months | necessary | This cookie is set by Impaxam.com. The purpose of the cookie is to determine the user’s selected Investor label type. |
| investor_country | 6 months | necessary | This cookie is set by Impaxam.com. The purpose of the cookie is to determine the user’s selected country. |
| lidc | 1 day | functional | This cookie is set by LinkedIn and used for routing. |
| bcookie | 2 years | functional | This cookie is set by linkedIn. The purpose of the cookie is to enable LinkedIn functionalities on the page. |
| lang | session | functional | This cookie is set by linkedIn. This cookie is used to store the language preferences of a user to serve up content in that stored language the next time user visit the website. |
| _gat_UA-28097176-1 | 1 minute | analytics | This is a pattern type cookie set by Google Analytics, where the pattern element on the name contains the unique identity number of the account or website it relates to. It appears to be a variation of the _gat cookie which is used to limit the amount of data recorded by Google on high traffic volume websites. |
| _gid | 1 day | analytics | This cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected including the number visitors, the source where they have come from, and the pages visted in an anonymous form. |
| _ga | 2 years | analytics | This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site’s analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors. |
| _gcl_au | 3 months | analytics | This cookie is used by Google Analytics to understand user interaction with the website. |
| vuid | 2 years | analytics | This cookie is used by vimeo to collect tracking information. It sets a unique ID to embed videos to the website. |
| IDE | 1 year 24 days | advertisement | Used by Google DoubleClick and stores information about how the user uses the website and any other advertisement before visiting the website. This is used to present users with ads that are relevant to them according to the user profile. |
| bscookie | 2 years | advertisement | This cookie is a browser ID cookie set by LinkedIn share Buttons and ad tags. |
| _mkto_trk | 2 years | advertisement | This cookie is associated with an email marketing service provided by Marketo. This tracking cookie allows the website to link visitor behavior to the recipient of an email marketing campaign, to measure campaign effectiveness. |
| test_cookie | 15 minutes | advertisement | This cookie is set by doubleclick.net. The purpose of the cookie is to determine if the user’s browser supports cookies. |
| viewed_cookie_policy | 1 year | necessary | The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data. |
| li_gc | 2 years | others | Used to store consent of guests regarding the use of cookies for non-essential purposes. |
| AnalyticsSyncHistory | 1 month | others | Linkedin – Used to store information about the time a sync with the lms_analytics cookie took place for users in the Designated Countries. |
| UserMatchHistory | 1 month | others | Linkedin – Used to track visitors on multiple websites, in order to present relevant advertisement based on the visitor’s preferences. |
Refusing or Restricting cookies
If you do not agree to the use of these cookies, you may refuse to accept, or withdraw your previous consent to, cookies in two ways:
- Using our cookies tool, which you can access at the bottom of the Site. Our cookies tool will record when you have consented to non-essential cookies. Essential cookies cannot be disabled using the tool because they are necessary to make the Site function. You may change your mind about the cookies you have selected through our cookies tool by updating your choices in our tool at any time.
- Please be aware that our cookies tool cannot be used to block cookies on third party websites linked to from our Site. In order to remove these cookies you will need to visit the relevant third party site and follow the instructions in their cookie notices. Alternatively, follow the instructions below to turn off these cookies using your browser settings.
Using your browser settings may allow you to refuse the setting of certain cookies. The “Help” or “Internet Settings” functions within your browser should tell you how. For information on how to manage cookies on popular browsers please see the following links:
Alternatively, you may wish to visit http://www.allaboutcookies.org/ which contains detailed information on cookies and how to delete, restrict or block them on a wide variety of browsers. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.
Third Party cookies
We work with third-party suppliers who may also set cookies on our site, such as Google.
Google Analytics uses cookies to help us analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full functionality of this website. Google’s privacy policy in respect of Google Analytics is available here http://www.google.com/analytics/learn/privacy.html. You may opt out of tracking by Google Analytics by visiting https://tools.google.com/dlpage/gaoptout?hl=en-GB.