Who 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 may process your personal data to meet our legal and/or contractual obligations. 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:
- 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.
Sensitive Personal Data may be processed 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
The purposes and reasons for processing your personal data are detailed below:
|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 any contract that you may enter into with us, or the steps taken prior to entering into a contract with us|
|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, or other information that we think is relevant using the contact information that you have provided||We have a legitimate interest in being able to 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|
Under the EU General Data Protection Regulation, 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 third-parties to provide the below services or business functions:
- Providers of services which may identify or prevent financial crime;
- Counterparty banks;
- Technology providers;
- Government, legal, tax and regulatory, or similar authorities;
- 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.
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 adequacy decisions;
- our intra-group 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. 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.
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.
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 17 May 2018 and is effective from 25 May 2018.
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. Please read this privacy notice carefully, and regularly check this page to review any changes we might make.
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 firstname.lastname@example.org
- or write to us at:
Information Security Officer
Impax Asset Management
30 Panton Street
|Data Controller Entity||Business Address||Controller For:|
|Impax Asset Management (Group) Plc||Seventh Floor|
30 Panton Street
|Investors in Impax PLC|
|Impax Asset Management Limited||Seventh Floor|
30 Panton Street
|Clients investing in our funds|
|Impax Asset Management (AIFM) Limited||Seventh Floor|
30 Panton Street
|Clients investing in our funds|
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