This Policy explains the collection, use, sharing and otherwise processing of your personal data
- as a visitor of this website,
- in connection with your investment in the range of CG’s Luxembourg domiciled UCITS funds, Australian domiciled funds and CG’s United Kingdom domiciled OEICS funds (the “Funds”) offered by Capital International Management Company Sàrl (“CIMC”) from Luxembourg, Capital Group Investment Management Limited (“CGIML”) ABN 73 164 174 501 from Australia and Capital Group UK Management Company Limited from the United Kingdom (“CGUKMC”) or,
- in connection with investment and shareholder services offered by CIMC or Capital International Sàrl (“CISA”) in Switzerland, Capital International Limited (“CIL”) and Capital Group Management Company Limited in the United Kingdom, Capital International Inc. (“CIInc”) in its capacity as Representative of the Funds in Singapore and Hong Kong, or CIInc ARBN 148 215 570 in Australia,
- or in connection with your business relationship with CG in accordance with applicable laws and regulations. CIMC, CGUKMC, CISA, CIL, CIInc, the Funds and/ or any other CG company with which you have a relationship will be the data controllers or joint controllers for the purposes of this Policy.
This Policy shall further inform you about your rights and choices in connection with our use of your personal information.
What is Personal Data and how do we collect it?
The term “Personal Data” as used in this Policy means any information relating to you as an individual and from which you can be identified.
We only collect personal information that is reasonably necessary for us to provide our products and services. If you do not provide the information that we ask for, we may not be able to provide the products or services you have requested.
For the purposes described below, we might collect and use your Personal Data, which can be grouped in the following categories, as may be relevant:
- Contact information: your name and contact details (private and professional), including telephone number, email address and/ or business contact information.
- Information related to regulatory requirements: in particular Anti-Money Laundering (“AML”)/ Know-Your-Customer (“KYC”) information, which may include your contact information, date of birth, passport or ID card, copies of household bills and any other information or data as required by applicable laws and regulations.
- Information related to your relationship with us: information received through agreements, application forms (completed in writing or electronically), which may include your contact information and tax identification number, your current and historic investments (including transaction and account history), investment preferences and investment amount, communications regarding your investment, any information, data or records that relate to your CG account or use of CG’s website; and
- Information collected when you visit our website: your online identifier (IP address) and your contact details where you register for any of our events or services online.
CG, as well as our distributors and sub-distributors, and the Transfer and Administrative Agent of the Funds will seek to collect directly from you your Personal Data which may be data you provide us in the course of our services, your investment in our funds and when visiting our website. Similarly, we may also collect such Personal Data provided by your employer, by our Transfer Agent when you invest in our funds, through publicly accessible sources, social media, subscription services, Dow Jones database, sanction lists, centralised investor database, public registers or other publicly accessible sources.
If you have accessed the “Institutional” or “Intermediaries” areas of our website, we will limit the collection and use of your Personal Data to what is necessary to administer our business and provide you with the highest quality service. We will not disclose any Personal Data except in the limited circumstances specifically described below. Any Personal Data disclosed to CG will be retained for so long as it is needed to fulfil any contractual obligations or services to you or comply with externally imposed legal/regulatory obligations.
We do not seek to collect and/ or process your sensitive personal data except where required and necessary for compliance with a legal obligation, where you have made such data publicly available or where we have obtained your explicit consent.
Why do we collect and process your personal data and what is the lawful basis for doing so?
We may collect your Personal Data for the following purposes and process it:
Automated decision-making and profiling
We will only engage in profiling and automated decision-making where it is necessary to enter into, or to perform, a contract with you, or where you have given your explicit consent, or where it is authorised by law. You can always express your opinion or contest decisions based solely on automated processing, including profiling, if such a decision would produce legal effects or otherwise similarly significantly affect you. When using automated decision-making we will provide you with further information about the logic involved, as well as the significance and the envisaged consequences to you.
To whom do we disclose and transfer your Personal Data?
We may disclose your Personal Data to other CG companies (this means our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this Policy.
To service our clients’ and shareholders’ accounts, your Personal Data may be disclosed or transferred within Capital Group and in certain circumstances to third parties and service providers, where permitted by laws and regulations. We may need to disclose your Personal Data to our auditors and/or professional advisers insofar as reasonably necessary for the purposes of the performance of our statutory or prudential audit or managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Please note that we may use or disclose your Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal processes. In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject.
We restrict access to your non-public Personal Data to authorised employees. We maintain physical, electronic and procedural safeguards to guard your non-public personal information. While we strive to protect our customers' and users' Personal Data and privacy, we cannot guarantee the security of any information you disclose online. We do not accept any liability for information which has been obtained through unauthorised access to the website.
For the purposes described above, we may have to transfer your Personal Data from the European Economic Area (“EEA”), United-Kingdom, Singapore, Hong Kong, or Australia to a CG affiliate or a third party outside these locations, including in a jurisdiction which may offer a different level of protection from the source location. However, we will keep your information private, in accordance with this Policy and applicable standard contractual clauses. CG further ensures that third parties are under contractual obligations to protect the confidentiality of your Personal Data, and to use it solely to provide services we have mandated them with.
You acknowledge that Personal Data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such Personal Data by others.
How long will we process and retain your Personal Data?
We will only retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying contractual obligations and legal, regulatory, accounting, tax or other reporting requirements. Where we keep your Personal Data for compliance with legal and regulatory obligations as per applicable laws and regulations, such as for AML/ KYC, we keep your Personal Data only if necessary and for the duration required under applicable laws and regulations. Please note that data retention obligations might differ within CG as they are subject to applicable local laws and regulations.
Your rights relating to your personal data?
As an individual you have the following rights, which you can exercise under certain circumstances in relation to your Personal Data which we hold:
- You have the right to access your Personal Data which we are keeping about you. Your right to access may, however, be restricted by applicable laws and regulations, the protection of other individual’s privacy and considerations for our business concept and practices.
- You have the right to request a copy of your Personal Data and request certain information relating to its processing.
- You have the right to ask us to rectify, amend, delete or have us completely remove your Personal Data from our data base.
- You have the right to object and/or request a restriction of processing of your Personal Data.
- You also have the right to make a complaint to the competent supervisory authority for data protection issues.
- In case you have provided consent to the collection, processing and/or transfer of your Personal Data, you have the right to fully or partly withdraw your consent.
We may ask you for additional information to confirm your identity and for security purposes before disclosing the Personal Data requested by you. We will not charge any administration fee for such a request unless the request is deemed unnecessary or excessive in nature.
How can you contact us?
Should you have any question about this Policy or wish to exercise your above listed rights, you can contact us under (firstname.lastname@example.org) for Europe, or (dataprotectionofficer_Asia@capgroup.com) for Asia ex-Japan and Australia.
This Policy is dated 11th April 2019 and was updated in July 2022 to incorporate the launch of the new UK based fund management company CGUKMC.