Ninety One is committed to protecting the information we hold about you. This notice applies to all of the companies making up Ninety One. In this notice, we refer to ourselves collectively as ‘Ninety One’, ‘we’, ‘us’ and ‘our’.
The name of the specific Ninety One company which processes your personal information, will depend on which of our fund ranges you invest into. We’ll let you know which company you have a relationship with when you invest into one of our funds.
More information on the companies making up Ninety One is provided in Part B and you can find out more at www.ninetyone.com.
This notice provides you with information about how, when, and why we use your personal information and how we keep it secure. It also sets out your rights under law, our responsibilities to you and how you can contact us.
If you are interested in a career at Ninety One, please review our Applicant Privacy Notice.
This notice concerns any information that we collect in the following ways:
Should you have any questions about who we are, or what we do with your personal information, please contact us using the information provided in Part B.
Information about other people.
If you provide us with personal information about other people – such as a joint applicant or your dependents - you must show this privacy notice to them, and you must ensure that you have their consent to provide their personal information to us.
Information we hold about you
A description of the types of personal information about you that we collect, use, process and share.
Where we get our information about you
Details of information which you give to us, which we gather ourselves and which we seek from third parties.
How we use information about you and why
A description of what we use your personal information for, why we use it and why we are allowed to use it.
Whether you have to provide personal information
An explanation of whether you have to provide personal information to us and what happens if you do not.
When we share your information with others
Information about third parties that we share your information with.
Where we transfer your data
A notification that your information is transmitted and processed outside the European Economic Area.
How long we will keep your information
A summary of the circumstances in which we can keep your information
Your rights (‘ data subject’ rights)
A summary of your general rights over personal information. Please note that these do not always apply.
Ninety One Website and other websites
Information about the Ninety One Website and the information we collect.
Future changes to this privacy notice
A notification that the privacy notice can change and that we will update you about changes.
As with other financial institutions, we collect personal information about you.
Most of this information is necessary for us to comply with our legal obligations, to enter into a contract with you, or for legitimate business purposes.
When you apply to become a client or investor, and during the course of our dealings with you, we will collect some personal information about you. This includes what you tell us about yourself and what we learn by having you as a customer. Whether this collection is mandatory, or voluntary, will depend on the reason why we are collecting your personal information. For example, if you want to become a client or investor of ours, we require certain mandatory information from you to be able to add you to the relevant register of the product you subscribe to. If you refuse or fail to supply this information we will not be able to enter into a business relationship with you. However, if you voluntarily contact us about our funds and you are not a client or investor, you are in control of what information you volunteer and which is subsequently collected by us.
We have set out below a description of the types of personal information about you which we will collect and process in different situations when you interact with us.
01. Personal information that we generally process regardless of how you contact us, or for whatever reason, includes:
02. If you submit an application to become a client or investor or are already one, in addition to the above personal information, we may collect the following from you:
03. When you interact with the Ninety One Website, in addition to the above personal information, we may collect the following from you:
04. In addition to the above, we collect the following information from you when required:
We may have information about you that you did not provide to us yourself.
In relation to the categories of personal information described above, we collect personal information in the following ways:
We typically collect the personal information directly from you as part of our client /investor on-boarding process when you complete an application form and provide proof of your identity. Additionally, we collect personal information from you when you correspond with us (whether by telephone, e-mail, or through the Ninety One Website) or complete a request for a product or service. The nature of our relationship with you will determine the kind of personal information we might ask for.
We will continue to collect additional personal information that we learn about you during the course of providing our products and services, such as:
Sometimes we collect additional information about you from third parties. Specifically, we will obtain information about you from:
We need to use some personal information to provide you with our service and to fulfil our contract with you.
We mainly use the personal information we hold about you where it is necessary for us to perform our contract with you and/or to enable us to comply with legal obligations. Your personal information will also be used when it is in our legitimate interest. A legitimate interest is when we (and sometimes third parties) have a business or commercial reason to use your information. But even then, our legitimate interest must not unfairly go against what is right and best for you.
Each of these categories is a ‘legal basis’ that allows us to process your information under data protection law. We have provided further information below about what this actually means, in terms of how we process, or the purposes for processing your personal information relevant to each legal basis.
We need to use some personal information to comply with legal obligations.
We are allowed to use your personal information to pursue our own interests as long as your fundamental interests do not override these.
This will include processing which, on balance, we consider is in our legitimate interests and which do not cause you undue prejudice. Our legitimate interests which are applicable to our processing of your personal information include:
(Should you have any questions about the above listed categories of people and/or organisations, please contact us using the contact information provided in this Privacy Notice.)
If you have further questions about the third parties we share your personal information with, please contact us. The relevant details are set out in Part B.
Where we are relying on your consent to process your personal information, you are entitled to withdraw your consent at any time.
However, as noted above, we are usually processing your personal information based on another reason, in which case withdrawing your consent will not change how we process your personal information.
If you wish to withdraw your consent you may do so by contact us using the information in Part B.
You have the right to withdraw your consent at any time – the contact information is given in Part B. Please note, if you do withdraw your consent, this will mean that we will stop similar future processing. However, the withdrawal of your consent will not invalidate any processing which we previously undertook before you withdrew your consent.
Please note that, where we rely on another lawful reason to process your personal information which does not require your consent, withdrawing your consent will not affect that processing. This is the case where the processing is necessary for our performing our contract with you, or where we must process your personal information to comply with law, as described above. We will continue to process your personal information for those lawful purposes notwithstanding the fact that you have withdrawn your consent for one of the above listed purposes that requires your consent.
If you want to use our services, there is some information which you will be required to provide to us either because of legal requirements, or because we need that information to provide our services to you.
We are required to collect some personal information by law and regulation. For example, we are required to verify your identify before we can accept any applications.
In other cases we need the information in order to provide our service to you. For example, we need your bank account information to send you the proceeds of your investments.
We will tell you when the personal information requested is mandatory, or if it is voluntary. If you do not provide that personal information that is mandatory, we will be unable to properly provide you with the services and/or perform all obligations under our agreement with you.
Where you choose not to provide us voluntary personal information this may reduce the quality of service we are able to provide (for example, if you only provide us your postal address and do not provide us with your e-mail address, we will only be able to contact you by postal mail).
Your personal information will be shared with other businesses, regulators and authorities.
If you have further questions about the third parties we share your personal information with, please contact us using the details in Part B.
Yes, there are times when we are either mandated by law to disclose your personal information to third parties (such as Tax authorities). In addition, where we or a fund contracts third parties to help us run our business or fulfil the operation of the fund, we will also disclose your personal information to those third parties, but always subject to appropriate contracts and safeguards.
We will never sell, rent or trade your personal information.
We will share your information with others who have a duty to keep it secure and confidential, and where we have a lawful reason for doing so, as explained above. The categories of organisations that we will share your information with are:
We can also share your information with UK and overseas regulators and authorities in connection with their duties (such as crime prevention), and/or in connection with our compliance with legal and/or regulatory obligations.
In some markets where the funds invest, we are required to share information on substantial investors with the market / local exchanges / regulators for market transparency. This information may become publically available.
We cannot control all use of your information by third parties (especially where they are not our service providers and under contract with us, for example personal information shared with regulators). As such, where your personal information has been shared with another data controller entity, you will have rights over how that third party handles your personal information and you can and should contact those parties directly if you want to exercise your rights in relation to those third party’s uses of your personal information.
Your personal information will be shared with credit reference agencies for anti-money laundering and identity checks.
These credit reference agencies have their own Privacy Notice applicable to the searches they carry out which can be found at: www.experian.co.uk/crain
In order to become a client or investor of ours, we will perform identity checks on you with one or more credit reference agencies (‘CRAs’). To do this, we will supply your personal information to CRAs and they will give us information about you. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and identity verification information.
The identities of the CRAs, their role, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail at www.experian.co.uk/crain/.
We transfer your data outside of the European Economic Area (EEA) to countries such as the USA and South Africa.
Ninety One is an international business with processing units based in many different geographical locations. As a result, we, or our administrators or other service providers or agents of the funds, will process and transfer your personal information outside the European Economic Area (EEA) to group companies who have strict obligations to keep the information secure.
In particular, Ninety One and its service providers process information in the following non-EEA jurisdictions:
We will also share your personal information, where necessary, with regulatory authorities in the home state of the Ninety One fund in which you have invested, and overseas. It is possible that those authorities will, in turn, also share your information with other regulators. However, when they do so, they do so in their own legal capacities. So if you would like more information about how they handle your personal information, you will need to contact them directly.
Where we transfer your personal information outside of the EEA, the safeguards that we will use to protect your personal information include contractual obligations imposed on the recipients of your personal information. Those obligations require the recipient to protect your personal information to the standard required in the European Economic Area. Safeguards also include requiring the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing and where the framework is the means of protection for the personal information.
Your information may be held for a considerable period after our relationship ends (or indefinitely if anonymised).
If you have further questions about our data retention practices, please contact us using the details in Part B.
We will keep your personal information as long as you are a client of, or investor with, the Ninety One Group.
After you cease to be a client of ours, or investor with us, we may keep your data for up to an additional 10 years for one of the below reasons:
If we anonymise your personal information so that it can no longer be associated with you, it will no longer be considered personal information, and we can use it without further notice to you.
You have a number of rights over your personal information including a right to object to the processing of your information.
You will not be able to use these rights in all circumstances.
You are also entitled to make a complaint to the regulator.
Under data protection law you have a number of rights (set out below). Please note that these rights are not without limitation, and in some instances may not be available.
Where applicable, you have the right to:
To exercise your rights as set out above, please write to us using the details in Part B. There is no fee for making these requests. However, if your request is excessive or unfounded, we can charge a reasonable fee or refuse to comply with it.
You also have the right to lodge a complaint with your local data protection regulator if you think that we have infringed any of your rights. Information about your local data protection regulator is set out in Part B.
Pursuant to applicable law, you will not be discriminated against for exercising certain of your rights as set out above.
The content of this notice is likely to change over time. We will tell you if it changes.
We will always have the latest version available on the Ninety One Website.
If you use the Ninety One Website and follow a link from it to another website different privacy policies may apply. Prior to submitting any personal information to a website you should read the privacy notice applicable to that website.
We reserve the right to update this privacy notice at any time, and we will notify you when we make any substantial updates.
We will also notify you in other ways from time to time about the processing of your personal information. For example if you take out a new product with us.
The latest version of this privacy notice can always be found at www.ninetyone.com
How you can contact us with questions.
You can contact Ninety One Fund Managers UK Limited if you have any questions about this privacy notice or information we hold about you in relation to a UK fund.
Email us: [email protected]
Call us: 020 7597 1900
Write to us:
Ninety One Fund Managers UK Limited
PO Box 9042
You can contact Ninety One Guernsey Limited if you have any questions about this privacy notice or information we hold about you in relation to a Luxembourg fund.
Email us: [email protected]
Call us: 020 7597 1800
Write to us:
Ninety One Guernsey Limited
PO Box 250
St. Peter Port
You can contact Ninety One North America, Inc. if you have any questions about this privacy notice or information we hold about you in relation to a U.S. fund.
Email us: [email protected]
Call us: 917 (206) 5179
Write to us:
Ninety One North America, Inc
666 Fifth Avenue
We have set out below the local data protection regulators in the countries where our funds are established.
Information Commissioner’s Office
National Commission for Data Protection
Office of the Data Protection Authority