Privacy Policy
This Privacy Policy is designed to help you understand what information we gather and process about you, why and how we use it, and with whom we share it. It also sets out the rights you have in relation to your information and how you may contact us for your queries.
Privacy Policy
In the course of doing business with you, Schroder Investment Management North America Inc. (“Schroders”) collects, uses and discloses personal and financial information (“personal information”) from you or other individuals. Schroders respects your right to privacy. We understand that you have entrusted us with this private information and we recognize the importance of protecting unnecessary or unauthorized access to it.
I. Information that we collect
We may collect personal information about you when you communicate or transact business directly with us or with our service providers in writing, electronically (including through our website or via email) or by telephone. For example, we may collect personal information about you, including:
- Identifiers, including names, aliases, postal addresses, unique personal identifiers, online identifiers, email addresses, account names, or other similar identifiers (including username and password if you need to access a restricted area of our web site);
- Commercial and financial information, including income and asset information, financial history and investment experience, and information on account balances and account transactions); and
- Government-issued identification such as a driver's license or passport numbers and other documentation to verify your identity or where required to meet anti-money laundering and know your client requirements.
In most cases, we collect personal information directly from you, however, we may also collect personal information indirectly from your consultant or administrator (in these cases, when consent is legally required, we rely on the third party to obtain your consent). We may collect personal information about you from the following sources:
- Applications or forms completed by you, including if you enter into an investment advisory contract with us
- Information you provide during telephone conversations, email, or contact forms that you send us;
- Your transactions and account positions with us, our affiliates or others (including, for example, your own broker or custodian); and
- Your use of our website as set out in Section IV below.
We collect information from you for the following purposes:
- To open your account with us.
- To maintain, process, or service your transactions or account(s) or to provide financial products or services.
- Investor onboarding, including to meet our legal and regulatory requirements, including anti-money laundering and know your client requirements.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing.
- To improve our website and present its contents to you.
- For marketing or client servicing.
- For testing, research, analysis and product development.
- For institutional risk control purposes as necessary or appropriate to product the rights, property or safety of us, our clients or others.
- As described to you when collecting your personal information.
If you sign-up to receive email marketing communications such as newsletters from us or our affiliates, we collect your email address. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email. Please note that you may continue to receive transactional or account-related communications from us.
II. Information that we disclose or share
We do not sell or rent your personal information to any third parties.
We and our service providers (including affiliates) may share your personal information with third parties in the following limited circumstances:
We may share some or all of your personal information with companies that help us maintain, process or service your transactions or account(s) or financial products or services effected by or through us, including companies that perform administrative, accounting, operational, IT, transfer agency, custodial, brokerage or proxy solicitation services for us. These companies will use this information only for the services for which we hired them, are not permitted to use or share this information for any other purpose (except to fulfill their own legal obligations) and are required to protect the confidentiality and security of this information.
- We may share some or all of your personal information, such as account and transaction data, to companies that assist us in marketing or client servicing. These companies will use this information only for the services for which we hired them, are not permitted to use or share this information for any other purpose (except to fulfill their own legal obligations) and are required to protect the confidentiality and security of this information.
- We may share or report some or all of your personal information if you request or authorize us to do so, for institutional risk control, or in other circumstances where we believe in good faith that disclosure is required or permitted under applicable Canadian, US or other law, which may include lawful access by US or foreign courts, law enforcement or other government authorities.
- We may transfer any information we have about you to evaluate or complete a merger, divestiture, restructuring, reorganization, assignment, dissolution, or other sale or transfer of some or all of our assets or change in corporate control, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
Personal information may be transferred to and processed by us and our service providers (including our affiliates) outside the jurisdiction in which you are located, including to other states or provinces in the US, Canada or other foreign jurisdictions where we or our service providers and affiliates are located.
III. Our security procedures
We maintain physical, electronic and procedural safeguards in an effort to protect your personal information. Within Schroders, access to such information is limited to those employees who need it to perform their jobs, such as servicing your accounts, resolving problems or informing you of new products or services. Finally, our Code of Ethics, which applies to all employees, restricts the use of customer information and requires that it be held in strict confidence.
We observe these policies with respect to current and former Schroders customers and shareholders.
If you identify any inaccuracy in your personal information or you need to make a change to that information, please contact us in writing so that we may promptly update our records.
IV. Information about our website
In general, you can visit our website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our website and other related information such as page requests, browser type, operating system and average time spent on our website. We use this information to help us understand our website activity and to monitor and improve our website.
Cookies: Our website uses "cookies". These are small text files that our website sends to the visitor’s browser and are stored on their device. Cookies are used by most websites and can do a number of things, including remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website. You may set your browser to notify you when you receive a cookie or to reject cookies.
Please see the Schroders Group cookie policy available [here] for information about the types of cookies we use, or click Manage Cookies to access our Privacy Manager where you can adjust your preferences for non-essential Cookies used on our website.
We use the following categories of cookies: Necessary, Performance, Profiling and Functionality, which are described in the Schroders Group cookie policy. We have provided additional information about our use of Performance and Profiling cookies below.
https://support.google.com/analytics/topic/2919631
- Profiling (including Interest-Based Advertising): We work with third parties such as ad networks and other advertising companies that use their own user tracking technologies (including cookies and pixel tags) on our website in order to provide you with tailored advertisements across the Internet, including on social media services. These companies may collect information about your activity and interactions on our website and third-party websites (such as web pages you visit and your interaction with our advertising and other communications) and use this information to build a profile of your interests, make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third-party websites. This information may also be used to evaluate the effectiveness of our online advertising campaigns. If you opt-out of these cookies, you will still receive Schroders ads but they may be less personalized.
- Opting-out of Interest-Based Advertising: 1. please click the link “Manage Cookies” in our Cookie policy to access the Privacy Manager window where you can adjust your preferences in regard to which cookie types you are willing to accept. 2. Ensure the “Profiling” category is set to “Off”.
- Please note that even if you opt-out of interest-based advertising by a third-party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads, but the ads will not be targeted based on behavioural information about you and may therefore be less relevant to you.
- To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.
For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices.
V. Your rights
Subject to applicable law, you have the right to access (including, where required, in a commonly-used electronic format), update, rectify and correct inaccuracies in your personal information in our custody or control. You have the right to opt out from receiving direct marketing communication from us, which you can easily exercise by clicking on the “Unsubscribe” link included in all our direct marketing communications.
You also have the right to receive some of your Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit such data to a third party where this is technically feasible. Please note that this right only applies to Personal Data that you have provided directly to Schroders.
In some circumstances you also have the right to request erasure of your personal data.
You may withdraw your consent to our collection, use and disclosure of your personal information (subject to legal and contractual restrictions), however, this may impact our ability to provide services to you.
You may request access, updating and corrections of inaccuracies in your personal information in our custody or control by emailing or writing to us at the contact information set out in section VII below. We may request certain personal information for the purpose of authenticating you.
VI. Privacy Governance Policies and Practices
Schroders is committed to protecting your personal information and have implemented policies and practices that govern our treatment of personal information, including:
- designated roles and responsibilities in connection with handling personal information in our custody and control;
- policies and procedures regarding the protection of personal information, including safeguards designed to protect personal information against loss or theft and unauthorized access, disclosure, copying, use, and modification;
- processes for responding to data subject requests and complaints;
- a framework for the retention and disposition of information designed to ensure compliance with our legal obligations.
In addition, we have designated our North America Privacy Officer as responsible for overseeing the company’s compliance with applicable privacy laws, and we provide our employees with privacy training and awareness.
VII. Contact Us
Schroders North America Privacy Officer
7 Bryant Park,
New York, NY 10018 USA
Email address: americasprivacy@schroders.com