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, world check 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.

We may collect your Personal Data for the following purposes and process it:

Purpose for processing
– Servicing of clients and/ or shareholders in our Luxembourg and Australian Funds: provide sales reporting and account statements, perform account openings/ closures and invoicing, monitor cash-flows, reporting to clients/ shareholders etc.

– Provision of our Funds and services: administering relationships and related services; performance of tasks necessary for the provision of the requested services; communicating with you in relation to those services.

Legal basis for processing
Processing is necessary in connection with the performance of a contract between you and us  and/or taking steps, at your request, to enter into such a contract; or

We have a legitimate interest in carrying out the processing for the proper administration of our funds and business.

Purpose for processing
– Offering investment in shares and performing the related services as described in the relevant Fund’s prospectus, account opening forms and any other agreement with other CG companies and third parties, including but not limited to: the opening of your account with the Funds, the management and administration of your holdings and any related account on an on-going basis, and the operation of the Funds’ investment in sub-funds, including processing subscriptions and redemptions, conversion, transfer and additional subscription request, the administration and payment of distribution fees (if any), payments to shareholders, updating and maintaining records and fee calculation, maintaining the register of shareholders, providing financial and other information to the shareholders.

Legal basis for processing
Processing is necessary in connection with the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract; or

We have a legitimate interest in carrying out the processing for the proper administration of our funds and business.

Purpose for processing
– On-boarding of clients and/ or shareholders in our Luxembourg and Australian Funds: Your Personal Data might be collected for the establishment of AML/ KYC files, to perform sanctions screenings, compliance with our internal compliance requirements, policies and procedures. 

Legal basis for processing
Processing is necessary for compliance with a legal obligation; or

Processing is necessary in connection with the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract; or

We have a legitimate interest in carrying out the processing for the proper administration of our funds and business.

Purpose for processing
– Direct or indirect marketing activities and prospecting: preparation of mailings (information about CG, promotion of new funds/ products, etc.), events, market research, communicating with you via any means (including via email, telephone, text message, social media, post or in person), subject to ensuring that such communications are provided to you in compliance with applicable laws and regulations; and maintaining and updating your contact information where appropriate.

Legal basis for processing
Processing is necessary in connection with the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract;

We have a legitimate interest in carrying out the processing for the proper administration of our funds and business;
or
We have obtained your prior consent to the processing where it is entirely voluntary, and not necessary or compulsory in any way.

Purpose for processing
– Publishing: promotional material/ reports for use with clients and prospects. 

Legal basis for processing
Processing is necessary in connection with the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract; or

We have a legitimate interest in carrying out the processing for the proper administration of our funds and business.

Purpose for processing
– Operating our website and ensuring the security of our website: operation and maintenance of websites, provision and update of website content, tracking and profiling of website visitors, log-in area for institutional clients, advertising and/ or other information to you.  

Legal basis for processing
The legal basis for this processing is our legitimate interest, namely the proper administration of our website;

Processing is necessary in connection with the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract; or

We have obtained your prior consent to the processing where it is entirely voluntary, and not necessary or compulsory in any way.

Purpose for processing
– Compliance with legal and regulatory obligations as per applicable laws: to carry out any form of cooperation with, or reporting to, public authorities including, but not limited to, legal obligations under applicable fund and company law, prevention of terrorism financing, anti-money laundering law, prevention and detection of crime, tax law (such as reporting to the tax authorities under FATCA  and CRS Law to prevent tax evasion and fraud), and to prevent fraud, bribery, corruption and the provision of financial and other services to persons subject to economic or trade sanctions on an on-going basis in accordance with relevant internal anti-money laundering policies and procedures, as well as to retain your AML and other records for the purpose of screening in relation to other funds or clients.

Legal basis for processing
Processing is necessary for compliance with a legal obligation; or

We have a legitimate interest in carrying out the processing for the purpose of establishing, exercising or defending our legal rights.

Purpose for processing
– Managing our business relationship: communicating with you regarding your services.

Legal basis for processing
The legal basis for this processing is our legitimate interest, namely the administration of our business relationship;

Processing is necessary in connection with the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

Profiling means the automated processing of Personal Data, such as the use of cookies, to evaluate certain things about the users of our websites. Profiling can be part of an automated decision-making process which means that a decision is solely made by automated means without any human involvement.

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.

When using the public areas of our website, through the use of cookies we may track the number of users who visit the public areas of the website and may also record the location of your computer on the internet for systems administrative and trouble-shooting purposes and to report aggregate information. We may collect and store certain navigational and transactional information, such as page hits and PDF files you view, and the times and ways you use this website. We use navigational information to personalize our website, for programming, editorial and financial research and to offer new content that our users may like. For the use of cookies on our website we further refer you to our Cookie Policy.

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.

Should you have any question about this Policy or wish to exercise your above listed rights, you can contact us under (dataprotectionofficer_europe@capgroup.com) for Europe, or (dataprotectionofficer_Asia@capgroup.com) for Asia ex-Japan and Australia.

This Policy is dated 11th April 2019 Any changes we make to our Privacy Policy in the future will be posted on this page, and where appropriate, notified to you by e-mail.

Switzerland Only
Capital International Sàrl is responsible for the content of our website in Switzerland. The Funds listed on this website are authorized by the Swiss Financial Market Authority (FINMA) for distribution in or from Switzerland. Capital International Sàrl, 3 Place des Bergues, 1201 Geneva, is the Funds’ Representative in Switzerland and JPMorgan (Suisse) SA, 8 rue de la Confédération, 1204 Geneva, acts as their Swiss Paying Agent. The prospectus, the key investor information documents, the articles of incorporation, the latest annual and semi-annual reports of the Fund can be obtained through this website and upon request free of charge from the Swiss Representative.

Australia Only
If you wish to contact us for any purpose regarding this policy including making complaint about the way we have handled your personal information (including if you think we have breached the Privacy Act) you may do so to our Data Protection Officer in writing, by mail to Data Protection Officer, Capital Group, Level 18, 56 Pitt Street, Sydney NSW 2000 or by email to dataprotectionofficer_Asia@capgroup.com. When you contact us, please include your email address, name, address and telephone number and clearly describe your complaint. Our Data Protection Officer will investigate the complaint and respond to you promptly. If you consider that we have failed to resolve the complaint satisfactorily, and you are an individual located in Australia, you can complain to the Office of the Australian Information Commissioner.