This EEA and UK Addendum supplements AEW’s Privacy Statement and is applicable to processing of personal data by AEW entities that is in scope of the General Data Protection Regulation (GDPR) or UK Data Protection Act 2018 (DPA).
AEW Capital Management L.P., AEW SA and AEW Global Advisors (Europe) Limited will each be considered a separate data controller in respect of personal data about you that is collected through AEW’s website or in the context of services offered to you in your personal capacity where you are in the EEA or UK, such as where you are an employee or an individual investor interested in investing in a fund that is managed by AEW Capital Management L.P., AEW SA or an affiliate.
References in this Addendum to “AEW” are to the relevant AEW entity which is the data controller of your personal data, as explained above.
A data controller is responsible for deciding the ways in which and purposes for which personal data about you is processed.
The information we process about you and why:
|Categories of personal information|
Last Updated: June 2021
|If you are an investor or client, identifiers such as a real name, alias, postal address, unique personal identifier, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.|
|If you are an investor or client, signature, physical characteristics, telephone number, education, employment, financial information.|
|If you are an investor or client, commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.|
|If you use our website, internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement, online identifiers, Internet Protocol address. |
|Audio, electronic, visual, thermal, olfactory, or similar information.|
|If you are a client or investor, professional or employment-related information.|
|If you are a client or investor, professional or employment-related information.|
|Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.|
The following table details how and why AEW uses your personal data:
|How We Use Your Personal Information||Why We Use Your Personal Information|
|To serve you or your company as our client, including to facilitate the opening of your account, the management and administration of holdings and any related account on an ongoing basis (including the processing of redemption, conversion, transfer and additional subscription requests) and the payment of distributions and the sending of account-related materials, and the processing and verification of instructions|
|To communicate with you as our client, or client contact|
|To manage our business operations|
|To manage privacy and security|
|To aid in the detection and prevention of financial crimes, including the carrying out of anti-money laundering checks and related actions|
|Where required by law or regulation or if we reasonably believe that it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process|
|To provide you with information about AEW’s services, marketing or research materials or other relevant information.|
Special category personal data is personal data which reveals or contains racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life and sexual orientation.
We do not intend to actively collect special category data about you. Whilst we will use reasonable efforts to limit our holding of such data, please be aware that we may hold such data incidentally. For example, where you volunteer special category data to us, such as if you send us an email containing special category data.
What if you do not provide the personal information requested?
Until you decide to engage in a business transaction with us you are not required to provide us with any information. If you are a prospective or current client or investor and do not provide us with certain information when requested, in some circumstances we may be limited or restricted in our ability to deal with you and may in some cases be prevented from complying with our legal obligations. Where we require your personal information to comply with legal requirements or to perform our contract with you, failure to provide this information means we may not be able to accept you or retain you as an employee, client or investor.
How your personal information is collected
We collect data from the following sources:
Sharing of your personal information
We may share your personal information with a third party where this is necessary to perform our contract with you, required by law or where we have another legitimate interest in doing so. We may need to share your personal information with:
We may also need to share your personal information with third parties, for example, in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with applicable law or judicial process or if we reasonably believe that disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
As AEW Capital Management L.P. is domiciled in the U.S. and our website is hosted in the U.S. Any personal data that AEW Capital Management L.P. collects about you via our website or in the context of providing services to you in your personal capacity may be processed in the U.S. for us to provide the services requested. AEW SA and AEW Global Advisors (Europe) Limited may transfer personal information collected about you to the U.S. where the parties listed above are based for the purposes outlined above. Those countries may not have the same standard of data protection laws as the EEA or UK. Where this is the case, and where the transfer is not necessary for the performance of a contract with you or concluded in your interests or for the establishment, exercise or defense of legal claims, we will put in place appropriate safeguards such as standard contractual clauses to ensure that your personal data is treated in a manner that is consistent with and respects the EEA and UK laws on data protection. For additional information please contact email@example.com or DataPrivacy@aew.com.
Retention of your personal information
We will retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and our legitimate interests in maintaining such personal information in our records. In doing this, we will have regard to the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Generally, we will keep information relevant to our dealings with you for seven (7) years following the last date of activity.
In some circumstances, your personal data may be anonymised so that it can no longer be associated with you, in which case it is no longer personal data.
Once we no longer require your personal data for the purposes for which it was collected, we will securely destroy your personal data in accordance with applicable laws and regulations.
Accuracy of information
It is important that the personal data held about you is accurate and current. Please let us know if your personal data changes during your relationship with us.
Your rights in relation to your information
You have rights as an individual which you can exercise in relation to the information held about you under certain circumstances. These rights are to:
In exercising your rights above, you may be required to [redeem/withdraw] from any investment you may have made.
You also have the right to make a complaint at any time to a supervisory authority for data protection issues. In the UK, this is the Information Commissioner’s Office.
You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact firstname.lastname@example.org or DataPrivacy@aew.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless we now have an alternative legal basis for doing so.
Changes to this privacy notice
We reserve the right to update this Privacy Notice at any time and will make an updated copy of such Privacy Notice available to you and notify you when any substantial updates are made. We may also notify you in other ways from time to time about the processing of your personal data.