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Privacy and Cookie Notice

Last Updated: May 25, 2018

BBH values your privacy.  This privacy and cookie notice applies to our privacy practices for handling information relating to your use of the bbhluxembourgfunds.com website (the “Site”) and our online services on the Site as well as services related to our business products (the “Services”). We also describe the rights you may have and how you can contact us about our privacy practices.

BBH is the data controller for personal information that we collect through the Site.  We are also the controller for personal data we collect in connection with your business relationship with us.  If you have questions on when we are acting as a controller or our processing of your personal data (or about any content in this notice) please find our contact details in the How to Contact Us section at the end of this notice.

Please read this notice carefully.  Your use of the Site and/or the Services, including your disclosure of any personal information into the Site and/or Services is subject to and governed by this notice. 

Information we collect

We collect, use and store personal information about you from several sources, including:

  • Information we receive from you in writing, in person, by telephone and electronically;
  • Information we receive in applications or in other forms; and
  • Information we receive through our website, online services and through the Internet.

This information may include:

  • Your name, address, phone number and other contact details;
  • Information about your transactions with us, our affiliates, and non-affiliated third parties, which may consist of information about account balances and counterparties to transactions; and
  • Your country of residence, status as an eligible investor (as obtained through your use of our websites or other means, as applicable) and other information as described below (under the heading “Information that We Collect Automatically”).

Information that you provide us

Personal information that you provide directly to us will be apparent from the context in which you provide it, for example:

  • if you fill out a form on our Site, you will generally provide your name, contact details and any other information required by the form, such as the content of your enquiry;
  • if you sign up to receive electronic marketing communications from us, you will generally provide your name, email address and other contact information, and your product preferences;
  • if you sign up for any of the online services we provide, you will generally provide your name and contact information and any other information necessary to access the feature;
  • If you are a key contact in a business that has a business account with BBH, we generally have your name, email address, phone number, title and other information relevant to your interaction with BBH on behalf of your employer; and 
  • if you are a person that we hold information on in relation to a business product or service held with us, we generally have information you have provided to us in order to open and administer your account and or the register of the fund(s) you own shares of, which could include data to detect and prevent fraud, anti-money laundering and terrorism financing as well as to perform negative news and sanctions screening.

Information that we collect automatically

Our web servers may log information such as your device type, operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The web server logs may also record information such as the address of the web page that referred you to our Site and the IP address of the device you use to connect to the Internet. They may also log information about your interaction with the Site, such as which pages you visit. To control which web servers collect information by automated means, we may place tags called “web beacons” – small files that link web pages to particular web servers and their cookies. We may also collect information from your browser, such as your browsing history, and use it in conjunction with data gathered from forms and emails to help understand and respond to your needs.

“Do Not Track” Signals

Your browser settings may allow you to transmit a “Do Not Track” signal to websites and online services you visit. Like many other websites and online services, we do not currently process or respond to “Do Not Track” signals from your browser or to other mechanisms that enable choice.  Both we and others (such as our service providers) may collect personal information about our visitors’ online activities over time and across third-party websites.  Other than collection of information as described in this Privacy and Cookie Notice, we will not collect personal information about you when you use the Site or the Services, unless you choose to directly provide such information to us when contacting us via email or other method.  We will use your personal information to process your request and, when applicable, respond to you. 

Sensitive data

We recognize that certain jurisdictions have enacted laws that require higher protection of certain sensitive personally identifiable information, such as state or national ID numbers, or other information regarding racial or ethnic origin, health or medical records (“Sensitive Data”).  As a general rule, we do not collect Sensitive Data from you.

In the limited cases where we do seek to collect such information, we will seek to do so only in accordance with applicable data privacy law requirements.

How we use and share personal information

Information that we collect from you

We may use your personal information provided for a number of reasons, including, but not limited to:

  • To respond to inquiries or service requests and monitor such responses;
  • To provide information about and market our products or Services;
  • To manage and improve the Site and assess its usage and usage of the Services we provide; and
  • To operate our business in accordance with industry standards and applicable laws and regulations, which may include, in addition to supporting the Services; responding to inquiries and requests; prevent fraud; and monitoring and archiving communications; and
  • Administering accounts, including anti-money laundering, sanctions and anti-fraud checks.

We use the personal information for the purposes described above because we have a legitimate interest in operating and improving our business that is not overridden by your interests, rights and freedoms to protect personal information about you.  We will only send you direct marketing materials if you have given consent for us to do so, unless such consent is not required, in which case you will be provided the opportunity to opt-out of receipt of direct marketing materials.

Information that we collect automatically

We use personal information that we collect automatically through cookies, non-cookie-based tokens, web beacons, and other automated means for purposes such as customizing and enhancing our visitors’ experience on the Site, facilitating use of the Site, collecting statistics about your visits to the Site, and understanding the way in which our visitors browse the Site. We also use the information to help diagnose technical and service problems, administer the Site, and identify visitors to the Site. We use clickstream data to determine how much time visitors spend on web pages of the Site, how visitors navigate the Site, and how we may tailor the Site to better meet the needs of our visitors. We use the personal information for the purposes described above because we have a legitimate interest in operating and improving our Site that is not overridden by your interests, rights and freedoms to protect personal information about you. 

Cookies

By using this Site you agree to the placement of cookies on your computer in accordance with the terms of this notice. If you do not wish to accept cookies from this site please either disable cookies in your web browser or refrain from using this Site.

A. What are cookies?

Cookies are text files containing small amounts of information downloaded to your computer or device when you visit a site. Cookies are then sent back to the originating site on each subsequent visit, or to another site that recognizes that cookie. Cookies are useful because they allow a site to recognize a user’s device. You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu.

Cookies do a lot of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and they generally improve the user experience. They can also help to ensure that the advertisements you see online are more relevant to you and your interests.

The cookies used on this site have been categorized on the basis of the categories found in the International Chamber of Commerce UK Cookie guide issued in April 2012. A list of the types of cookies used on our website is set out below.

Some of the cookies we use are for web analytics and intelligence about our site. We may also use web beacons or other technologies for similar purposes and we may include these in marketing e-mail messages or our newsletters in order to determine whether messages have been opened and links clicked on. Web beacons do not place information on your device, but may work in conjunction with cookies to monitor site activity.

B. Types of cookies

There are four types of cookies explained below. We use the first three on our site.

(1) Strictly necessary cookies - These cookies are essential in order to enable you to move around the site and use its features, such as accessing secure areas of the site. Without these cookies the Services cannot be provided.

We categorize the following cookies as strictly necessary:

  • Registered Visitor Cookie - A unique identifier given to each registered user, used to recognize them through their visit and when they return to the site. (see also Functionality cookies below).

(2) Performance cookies - These cookies collect information about how visitors use a site, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is anonymous and is only used to improve how a site works.

We categorize the following as performance cookies:

  • Referrer URL (internal page) - Used to store the URL of the previous page visited. Allows us to track how visitors navigate through our site.
  • Referrer URL - Used to store the URL which refers a visitor to our site so we may understand what URLs are referring visitors to our site.
  • URL history - Used to store the page visited by a user before that user submits a form. Also, used to display recently viewed articles to each visitor.
  • Unregistered Visitor Cookie - A unique identifier given to each visitor to allow analysis on how unregistered visitors use our site.
  • Session management cookies - These cookies allow us to follow the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close their browser window. Our session management cookies are created temporarily. Once you close your browser, our session management cookies are deleted.

(3) Functionality cookies - These cookies allow a site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a site may be able to provide you with local information by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. We may use information collected from our cookies to identify user behavior and to serve content and information on products and services based on your profile. We may pass or share this information within BBH for marketing or analysis purposes. In most cases we will not be able to track individuals by name; only if you are a registered user we can associate the cookie information with your name.

These cookies cannot track your browsing activity on other websites. They don’t gather any information about you that could be used for advertising or remembering where you’ve been on the internet outside our site.

We categorize the following as functionality cookies:

  • Recently viewed pages - Stores pages visited by the user on our site and displays them in right hand navigation for easy reference.
  • Search history - Stores searches on our site conducted by the user and displays them for the user in the right hand navigation for easy reference.
  • Registered Visitor Cookie - A unique identifier given to each registered user to our site, used to serve them content and offers based on their profiles. Also used for analysis and marketing purposes (see also Strictly necessary cookies above).

(4) Targeting cookies - These cookies are used to deliver advertisements that are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the site operator’s permission. They remember that you have visited a site and this information is shared with other organizations such as advertisers. Quite often they will be linked to site functionality provided by the other organization. We recommend you read the terms of use and privacy policy of such sites before using them.

C. Refusing cookies on our site

By using our site you agree that we can place cookies on your device as explained above. If you want to remove existing cookies from your device you can do this using your browser options. If you want to block future cookies being placed on your device or would like to prohibit website tracking you can change your browser settings to do this.

For more information on managing cookies and other tracking devices see:

www.allaboutcookies.org/manage-cookies

Deleting and blocking cookies will have an impact on your user experience as parts of the Site may no longer work. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon you visit our site, even if you have previously deleted our cookies.

Other uses of your personal information

We also may use the personal information that we collect to protect against and prevent fraud, claims, and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms.   We use personal information for these purposes when it is necessary to protect, exercise or defend our legal rights, or when we are required to do so by law that applies to us.

In addition to the uses described above, we may use personal information that you provide to us or that we collect for other purposes. Where this is the case, we will provide an additional privacy notice to you that describes the purposes for which we will use the personal information and our legal basis for doing so. 

Sharing your personal information

We do not sell any personal information that we collect about you. We do not disclose any personal information about our current or former clients to anyone, except as described in this notice, as permitted by contract or law and subject to confidentiality obligations that apply in certain jurisdictions.

We may disclose or share personal information about our customers to our affiliates, as permitted by law, for our affiliates to provide services.  We also may share your personal information with service providers that perform services on our behalf, such as hosting providers and advisers.  All service providers have entered into legally binding agreements requiring them to use or disclose personal information only as necessary to perform services on our behalf or comply with applicable legal requirements.  We may share personal information with our affiliates and service providers for a number of reasons, including:

  • You have requested information about our affiliates’ products and services; and
  • We rely on services provided by our affiliates and service providers to provide you with the services you require.

In addition, we may disclose your personal information (i) at the request of a bank or other regulatory agency or in connection with an examination of us by bank or other examiners, (ii) to our internal or external auditors or attorneys, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (iv) if we are required or permitted to do so by law or legal process, for example due to a court order or a request from a law enforcement agency, (v) if disclosure is necessary to protect the vital interests of a person, or (vi) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

How we transfer and store personal information

BBH is a global organization; personal information we collect may be transferred internationally throughout the world to countries where we do business, which may not have the same data protection laws as the country in which you reside. We have internal policies and procedures in place to achieve an equivalent level of protection in place across our organization. The transfer of personal information to other countries is based on a business need or to comply with applicable laws. Personal information stored or processed in a foreign jurisdiction may be accessed under a lawful order made in that jurisdiction.

If you are in the European Economic Area (“EEA”), we will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries outside of the EEA and Switzerland. In all such cases, we will only transfer your personal information if:

  • The country to which the personal information will be transferred to has been granted a European Commission adequacy decision;
  • The recipient of the personal information is located in the U.S. and has certified to the EU-U.S. Privacy Shield Framework;
  • We have put in place appropriate safeguards in respect of the transfer, for example the EU Model Clauses; 
  • The recipient of the personal information has adopted Binding Corporate Rules in relation to the personal information transferred; or
  • The transfer is otherwise authorized by applicable legal requirements.

You may request a copy of the safeguards that we have put in place in respect of transfers of personal information by contacting us as described in the How to Contact Us section below.

How long we keep personal information

The time period for which we keep personal information depends on the purpose for which we collect it.  In all cases we keep it for as long as is necessary to fulfil the purposes for which we collected it.  We will then delete or anonymize the personal information, unless we are legally required to retain it or if we need to retain it in order to comply with our legal obligations (for example, for tax and accounting purposes).

Subject to any applicable legal requirements, we typically retain personal information as follows:

  • Personal information you provide to us through our Site: we keep this personal information for as long as necessary to respond to your request, and for a short further period in the event that you send us further requests.
  • Personal information you provide when you sign up to receive direct marketing communications: we keep most of this personal information for the duration of our relationship with you until you opt out or we do not have any contact with you for a long period of time.
  • Personal information collected for analytics purposes: we keep this personal information for a short period of time necessary for us to carry out the analytics. We anonymize or aggregate personal information used for analytics once it is no longer required.
  • Website logs: we keep Site audit logs, which may contain your personal information, for several months.

Your rights 

As a person who provides us with personal information, you may inquire as to the nature of the personal information stored at and/or processed by us. You will be provided reasonable access to your personal information held by us and, where appropriate, with the ability to review and correct inaccuracies. We will cooperate in providing such access. All such requests for access may be made by sending a request in writing to: DPO@bbh.com.

If you are in the EEA or Switzerland, you may have the following rights in relation to your personal information that we hold about you:

  • To request confirmation of whether we process personal information relating to you and, if so, to request a copy of that personal information;
  • To request that we rectify or update your personal information that is inaccurate, incomplete or outdated;
  • To request that we erase your personal information in certain circumstances, such as where we collected personal information on the basis of your consent and you withdraw your consent;
  • To request that we restrict the use of your personal information in certain circumstances, such as while we consider another request that you have submitted, for example as a request that we update your personal information;
  • Where you have given us consent to process your personal information, to withdraw your consent; and
  • To request that we provide a copy of your personal information to you in a structured, commonly used and machine-readable format in certain circumstances. 

To help protect your privacy and provide security, we may take reasonable steps to verify your identity before we satisfy your request. We shall respond to such reasonable request made by you within such time period as required under applicable law after your identity has been confirmed.

You also have the right to lodge a complaint with the data protection supervisory authority in your country.

Children’s Privacy

We recognize the need to provide particular privacy protections with respect to personal information that may be collected from children.  This Site and Services are not aimed at or intended for children. 

Effective date and notice changes

Each time you use this Site or otherwise interact with us, the current version of the Privacy and Cookie Notice will apply. This notice is subject to change from time to time. Unless stated otherwise, our current Privacy and Cookie Notice applies to all information that we have about you. We will not materially change our policies and practices to make them less protective of your privacy without your consent.

How to contact us

If you have questions or comments about this Privacy and Cookie Notice, or about how your personal information is processed you may contact us:

By email at: DPO@bbh.com

In writing at:

BBH Luxembourg Funds
Attention: Data Protection Inquiries
6, route de Trèves,  L-2633 Senningerberg, Luxembourg