Online Privacy Notice and Cookies Policy

Introduction and definitions
Thank you for visiting our website and for using our services.  We’d like to tell you about our online privacy notice and how we use cookies on our website.  We have defined some words and phrases to help make it clear what we mean.

In this Online Privacy Notice and Cookie Policy:

“personal data” means personal data as defined under the Law and includes any information about an identified or identifiable natural person.  Such information may include, for example, information we collect against an identifier for you (for example, your IP address or cookie ID). We also refer to personal data as “data about yourself”, “personal information”, “your information”, “personal details” and “information about you”;

“controller” means controller as defined in applicable data protection legislation;

“Invesco”, “ “our”, “us” and “we” means  “Invesco UK Services Limited” and “Invesco Asset Management Limited”;

“the Law” means applicable data protection legislation, including (where applicable) the General Data Protection Regulation (“GDPR”).

What is the purpose of this Online Privacy Notice and Cookies Policy?
This Online Privacy Notice and Cookie Policy tell you how we will process any personal data that we collect from you, or that you provide to us online.  The Law says we must provide you with this information and we hope this will help you to understand how we will keep your personal data safe.  You can find more information about how we process your personal data in our privacy notice here which also applies to the use of personal data we collect offline.  

Who are we? 
We are the controllers of your personal data and, as controllers, determine why and how we collect and use your personal data. We are committed to protecting your privacy and personal data as you use our website. We take seriously our responsibility to hold your personal data securely and confidentially. 

What kind of personal data do we collect about you and how?
Depending on your interaction with our website, we collect the following categories of personal data from you:
  • For certain services (such as email updates), we need to be able to identify who you are. To do this we will ask you to register to our website by providing your name and email address, and then we will ask you to create a password. If you ask us for information by post, we will also ask you to provide your postal address. Once you have registered with our website, we will link all of the personal data we collect about you via the website, and what we may know about you offline as an investor, to your registration   ;
  • If you use the online email or the online chat facilities, you may choose to give us your personal data and we will also ask you to provide us with certain personal data such as your name, business email address, job title and company We may need to ask you for additional personal data to help us to meet your needs and to provide you with the services you require. If you do not provide your personal data to us, it may make it impossible for us to provide these services to you;
  • We use cookies on our website that are more than strictly necessary, however we will only do so where you have consented to us placing these on your computer or other device. These cookies collect data about your use of the website including how you arrived at our website, which pages you click on and where you scroll on the page, the country from which you are accessing the website, which website you go to when you leave our website and your activity on other third-party websites. This information is linked to a unique cookie ID number which is provided to you when you visit our website or to your IP address. For more information on the cookies we use and what information is collected, together with information on how to accept, delete or block cookies, please see our Cookies Policy below. 
As we have described above, we use cookies on our website. Some of these cookies collect personal data about you, including data you have provided to us, for example your email address, as well as information about your website activity (pages you visit, how you scroll through the page and what you click on) both on our website and on third-party websites. With this information, we allocate you to a particular profile. We then show adverts for products and services that we think are most interesting to that profile. This targeting of advertising is an automated process using Google Retargeting (part of the Google AdWords product). For more information on the use of cookies on our website, please see our Cookies Policy below.
We may collect, process, use and store your personal data electronically or on paper and in written or digital formats. We collect, process and use your personal data with automated tools. 

Do we collect personal data about you from third parties?

We may also collect your personal data from third parties, for example (i) from publicly accessible sources, including publicly available online profiles and databases e.g. to establish and verify your identity, to find out your contact details or to liaise with you in relation to our products and services, or (ii) by using third party cookies. Please find more information about how we use third party cookies in our Cookies Policy.  

How do we protect your personal data?
We maintain strict security standards and procedures with a view to preventing unauthorised access to your personal data by anyone, including our staff. We use leading technologies such as (but not limited to) data encryption, firewalls and server authentication to protect the security of your personal data. The staff of Invesco follow strict privacy standards and whenever we hire third parties to provide support services, we require them to observe the same standards and to allow us to audit them for compliance.

How will we use your personal data we collect online?
This section of this Online Privacy Notice and Cookies Policy explains for what purposes we use your personal data we collected online and on which legal bases we rely. Our legal bases for collecting and using your personal data will include
a) to perform our contract with you such as servicing your account; 
b) to pursue our legitimate interests which do not override your interests or fundamental rights and freedoms, such as (i) improving our services to you and other website users and developing new products; (ii) providing information to you about our services and products or anything else (e.g. additional products and services) that we think may be of interest to you (this information may be provided to you in the form of a digital advertisement or via email), and we may identify which products or services we think you are interested in by using cookies on our website which track and analyse how you use our website; and (iii) processing your personal data for administration, assessment and analysis purposes (for example, marketing and product analysis and behaviour scoring);   
c) to comply with our legal obligations laid down in laws applicable to us; and
d) in some circumstances and subject to applicable laws, we will process your personal data where we have obtained your consent, for example to send you direct marketing via email or to process your personal data we have collected by using cookies. However, we will make it clear to you at the time of collection of your personal data that we are relying on your consent to process your personal data for those purposes, and you will have the right to withdraw your consent at any time. The withdrawal of your consent shall not affect the lawfulness of processing based on your consent before its withdrawal. For example, if you change your mind and would like us to stop sending direct marketing to you via email, we tell you in each email how to unsubscribe. You can also unsubscribe by contacting us at invest@invesco.com.
 
For how long do we keep your personal data?
We only keep your personal data for as long as is necessary to fulfil the purposes for which it has been collected. When determining the appropriate retention period, we consider the risks of the processing, our contractual, legal and regulatory obligations, internal data retention policies and our legitimate business interests as described in this Online Privacy Notice and Cookies Policy.
 
Who do we share your personal data with?
Where we send direct marketing materials to you, we may send your personal data to third parties with whom we have contracted to provide these materials to you on our behalf and in our name. These third parties act as our processors in relation to their processing of your personal data in this way.  
 
We also use other third parties to process your personal data on our behalf. For example, we use Salesforce to provide and administer the webchat function on our website and we use HubSpot to store and analyse personal data, and third parties to drop cookies and perform analytics on our website (please see the Cookies Policy below for further information about our use of cookies). When we use third party processors, we ensure they process your personal data in accordance with our instructions and that they put appropriate technical and organisational security measures in place to adequately protect your personal data.
 
In certain circumstances, we may also share your personal data we collected online, for the purposes set out in this Online Privacy Notice and Cookies Policy, with other third parties such as:
 
  • service providers (e.g. data analysis or web-hosting firms, other information technology service providers), who provide a service to us or you, their service providers, delegates and agents; and other entities within Invesco Ltd’s group of companies.
 
We also may disclose your personal data to courts, the police, or other law enforcement agencies where we are legally obliged to do so or in our reasonable opinion such disclosure is necessary to comply with applicable laws and legal processes, support an investigation or to protect our rights and interests in relation to any suspected misuse by you of our website. 
 
We endeavour to prevent unauthorised disclosures of your personal data by other people, but we are not responsible for any unauthorised disclosures or other breaches of security or for the actions of others if the personal data was passed to them with your authority or with the authority of anybody other than us or our affiliates.
 
We may also share your personal data with a potential buyer in connection with any proposed purchase, merger or acquisition of any part of our business.
 
Where is your personal data transferred?
When we share your personal data with the organisations listed above, it may involve transferring your personal data outside the European Economic Area (EEA) or outside any other country from where you may access our website, to countries where the level of protection of personal data has not been deemed adequate by the European Commission. The absence of an adequacy decision means that the laws of these countries may not guarantee the adequate level protection of your personal data as defined by the Law. However, we will ensure that your personal data is transferred, processed and maintained to the standards required by Law by putting standard data protection clauses in place (as approved by the European Commission) or where we use third parties, we may rely on other appropriate transfer mechanisms they have implemented (e.g. EU-US Privacy Shield, binding corporate rules). Please contact us using the contact details provided below to obtain a copy of our standard data protection clauses or further information about other appropriate transfer mechanisms we may rely on. For example, we transfer your personal data to the United States for analysis purposes by employing the Google Analytics technologies. The personal data transferred to Google is protected under the terms of their EU-US Privacy Shield Certification (for more information see here: https://www.privacyshield.gov/Individuals-in-Europe). We also transfer your personal data to the United States to HubSpot (HubSpot, Inc. First Street, 2nd Floor, Cambridge, MA 02141 USA.) for storage purposes.
 

What are your rights in relation to the personal data we hold about you?

Subject to the conditions prescribed in applicable laws, you have the right: (i) to access, rectify or request erasure of your personal data; (ii) to ask us to restrict processing of it; (iii) to request portability of it, and (iv) not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

Subject to the conditions prescribed in applicable laws, you have the right (i) to object, on grounds relating to your particular situation, to processing of your personal data which is based on our or a third party’s legitimate interests; and (ii) to object to processing of your personal data for direct marketing purposes. 

You can exercise these rights by contacting us using the contact details provided below. 

You also have the right to lodge a complaint with a supervisory authority about our use of your personal data in the EU Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes the GDPR. 

Can I use the website in an anonymised or pseudonymised manner? 

In accordance with applicable data protection legislation, you may choose to use the website in an anonymised or pseudonymized manner. This applies only to the extent that anonymous or pseudonymized use of the website is technically possible and reasonable.

Our Cookies Policy 

How will your site recognise who I am?

When you access our site for the first time, we will place a 'cookie' on your computer. Cookies are small text files placed on your computer and are commonly used on the internet by many websites to store information on their users' computers. Cookies only contain information relating to the website that created them, and can only return the information to that website. In other words, our site cannot read the information contained in cookies created by anyone else's website on your computer. Similarly, only our site can read the information in cookies that it creates. Cookies cannot be used to get or view data from your hard drive.

 

What purposes are cookies used for?
By consenting to the use of cookies on our website you acknowledge and agree that we may (i) track and record information for systems, marketing, trouble shooting, administrative, analysis and reporting purposes, and (ii) use your personal data for the following purposes: 
  • track and record the aggregate number of visitors to the website and the sections of the site visited by visitors using cookies; 
  • operate our website, for example by directing you to the right area depending on what country you have selected.  We call these cookies “strictly necessary”;
  • analyse our website, for example to collect information that will help us understand visitors' browsing habits on our website;
  • compile statistical reports on website activity, e.g. number of visitors and the pages they visit;
  • improve the functionality of our website by temporarily storing any information which you may enter in tools, such as calculators or demonstrations on our website; in some cases, remember information about you when you visit our site. We may need to do this to provide some of our services; and
  • record your visit to our website, the pages you have visited and the links you have followed.  We use this information to make our website more relevant to your interests and identify products or services that may be of interest to you.  We may also share this information with third parties for these purposes.

We use two types of cookies:

Session cookies: These are temporary and are deleted as soon as you close your browser; and

Persistent cookies: These are stored on your computer until they expire or you remove them. Persistent cookies store your personal preferences such as your language preferences on multi-lingual sites to make subsequent visits easier. They also remember questions we have asked you previously, such as a request to complete an online survey.

You can find more information about the individual cookies we use, when they expire and the purposes for which we use them in the table below:
 

Country
Expires: session only.

Used to pre-populate user country on the landing page

This cookie is used to predict the country that a user of our website is from and it pre-populates the country location field that appears when users first access our website.

We collect this data on the very first page of our website. We only collect this once.

We use this data to improve the user experience of the website (this means users do not have to search for their country if the information is available from their IP address)

Drupal.visitor.user-language
Expires: 3 months

Tracking of language selected by user

This cookie remembers the language the user selects when they come into our website.

We collect this data the first time the user comes to our website.

We use this data to improve the user experience of the website (this prevents a returning user from having to reselect their language choice each time they enter our website).

Drupal.visitor.user-type
Expires: 3 months
Tracking of investor type (private or professional)

This cookie remembers the user type the user selects when they first some to the website. They either select Private Investor or Professional Investor. The cookie remembers which one they selected.

We collect this data the first time the visitor comes to our website.

We use this data to improve the user experience of the website (this prevents a returning user from having to reselect their user type (Professional Investor/Private Investor) each time they enter our website).

Cookies set by Snap Engage (Chat):
SnapABugRef
Expires: 120 min

This cookie tracks the country the user is from (best prediction) and also what page on our website the user hits the chat button.

We only collect data using this cookie when a user who has stated that they are a Professional Investor clicks the "online chat" button.

We use this data to enable web chat to function - This helps us route the chat to the right chat operator with the correct language skills. For example we route French visitors to a chat operator fluent in French. This cookie is also used for regulatory compliance purposes as it allows the chat operator to ensure we are not selling to an investor claiming to be in Europe that is actually based in, for example, the USA.

SnapABugChatSession
Expires: 16 min

This cookie tracks a live chat that is in progress.

We only use this cookie when a user who has selected they are a Professional Investor clicks the "online chat" button.

This allows a chat to continue when the user starts to browse different pages on the website whilst they are having a live chat with us.

SnapABugNoProactiveChat
Expires: 30 min (but to be configurable)

This cookie is used once we have proactively approached a user and asked them "do you want to livechat with us", if they say “no”, this cookie ensures this will not happen again.

We use this cookie on the Product Page when we proactively approach a user for the first time.

This data enables web chat to function and avoids prompting a user to chat when they have finished a chat / declined to chat earlier in that session.

SnapABugChatPoll
Expires: 16 min

This cookie tracks web chats in progress and the transcript position

We use this cookie when a user engages in web chats with one of our chat operators .

This data enables web chat to function.

SnapABugChatMessage
Expires: 16 min

This cookie tracks the message type by user persistence across pages

We use this cookie when a user engages in web chat with a chat operator at Source.

This data enables web chat to function.

SnapABugChatView
Expires: 16 min

This cookie checks logic handling - needed to run web chats

We use this cookie when a user engages in web chat with a chat operator at Source.

This data enables web chat to function.

SnapABugHistory
Expires: 1 year

This cookie keeps track of the user visits and previous chats to present history to agent

We use this cookie when a visitor engages in web chat with a chat operator at Source.

This data is used to provide a better user experience as we will be able to review your chat history and previous visits to our website.

SnapABugVisit
Expires: session only

This cookie detects the start of a new session

We use this cookie when a user engages in web chat with a chat operator at Source.

This data enables web chat to function.

SnapABugUserEmail
Expires: 1 year

This cookie remembers a user’s email address and pre-populates this address in the pre-chat window

We use this cookie on the web chat function. If the user gives us their email address we will store this.

This information

is stored in our client relationship management database so that we can help you with the query you raise with us using the chat window and to keep a record of the action we took to resolve your query. Where we collect your email address using this cookie we will not add your email address to any direct marketing lists.

SnapABugBanned
Expires: 30 days

This cookie keeps track of any users banned from web chatting

We use this cookie on pages of our website used by Professional Investors.

This data enables web chat to function and prevents a web chat window being opened with banned users (e.g. by visitors blocked by Source web chat team)

Cookies set by HubSpot:
__hstc
Expires: 2 years

This cookie is the main cookie for tracking users on our website. It contains: the domain, utk (see below), initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session)

We use this cookie when users first come to our website.

This data is matched with incoming user information to the HubSpot database (please see the row below for further information on the purpose for which we use the Hubspt database)

hubspotutk
Expires: 10 years

This cookie is used to keep track of a user’s identity by giving the user a unique ID (ID44692, for example)

We use this cookie when a user first enters the website and when the user fills out a web form.

We pass data collected using this cookie to HubSpot on form submission and use this data when deduplicating contacts. This cookie does not store personal data.

__hssc
Expires: 30 min

This cookie keeps track of sessions (number of visits to the Source website).

We use this cookie on site entry.

This data is used to determine if we should increment the session number and timestamps in the hstc cookie. It contains: the domain, viewCount (increments each pageView in a session), session start timestamp.

__hssrc
Expires: None. Session cookie

Whenever HubSpot changes the session cookie, this cookie is also set.

We use this cookie on site entry.

We use this data to determine if a user of our website has restarted their browser. We set it simply to the value "1", and use it to determine if the user has restarted their browser. If this cookie does not exist when we manage cookies, we assume it is a new session.

GOOGLE _ga
Expires: 2 years

This cookie uses a client ID, to distinguish users.

We use this cookie on site entry.

We use this data to help to confirm returning/unique users.

GOOGLE _gat
Expires: 10 min

This cookie is used to throttle request rate.

We use this cookie on site entry.

This cookie does not store any personal data, it's just used to limit the number of requests that have to be made to doubleclick.net.

Drupal: has_js
Expires: session only

This cookie is used to check if Javascript is enabled on the user’s system. This cookie indicates if the user’s browser supports Javascript

We use this cookie on site entry.

We use this data as part of our content management system, which needs this to serve web content (such as the performance charts on the product pages).

Third party cookies

We work with third parties who, on our behalf, research the use of our website and activities on it. In doing so they may place a cookie on your computer. However, it would not contain any personal data in a format that can be read by anyone else.

We also work with third parties to evaluate the effectiveness of our advertising and promotions on third party websites. Again, the cookie would not contain any personal data in a format that can be read by anyone else.

Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Accepting or rejecting cookies

You can refuse, accept or remove cookies at any time by using the settings on your internet browser. You can configure your internet browser to warn you each time a new cookie is about to be stored on your computer so that you can decide whether to accept or reject it. Please refer to your internet browser's help section for further information. Please note that some parts of our website may not function properly if you reject cookies.

Use of Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc. (Google). Google Analytics uses cookies, which are text files stored on your computer or mobile phone to help analyse how the website is used by you. As a rule, the information generated by the cookie about your use of the website is transmitted to and stored by Google on a server in the United States. If IP anonymisation is activated on this website, however, your IP address will be truncated by Google in Member States of the European Union or in other states party to the Agreement on the European Economic Area prior to transmission. Only in exceptional cases will the complete IP address be transmitted to a Google server in the United States and truncated there. Google will use this information on behalf of the operator of this website for the purpose of evaluating your use of the website, compiling website activity reports and providing other services to us relating to the use of this website.

The IP address transmitted by your browser within the scope of Google Analytics will not be associated with any other data held by Google.

You can prevent the storage of cookies by selecting the appropriate settings of your browser software; however, please note that if you do this, you may not be able to use the full functionality of this website.

You can also prevent the data (including your IP address) generated by the cookie relating to your use of this website from being collected and processed by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

This website uses Google Analytics with the extension "_anonymizeIp()". This means that only truncated IP addresses will be further processed so as to prevent them from being linked to a specific user.

The use of Google Analytics is made in line with the requirements agreed between the German data protection authorities and Google. Third-party provider information: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Terms of Service: http://www.google.com/analytics/terms/de.html, Overview - Safeguarding your data: http://www.google.com/intl/de/analytics/learn/privacy.html and Privacy Policy: http://www.google.de/intl/de/policies/privacy

 

Use of HubSpot

We use the web analytics technology of HubSpot to enable a statistical analysis of how this website is used by visitors. Such data are used to continuously improve the website, our service and make it more user-friendly. If you do not consent to such use, please untick this box .

For this purpose HubSpot creates pseudonymized user profiles to form the basis for statistics. You may at any time object with future effect to the creation of pseudonymized user profiles by unticking the box above.

You will only be personally identifiable once you fill out our contact form on the website. In this case only, we link the analytic data collected, processed or used via HubSpot to your personal data. You may at any time object with future effect to the matching of your pseudonymized user profiles with your personal data by unticking the box above.

Revisions to this Online Privacy Notice and Cookies Policy 
This policy was updated on 24 May 2018. We reserve the right to revise this policy at any time by posting a revised Online Privacy Notice and Cookies Policy online. 

How can you contact us?
If you have any questions about this Online Privacy Notice and Cookies Policy, please contact us via email at emea.privacy@invesco.com, or in writing at the addresses provided below:

Invesco Asset Management Limited
Perpetual Park
Perpetual Park Drive
Henley-On-Thames
RG9 1HH

Invesco UK Services Limited,
Perpetual Park
Perpetual Park Drive
Henley-On-Thames
RG9 1HH

Issued and approved in the United Kingdom by Invesco UK Services Limited and Invesco Asset Management Limited, both authorised and regulated by the Financial Conduct Authority.

© 2018 Invesco UK Services Limited. All rights reserved.