EMEA online privacy notice

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 and similar technologies 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 “information about you”;

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

“Invesco”, “our”, “us” and “we” mean Invesco; and

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

What is the purpose of this Online Privacy Notice and Cookies Policy?

This Online Privacy Notice and Cookies Policy tells 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 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 and web services. 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. 
• Your audience type: we have created certain pages on our website specifically for certain types of audience. By letting us know what type of audience you are (Private Investor or Professional Client (Financial Adviser or Institutional Investor)) we can show you pages that are most relevant to that audience type. You can always change your audience type using the links at the top of each page of our website. 
• 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, company and Invesco account information. 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 and if they are not strictly necessary to operate our website, we will only use them where you have consented to us placing these on your computer or other device. These cookies and tags 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 manage your cookie settings, 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 (e.g. 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 Ads product). For more information on the use of cookies on our website, please see our Cookies Policy below.

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 below.

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 collect online and on which legal bases we rely. Our legal bases for collecting and using your personal data will include:

1. to perform our contract with you such as (i) servicing your online account or (ii) providing you with our online valuation service;
2. 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 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);
3. to comply with our legal obligations laid down in laws applicable to us; and
4. in some circumstances and subject to applicable laws, we will process your personal data where we have obtained your consent. 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, 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.

How do we use another person's personal data you have provided?

Using our Email page tool, you will be able to send links to site content to another person, by providing their name, audience type, company name (if relevant) and email address. We will not use this information for any purpose other than sending the links you request. You should always get permission before providing someone else's details to us.

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 them to provide and administer the webchat function on our website, to drop cookies and perform analytics on our website (please see the Cookie 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 collect 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;
• credit reference agencies;
• other entities within Invesco Ltd’s group companies; and
• your financial advisor or other intermediaries.

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 or any of our website services.

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 of the UK or 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 (or e.g. by relevant bodies or applicable laws in the UK or in other countries outside of the EEA). 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 in accordance with the Law. You can obtain a copy of the standard data protection clauses at https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en and contact us by using the contact details provided below for further information about other appropriate transfer mechanisms we may rely on.

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.

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 your local supervisory authority about our use of your personal data including in the UK or the appropriate 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 or the UK 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.

How 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 a variety of leading administrative, physical, and technical security measures to help safeguard your personal information. You can learn more about how Invesco keeps your data safe by reading our article Keeping safe online with Invesco. 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.

Sharing of Your Personal Data (Disclosure and Transfer)

Using our Email page tool, you will be able to send links to site content to another person, by providing their name, audience type, company name (if relevant) and email address. We will not use this information for any purpose other than sending the links you request. You should always get permission before providing someone else's details to us.

Disclosure of your personal data

Depending on the Online Services provided, we may share your personal information with different parties.

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 may also use other third parties to process your personal data on our behalf. For example, we may use them to provide and administer the webchat function on our website, or to drop cookies and perform analytics on our website (please see the Cookie Notice 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 collect online, for the purposes set out in this Online Privacy Notice 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;
• credit reference agencies;
• other entities within Invesco Ltd.’s group companies; and
• your financial advisor or other intermediaries.

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 services.

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.

Transfer of your personal data

As we operate globally, your personal data may be transferred to countries outside the UK, European Economic Area (EEA) or Switzerland, or outside any other country from where you may access our website, for example, to the United States, Canada, India, and Hong Kong. Where the level of protection of personal data in those countries has not been deemed adequate by the European Commission (or e.g. by relevant bodies or applicable laws in the UK or in other countries outside the EEA), we will enter into a data transfer agreement with the data recipient incorporating the standard contractual clauses published by the European Commission (found at this link) (and/or any other applicable model clauses in other jurisdictions, including the UK Addendum to the standard contractual clauses published by the UK Information Commissioner's Office (found at this link). Some of the third parties engaged by us may rely on other transfer mechanisms (e.g. binding corporate rules) to provide appropriate safeguards to ensure that your personal data will remain adequately protected in accordance with applicable data protection laws.

When we need to transfer your data, we will ensure that your personal data is transferred, processed, and maintained to the standards required by Law.

You can contact us by using the contact details provided below for further information about other appropriate transfer mechanisms we may rely on.

Data Retention

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 type of personal data, type of services provided, 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.

We may be required to retain certain data for the purposes of tax reporting or responding to tax queries. In other instances, there may be some other legal or risk management requirements to retain data (including legal requirements that may require us to retain it for certain minimum periods), including where certain data might be relevant to any potential litigation.

Your Rights

Subject to the conditions prescribed in applicable Laws, in relation to the personal data we hold about you, you have the right:

• to be informed about the collection and processing of your personal data;
• to access or request a copy of your personal data that we have collected;
• to rectify or request erasure of your personal data;
• to ask us to restrict processing of it; and
• to request portability of it.

If we have obtained your consent to process your personal data, 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, and you will have the right to withdraw your consent at any time. The withdrawal of your consent will not affect the lawfulness of processing based on your consent before its withdrawal.

Subject to the conditions prescribed in applicable Laws, in relation to the personal data we hold about you, you have the right:

• 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
• 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. We will respond to your request consistent with applicable Law. To protect your privacy and security, we may require you to verify your identity.

You also have the right to lodge a complaint with a supervisory authority about our use of your personal data in the applicable jurisdiction 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 Law.

Using Invesco websites in an anonymised or pseudonymised manner

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

Children’s Privacy

We are committed to protecting the privacy of children. Our Online Services are not intended for children under the age of 18.

Contact

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

Global Privacy Office
Invesco Asset Management Limited
Perpetual Park
Perpetual Park Drive
Henley-On-Thames
RG9 1HH
United Kingdom

Revisions to this Online Privacy Notice

This Online Privacy Notice was last updated on 21/02/2024. We reserve the right to revise this Online Privacy Notice at any time by posting a revised version of it online.

Issuing Companies

Invesco Ltd.’s group of companies and investment funds managed by members of the Invesco Group are each controllers of your personal data under applicable data protection Laws. We, as controllers, determine why and how we collect and use your personal data. You can find the complete list of these issuing companies in our Terms & Conditions under the Site Issuers section.