Our aim is to be transparent about how we deal with personal data. This privacy statement details how AAM PE, other entities in Aegon Asset Management, appointed suppliers and the Aegon group of companies process your personal data.
Protecting your personal data
At AAM PE we are committed to protecting and respecting your privacy. Our aim is to be transparent about how we deal with personal data. This privacy statement details how AAM PE, other entities in Aegon Asset Management, appointed suppliers and the Aegon group of companies process your personal data.You can print this privacy statement by right-clicking on the page and selecting 'Print'.
This privacy statement is applicable to the processing by AAM PE of all personal data such as but not exclusively of (potential) customers, suppliers and business partners as well as visitors of our websites.
Controller for the processing of your personal data
Aegon Asset Management Pan-Europe B.V., with branches located in Frankfurt and Madrid, is the controller or joint controller for the processing of all personal data within the scope of this privacy statement. The applicable data controller location will be based on which branch you initially provided your personal data to and/or maintain your service relationship with. We are part of Aegon Asset Management, the asset management arm of Aegon, a global life insurance, pensions and asset management company.
If you have any questions about this privacy statement or the information we collect about you, please contact our Data Protection Officer:
Email Data Protection Officer: firstname.lastname@example.org
Aegon Asset Management Pan-Europe B.V.
Neue Mainzer Strasse 66-68
60311 Frankfurt am Main
Aegon Asset Management Pan-Europe B.V.
Vía de los Poblados 3, 28033
How we handle your privacy
You or someone representing you, for example a financial advisor, an employer or the business you work for, may give us information about you by completing forms (paper versions or through a website), concluding contractual arrangements or by contacting us by phone, email or otherwise. We may also receive your personal information from a third party where they have obtained your consent to share such information. Alternatively you will have provided the information to us directly.
For the processing activities described below, the personal data that is gathered and processed may include, but is not limited to:
- Full name
- Address including post code
- Phone number
- E-mail address (personal and/or business)
- Aegon account number or other Aegon identifier, whether for internal or external use
- Cookie information collected when you visit one of our websites. Further information is available in our cookie statement.
Where sensitive personal data is collected and processed as part of any of the activities below, this will be stated in the relevant processing descriptions. Sensitive personal data processed may include the following:
- Copy of identification document (i.e. passport or ID card)
When collecting and processing personal data, AAM PE will only process the minimum amount of personal data relevant to the specific purpose it is collected for. AAM PE will only use the data in-line with the original purpose (stated below) or a further purpose deemed sufficiently similar and likely to be in line with your expectations.
You can find additional information on the most common activities that we conduct which involve the collecting and processing of personal data and why below:
This will include Anti-Money Laundering checks as well as screening personal data against known sanctions and politically exposed persons ("PEP") lists. This processing may require the collecting and sharing of (sensitive) personal data including copies of identification documents, with other entities within Aegon Asset Management, appointed suppliers and the Aegon group of companies. Data may also need to be shared with supervisory authorities in certain circumstances. More information can be found in the section titled 'Sharing your personal data'.
This processing is conducted in order to detect and prevent financial crime. It is also necessary in order for us to meet our legal and regulatory obligations as a company. In the event of other checks these will be conducted in order to provide a requested service. We conduct screening checks automatically using a third party system provided by FinScan which compares personal data against a number of official sanctions and PEP lists. The results of this check will be considered by a member of our staff in determining whether we can proceed with conducting business/providing a service or not.
This includes managing existing and prospective customer relationships, handling complaints, managing any incidents/issues encountered, detecting fraud, sharing client reporting and providing online services including our websites. This processing is required in order for us to provide the service requested by yourself. Some of the processing will be based on a legal obligation. We may communicate with prospects and customers by phone, mail, e-mail and fax where appropriate.
This includes reviewing our existing offering of products and services, making required improvements and launching new products/services. Personal data may also be processed when we develop our appropriate business strategies and systems internally. Where these processes include personal information they are conducted in the legitimate interest of AAM PE to ensure we provide the best products and services for our customers. We are committed to ensuring that the impact to the data subjects involved is minimal, the approach adopted is reasonable and we will ensure that the least intrusive approach is followed. The data may be shared with other entities within the Aegon group of companies. More information can be found in the section titled 'Sharing your personal data'.
Please note that all investment products are provided by one of our affiliated Aegon Asset Management companies, including the brands of Kames Capital and TKP Investments, and not AAM PE itself.
Personal data will be processed in order to obtain services provided by a third party company, to manage the relationship between the companies (including where they act as our data processor) and reporting and performance analysis on these relationships. These processes may also require sharing personal information with other entities within Aegon Asset Management and the Aegon group of companies as well as consulting publicly available records. These processes are conducted to ensure appropriate execution of the service agreed between the parties and between us and our customers, as well as being in the legitimate interests of AAM PE and other Aegon Asset Management companies to be able to utilise third party services when providing its products and services to customers in the best way possible. More information can be found in the section titled 'Sharing your personal data'.
Aegon Asset Management companies assist in providing legal and regulatory support and advice (both internal and external), internal auditing, strategy development and providing and maintaining IT solutions. These processes are conducted in order to execute activities vital to the internal management and improvement of our business and are imperative to the performance of our services and agreements with prospects and suppliers. Some of these processes are also conducted in order to fulfil a legal or regulatory obligation. Personal data may be shared with other entities within the Aegon group of companies, including Aegon Global Technology who will act as a data processor of any personal data handled when providing IT and technology solutions. Personal data may also be shared with third parties including external law firms, accountants and auditors.
More information can be found in the section titled 'Sharing your personal data'.
This includes responding to requests and providing regular and ad hoc reporting. These processes are conducted in order to fulfil a legal and regulatory obligation of the company. Where personal data, including sensitive personal data, needs to be processed in order to fulfil these obligations it will be in line with this privacy statement including when processing involves third parties and entities within the Aegon group of companies.
More information can be found in the section titled 'Sharing your personal data'.
This will include the execution and analysis of marketing campaigns and strategies, promoting products and services provided by affiliated Aegon Asset Management companies including under the brands of Kames Capital and TKP Investments, running and contributing to promotional events and the use of ad hoc competitions and promotions.
We will ensure that we obtain the necessary consent in order to send you marketing information and news about our products and services that may be of interest to you, as well as invite you to relevant events. When running or contributing to promotional events we may need to collect personal information in relation dietary and access needs but this information will only be used for the purposes confirmed at the time of collection. Marketing communications will be conducted using various channels such as mail, phone and email.
Your personal data will only be shared with external third parties for marketing purposes where you have agreed to do so. We won't sell your personal information to other organisations for marketing purposes.
Please remember that you can withdraw your consent at any time by contacting us (see section 'Your Rights').
The withdrawal of consent to specific processing of personal data, including for the purposes of marketing, does not affect the processing based on consent before the withdrawal. It will also not affect the provision of any other products and services or the processing of personal data unrelated to the process for which you have withdrawn consent.
We may conduct marketing related analytics which may include the processing of personal data based on our legitimate interest to ensure we provide customers with appropriate marketing information that is relevant to them. When doing this we will ensure that aggregated information is used where possible and where personal data is processed the least intrusive method is used and that we feel the recipient would reasonably expect this type of processing. Data subjects may object to this at any time by contacting us.
Sharing your personal data within the Aegon group
As a global organization, personal data we collect may be transferred internationally throughout Aegon's worldwide organization. Your personal data will be exchanged within the Aegon group of companies (meaning all subsidiaries and affiliates of Aegon N.V.), including the Aegon Asset Management group (the entities within the Aegon group that are responsible for asset management activities) including Kames Capital PLC, Aegon Investment Management B.V. (including where trading as TKP Investments), Aegon Magyarország Befektetési Alapkezelő Zártkörűen Működő Részvénytársaság (Aegon Asset Management Central and Eastern Europe), Aegon Asset Management (Asia) Limited, Aegon USA Investment Management LLC, , Aegon USA Realty Advisors LLC and Aegon Asset Management Value Hub B.V.
We share your data for the purposes mentioned in the 'how and why we obtain personal information about you' section and to have a complete overview of our contacts and contracts within the Aegon group. We may also share your data in order to offer you a complete package of services and products. This will be handled in line with the description above on how we provide marketing to customers and prospects.
If your personal data is transferred within the Aegon group to a country where the local regulation does not reach the EU adequate level of protection of personal data AAM PE will take measures to ensure that your personal data is adequately protected, such as entering into EU standard Contractual Clauses with these parties.
AAM PE employees are authorized to access personal data only to the extent necessary to perform their job.
Sharing your personal data with third parties
We work with carefully selected providers that carry out certain functions on our behalf and cooperate with relevant authorities. The following types of third parties have or could be granted access to your personal data where relevant for the processing described above.
- Supervisory authorities – including Deutsche Bundesbank, Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin), Der Hessische Beauftragte für Datensschutz und Informationsfreiheit, Amtsgericht Frankfurt am Main, Industrie und Handelskammer Frankfurt am Main, Finanzamt Frankfurt am Main (Tax), Bundesagentur für Arbeit, Comisión Nacional Mercados de Valores, SEPBLAC (AML), Agencia Tributaria (Tax)
- Technology suppliers
- Client Relationship Management (CRM) tool providers – including SalesForce
- External legal counsel
- Mailing houses
When third parties are given access to your personal data, AAM PE will take the required contractual, technical and organizational measures to ensure that your personal data is only processed to the extent that such processing is necessary. The third parties will only process your personal data in accordance with applicable law.
If your personal data is transferred to a third party recipient in a country where the local regulation does not reach the EU adequate level of protection of personal data AAM PE will take measures to ensure that your personal data is adequately protected, such as entering into EU standard Contractual Clauses with these parties.
In other cases, your personal data will not be supplied to third parties, except:
- to the extent that we are required to do so by law, by a government body or by a law enforcement agency, or for crime prevention purposes (including financial crime protection and credit risk reduction);
- when protecting your interests or the interests of other individuals or for reasons of substantial public interest;
- in connection with any legal proceedings (including prospective legal proceedings);
- in order to establish or defend our legal rights;
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets and for the purposes of effecting any sale or purchase; or
- if we, or substantially all of our assets, are acquired by a third party, we may disclose your personal data to that third party in connection with the acquisition.
The use of your personal data by data processors
When a third party processes your personal data solely following our instructions, it acts as a data processor. We enter into an agreement with such a data processor concerning the processing of personal data. In this agreement we include obligations to safeguard that your personal data is solely provided to the data processor to provide specific services to us and the data is afforded a sufficient level of protection.
We will keep your personal information only as long as necessary to complete the processes mentioned in this statement including for 5 years following the conclusion of our relationship. This is to ensure that we comply with our retention obligations , as set out in our internal retention policy and determined by the appropriate supervisory authorities (including financial regulators) or other regulatory and legislative requirements.
In limited circumstances, we are required to keep some specific information for longer, for example in order to satisfy requirements in regards to Anti-Money Laundering, , but we regularly review the applicable retention obligations to ensure we keep personal data for the minimum time we are legally obliged to and delete information that is no longer required to be kept.
* The main legal obligations for the retention of information come from a number of laws applicable to our business as an Asset Management company, including but not limited to the Markets in Financial Instruments Directive.
We are committed to ensuring your information is protected and held securely. AAM PE has implemented functional, technical, physical and organizational safeguards to protect the personal data that we hold to minimize:
- Unauthorized access and alteration;
- Improper disclosure; and
- Accidental or unlawful destruction or loss.
We have information security policies, staff training and secure servers. All our employees and service providers who have access to personal information are obliged to protect it and keep it confidential.
In the event that a data breach results in there being a high risk to your personal rights and freedoms we will contact you in accordance with our data breach notification procedures.
You, as a data subject, have a number of rights including:
- the right to request a copy of the personal data we hold on you. (Example; when you request this information, this is known as making a Subject Access Request (SAR). In most cases, this will be free of charge, however in some limited circumstances, for example, repeated requests for further copies, we may apply an administration fee);
- the right to have any inaccurate personal data corrected;
- the right to have any out of date personal data deleted once there is no business need or legal requirement for us to hold it;
- the right to object or restrict some processing, in limited circumstances and only when we do not have legitimate grounds for processing your personal data;
- the right to object to your personal data being used to send you marketing material. As mentioned above, generally we will only send you marketing material where you have given us your consent to do so or where we believe there is a legitimate reason for doing so. You can withdraw your consent at any time;
- the right to have personal data that you provided us with transferred to another service provider in electronic form in certain scenarios; and
- the right to ask for a decision to be made manually, where a decision is made using automated means and this adversely impacts you.
To exercise any of these rights, please contact our Data Protection Officer.
When requesting to exercise your rights, we will take into account other obligations of AAM PE as well as the rights of other data subjects. As a result, there is a chance that your request may be partially fulfilled or in limited circumstances rejected. If this is the case an explanation will be provided to you.
If you wish to exercise your rights in relation to the processing of your personal data conducted by one of our joint controllers then please contact AAM PE in the first instance.
From time to time we may make changes to this privacy statement. If we make any changes to this privacy statement and the way in which we use your personal data we will post these changes on this page and where the changes are significant we will do our best to notify you.
This privacy statement was last updated on August 1, 2019
If you believe we have not processed your personal data in accordance with our data protection obligations, and that you have been affected by our non-compliance, you can make a complaint to us by contacting our Data Protection Officer. If you are not satisfied with our response, you can raise a complaint with the Der Hessische Beauftragte für Datensschutz und Informationsfreiheit in Germany or the Agencia Española de Protección de Datos in Spain, the independent authorities set up to enforce the data protection regulations.