The Ashmore Group aims to protect the privacy of our shareholders and customers (“you” and “your”) as far as possible. References to “Ashmore”, “we”, “our” and “us” in this policy, depending on the context, collectively refer to those separate and distinct legal entities. Ashmore is a “data controller” in respect of any personal data we hold about you.
Ashmore Group plc has appointed Ashmore Investment Management (Ireland) Limited as its representative in the EU, in accordance with the requirements of the EU General Data Protection Regulation. If you would like to get in touch with us in relation to this privacy notice, contact details may be found for both Ashmore Group plc and Ashmore Investment Management (Ireland) Limited in the “Contact Us” section below.
Applications to invest in Ashmore funds are subject to a separate privacy notice, which forms part of the application form and /or relevant offering memorandum. Applications for careers at Ashmore are subject to a separate ‘Applicants’ Policy’ which can be found at: www.ordinfc.com/careers. Ashmore employees are also subject to a separate privacy notice which may be found in the Employee Handbook or requested from your HR contact.
Ashmore will amend this privacy notice from time to time. Where we do so, we will take appropriate steps to bring the amendment to your attention. This privacy notice was last updated in December 2022.
How we obtain your information
In the course of providing services to you or receiving services from you, we collect information that personally identifies you.
The information we collect about you (your representative or your staff or your Ultimate Beneficial Owners) comes from:
- application forms, identification documents or other materials you submit to us during the course of your relationship with us;
- your interactions with us, transactions and use of our products and services (including the use of our website);
- your business dealings with us, including via email, telephone or as stated in our contracts with you;
- depending on the products or services you require, third parties (including for credit and money laundering checks, among other things); and
- recording and monitoring tools that we use for compliance or security purposes (e.g. recording of telephone calls, monitoring emails, etc.).
The information we collect
We collect information that helps us to identify you and where applicable, to manage your accounts. We also collect financial information about you, information about your transactions with us and information required for us to carry out credit, money laundering and other checks and to comply with our legal obligations.
The information or personal data that we collect includes:
- your name, title and contact details;
- your professional title and occupation;
- your age and marital status;
- financial information, including investments with Ashmore and elsewhere, account details, risk appetite and evidence of ownership of financial assets;
- personal identifiers such as your social security number, national insurance number, tax file number, IP address or our internal electronic identifiers;
- information which we might need to conduct ‘know your client’ checks such as details relating to your passport and credit history; and
- other information you provide to us in the course of your dealings with us or which we require to provide you with Ashmore’s product and services.
In limited cases, we also collect what is known as “special categories” of personal data. Our money laundering, sanctions, financial crime and fraud prevention checks sometimes result in us obtaining information about actual or alleged criminal convictions and offences. This information will only be processed if allowed under the relevant data protection legislation.
You are not obliged to provide us with your information where it is requested but we may be unable to provide certain products and services or proceed with our business relationship with you if you do not do so. Where this is the case, we will make you aware.
Our use of your information
We collect, use, share and store information about you to process transactions or holdings and to improve the quality of the service that we provide to you.
When processing your information, we do so in our legitimate interests (as set out in the bullet points below), because of legal obligations that we are subject to or because the information is required either in order to provide our products or services to you (including entering into an agreement with you) or to receive products and services from you in accordance with a contract.
Where we process “special categories” of personal data ?about you, we do so either because you have given us your explicit consent, we are required by law to do so or the processing is necessary for the establishment, exercise or defence of a legal claim.
We use your information for the purposes of the following legitimate interests:
- to permit, administer and record your shareholding in Ashmore, or your investment in any of our funds;
- to administer, operate, facilitate and manage your account(s) with or shareholdings in us and your use of our services and products;
- to manage any funds that you invest in with us and to communicate with you in connection with your investment in our funds;
- in connection with Ashmore’s internal management and reporting;
- to identify the geographical location of visitors to our website, and their investor type, so we can display information about appropriate products and services (for further information about the cookies we use on our website, please see our cookies policy: http://www.ordinfc.com/cookie-policy; and
- to facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.
Should we wish to use your personal information for other specific purposes (including, if applicable, any purpose that requires your consent), we will contact you.
How we share your information
We share certain information within Ashmore and ?with our third party partners, business associates and subcontractors, and with other third parties for the purposes set out in this policy.
These third parties may include:
- share registrars, auditors, professional advisors, IT service providers subcontractors, agents and other third parties who provide advice or other services to us or the Ashmore funds;
- intermediaries and third parties operating trade execution services, exchange clearing systems, custodians, fund administration providers, transfer agents and market counterparties with whom we transact or intend to transact; and
- persons with whom you have authorised us to share your personal data such as joint account holders, accountants and professional advisors.
Such third parties also include subsidiaries of Northern Trust Corporation who may process data to:
- facilitate the opening of your account with the Fund, the management and administration of your holdings in the Fund and any related account on an on-going basis (the “Services”) which are necessary for the performance of your contract with the Fund, including without limitation the processing of redemption, conversion, transfer and additional subscription requests, and the payment of distributions;
- carry out anti-money laundering checks and related actions which the Ashmore, considers appropriate to meet any legal obligations imposed on Ashmore , or the Administrator relating to, or the processing in the public interest, or to pursue the legitimate interests of Ashmore or the Administrator in relation to, the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis, in accordance with Ashmore’s and the Administrator's anti-money laundering procedures;
- report tax related information to tax authorities in order to comply with a legal obligation;
- monitor and record calls and electronic communications for (i) processing verification of instructions; (ii) investigation and fraud prevention purposes; (iii) for crime detection, prevention, investigation and prosecution; (iv) to enforce or defend Ashmore, the Administrator’s or their affiliates' rights, themselves or through third parties to whom they delegate such responsibilities or rights in order to comply with any legal obligation imposed on Ashmore or the Administrator;? (v) to pursue the legitimate interests of Ashmore or the Administrator in relation to such matters; or (vi) where the processing is in the public interest;
- disclose information to other third parties such as service providers of the Fund, auditors, regulatory authorities and technology providers in order to comply with any legal obligation imposed on Ashmore, or the Administrator or in order to pursue the legitimate interests of Ashmore, or the Administrator;
- monitor and record calls for quality, business analysis, training and related purposes in order to pursue the legitimate interests of Ashmore, or the Administrator to improve their service delivery;?
- update and maintain records and carry out fee calculations; and
- retain AML and other records of individuals to assist with subsequent screening of them by the Administrator including in relation to your investment in other funds administered by the Administrator in pursuance of the Administrator’s or its clients’ legitimate interests.
All third parties that receive your personal data are required to maintain the confidentiality of such information to the extent they receive it.
In addition, we may share information relating to you with a potential buyer, transferee, or merger partner or seller and their advisers in connection with any actual or potential transfer or merger of part or all of Ashmore’s business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it.
We also disclose your personal data or any portions thereof as required or requested by, or as we determine is necessary or desirable to comply with, applicable law, regulation, court process or other statutory requirement, and regulatory, supervisory or governmental authorities.
Where we share your information, we require those receiving it to put in place security and confidentiality measures to protect it.
How we transfer your information
We use cloud-based technologies and do business in a global marketplace. This means that, like many organisations, we may share your personal data outside the UK or the European Economic Area (the “EEA”), as relevant. These locations include: the US, Colombia, Japan, Singapore, Saudi Arabia, Indonesia and the UAE.
Some of these countries may have lower standards of data protection than in your home country, and not all countries outside of the UK or the EEA have data protection laws that are similar to those in the UK and the EEA, so they may not be regarded by the UK or the European Commission as providing an adequate level of data protection. Where we transfer your information outside of the UK or the EEA, we will ensure that the transfer is subject to appropriate safeguards in accordance with data protection laws. Often, these safeguards include contractual safeguards. Please do contact us if you would like more information about these safeguards (see the “Contact Us” section below for further details).
Retention of information
We will hold your personal data on our systems for the longest of the following periods:
- a minimum of six years;
- as long as is necessary for the relevant activity or as long as is set out in any relevant agreement you enter into with us;
- the length of time it is reasonable to keep records to demonstrate compliance with professional or legal obligations;
- any retention period that is required by law; or
- the end of the period in which litigation or investigations might arise in respect of the services that we provide to you
You may have the following rights under data protection law in the UK or the EEA:
- Right of subject access: The right to make a written request for details of information about you held by Ashmore and a copy of that information.
- Right to rectification: The right to have inaccurate information about you rectified.
- Right to erasure ('right to be forgotten'): The right to have certain information about you erased.
- Right to restriction of processing: The right to request that your information is only used for restricted purposes.
- Right to object: The right to object to the use of your information, including the right to object to marketing.
- Right to data portability: The right, in certain circumstances, to ask for information you have made available to us to be transferred to you or a third party in a machine-readable format.
- Right to withdraw consent: The right to withdraw any consent you have previously given us to handle your information. If you withdraw your consent, this will not affect the lawfulness of Ashmore’s use of your information prior to the withdrawal of your consent.??? ???? ?
These rights are not absolute: they do not always apply and exemptions may be engaged. We may, in response to a request, ask you to verify your identity and to provide information that helps us to understand your request better. If we do not comply with your request, we will explain why.
If you are seeking to exercise any of these rights, or if you have any other questions about our use of your information, please contact us at the details set out in the “Contact Us” section below.
If you are unhappy with the way we have handled your information you may have a right to complain to the data protection supervisory authority in the UK or EU Member State where you live or work, or where you think a breach of your personal information has taken place.
- In the UK, your local data protection supervisory authority is the Information Commissioner. The website is available at https://ico.org.uk
- In Ireland, your local data protection supervisory authority is the Data Protection Commission. Their website is available at https://www.dataprotection.ie
No part of this policy may be copied, duplicated or redistributed without our written consent. The content is provided for informational purposes only and should not be used as the basis for any decision to purchase or redeem investments in any Ashmore fund. The views and information expressed in this policy do not constitute and may not be relied upon as constituting any form of investment advice or inducement to invest, and prospective investors must obtain appropriate independent professional advice before making investment decisions.
Ashmore takes the protection of your personal data seriously, and has security measures and policies in place to address this. All Ashmore Group staff are made aware of their information security responsibilities.
Notification of your associated persons
Where you are providing personal data relating to your beneficial owners, representatives or other associated individuals to us, you should notify such parties of this Privacy Notice.
If you have any questions about this privacy notice or our privacy related practices, you can contact us:
Ashmore Group plc
- at the following address:?Ashmore Group plc,?61 Aldwych,?London WC2B 4AE, UK.
- by email at: AshmoreCorporate@ashmoregroup.com
- by phone at: +44 20 3077 6000.
Ashmore Investment Management (Ireland) Limited
- at the following address:?32 Molesworth Street, Dublin 2, D02 Y512, Ireland.
- by email at: AshmoreCorporate@ashmoregroup.com
- by phone at: +353 1588 1300.