Russell Investments EMEA Privacy Policy
Russell Investments appreciates the opportunity to help you meet your financial needs. We are committed to safeguarding the privacy and confidentiality of the Personal Information you have entrusted to us. It is important for you to understand what Personal Information we will collect, how we will use it, and who may access it.
Overview
This Privacy Policy applies to the operations of Russell Investments in the European Economic Area (EEA) and Dubai International Financial Centre (DIFC).
If you are an existing customer of ours, further details about how we use your Personal Information is set out in your customer contract with us. Further notices highlighting certain uses we wish to make of your Personal Information together with the ability to opt in or out of selected uses may also be provided when we collect Personal Information from you.
Our websites may contain links to other third-party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your Personal Information. Please check these policies before you submit any Personal Information to such third-party websites.
This Privacy Policy outlines our commitment to you.
Accountability
We have strict policies and procedures governing how we deal with your Personal Information. Each and every one of our employees is responsible for respecting and protecting the Personal Information to which the employee has access.
Our Data Protection Officer oversees privacy governance including policy, dispute resolution, education, communications activities and reporting to our Board of Directors on privacy matters.
Please visit the "contact us" tab below for information on how to reach our Data Protection Officer.
Use the tabs below to view the different sections of our privacy policy
- COLLECTION/USE
- CONSENT/SHARING
- MAINTENANCE
- CHANGES
- CONTACT US
- ANNEX
Copyright 1995-2021 Russell Investments Limited. All Rights Reserved.
You acknowledge that you understand and agree to the following terms and conditions (“Terms and Conditions”) and Privacy Policy. If you do not agree to the Terms and Conditions and the Privacy Policy, you are not authorised to access and use this website.
Disclaimer
Russell Investments Limited, Russell Investments Implementation Services Limited, Russell Systems Limited and their affiliates (together “Russell Investments”) have prepared the information contained in this website (“Information”) solely for informative purposes and have obtained the Information from sources that they believe to be reliable, notwithstanding this the Information is not intended to amount to advice on which reliance should be placed and Russell Investments makes no guarantees, representations or warranties (whether express or implied), and accepts no liability (where legally permitted) as to the Information’s accuracy and completeness.
Any opinions expressed are those of Russell Investments, are not a statement of fact and they do not constitute investment advice and are subject to change.
Restrictions on Distribution
The Information is not intended for distribution to retail clients. This website is not intended for distribution to, or use by any person or entity that is a resident of or located in any jurisdiction where such distribution or use would be in contravention of law or regulation or which would subject Russell Investments to any registration or licensing requirement in that jurisdiction.
This website and the Information are publications of Russell Investments and are not intended to constitute legal, tax, accounting, securities, or investment advice, nor any opinion regarding the appropriateness or suitability of any investment. This website shall not constitute an offer or a solicitation of an offer to buy or sell any investment product or service to any person or entity in any jurisdiction.
Investment products named in the Russell Worldwide site are only available to residents of countries where offers of such products are permitted by law. Where permitted, prospectuses for funds can be obtained by contacting Russell through the respective country websites.
Risk Warnings
The value of investments and the income from them may fall as well as rise and is not guaranteed. You may not get back the amount that you originally invested. There is no guarantee that any target or projected figures will be met and any forecast or projection is for illustrative purposes only. Any simulated figures and estimated figures are for illustrative purposes only. Any past performance figures are not a guide to future performance. Russell Investments makes no guarantee, representation or warranty (whether express or implied) regarding future performance. Any reference to returns linked to currencies may increase or decrease as a result of currency fluctuations. Any references to tax treatments depend on the circumstances of the individual client and may be subject to change in the future.
Privacy Policy
Russell Investments’ Privacy Policy forms a part of these Terms and Conditions, and is incorporated by reference. Please review this Privacy Policy to understand the controls we have in place to ensure the security of your information. Visit the Privacy Policy
Liability
To the extent permitted by law, Russell Investments shall not be liable for any damages or losses of any kind including but not limited to direct or indirect losses, damages or special, incidental or consequential losses (including but not limited to loss of profits, loss of business, loss of income or revenue, loss of anticipated savings, loss of data, loss of goodwill or trading losses) or losses due to tort (including negligence), breach of contract or otherwise, arising out of or in connection with access to, reliance on or use of this website and/or the Information (whether in whole or part) or to any links the website contains, or due to the inability for such access, reliance or use, even if Russell Investments has been advised of the possibility of such damages or losses. This doesn’t affect Russell Investments liability for death or personal injury or any other liability which cannot be excluded under applicable law.
Confidentiality
When using this website data may be transmitted over an open network which may allow such communications to be intercepted by third parties. As a result Russell Investments cannot guarantee the confidentiality of any communication or data that you may transmit to Russell Investments through this website.
Linking Websites
You may only display links or hyperlinks on your websites to any website owned by Russell Investments if you have entered into a prior written agreement with Russell Investments addressing such use of links or hyperlinks. You are prohibited from framing the content of this website in any way or any other activity including but not limited to referencing “Russell Investments” or “Russell” as a metatag, that may create a misimpression or confusion among users with respect to sponsorship or affiliation.
This website may contain links or hyperlinks to other websites operated by third parties. Should you use such links or hyperlinks you leave this website at your risk. Russell Investments accepts no liability and provides no representation or warranty (whether express or implied) as to the completeness or accuracy of any information contained in such websites nor to the operators of or the products or services contained in such websites.
Intellectual Property Rights
This website and the Information are owned by Russell Investments and are protected by applicable copyrights, trademarks, service marks and other intellectual property rights. All such rights are reserved.
You are only permitted to use this website for personal non-commercial use only, and your use of this website, including the downloading of any parts of this website or the Information shall not transfer any title to any software or information from this website to you. You may only reproduce, distribute or re-publish any Information with the express prior written agreement of Russell Investments.
If you print off, copy or download any part of this website in breach of these terms, your right to use this website will cease immediately and you must, at Russell Investments option, return or destroy any copies of the materials you have made.
Amendment
Russell Investments may amend these Terms and Conditions and Privacy Notice from time to time and without prior notice. Russell Investments reserves the right at any time and without notice to change, amend, or cease publication of the whole or any part of the Information.
Severability
If any provision of these Terms and Conditions are deemed unlawful or are unenforceable, then that provision shall be deemed severable from these Terms and Conditions and shall not affect the enforceability of the remaining provisions.
Governing Law and Jurisdiction
These Terms and Conditions are governed by the laws of England and Wales. The exclusive place of jurisdiction is England and Wales.
Most of our processing is permitted by “legal grounds” other than consent (see “). In relation to Direct Marketing, where we are required to do so, we will obtain your consent before using your Personal Information for this purpose. If you prefer not to receive our Direct Marketing communications and/or not have your Personal Information shared among the members of the Russell Investments group for the purpose of marketing, you can have your name deleted from our Direct Marketing and/or shared information lists. If you want to change your privacy preferences, please visit the tab.
In relation to processing of criminal convictions data and politically exposed person data for the purposes of complying with our anti-money laundering obligations and to combat fraud we consider that our processing is permitted by the substantial public interest ground (to prevent or detect crime) but to the extent it is not you give and we rely on your consent to process that type of Personal Information. Although you have a right to withdraw such consent at any time, as we consider the processing to be necessary for us to provide our services its withdrawal (to the extent the processing cannot be justified on substantial public interest grounds) may require us to cease to provide certain services.
We will only use or disclose your Personal Information for the purpose(s) it was collected and as otherwise identified in this Privacy Policy.
Sharing outside the Russell Investments group: Personal Information may be provided to third parties, including anti-fraud organisations, legal, regulatory or law enforcement authorities in cases of suspected criminal activity or contravention of law, for the detection and prevention of fraud, or when required to satisfy the legal or regulatory requirements of governments, regulatory authorities or other self-regulatory organizations, or to comply with a court order or for the protection of our assets.
Sharing within the Russell Investments group: We may share your Personal Information within the Russell Investments group, including locations outside of the European Economic Area where we do business, for marketing purposes, for legal and regulatory purposes, to manage credit risk and other business risks, to perform analytics, to ensure we have correct or up to date information about you (such as your current address or date of birth) and to better manage your relationship with us.
Business sale or reorganisation: Over time, we may buy new businesses or sell some of our businesses. Accordingly, Personal Information associated with any accounts, products or services of the business being purchased or sold will be reviewed as part of the due diligence process and subsequently transferred as a business asset to the new business owner. We may also transfer Personal Information as part of a corporate reorganisation or other change in corporate control.
Sub-contractors and agents: We may use affiliates or other companies to provide services on our behalf such as data processing, account administration, fraud prevention and detection, analytics and marketing. Such companies will be given only the Personal Information needed to perform those services and we do not authorise them to use or disclose Personal Information for their own marketing or other purposes. We have contracts in place holding these companies to the same standards of confidentiality by which we are governed.
Transfers outside of the EEA: Your Personal Information may be accessed by staff, suppliers or other persons in, transferred to, and/or stored at, a destination outside the European Economic Area (EEA) in which data protection laws may be of a lower standard than in the EEA. We will, in all circumstances, safeguard personal information as set out in this Privacy Policy.
Where we transfer personal information from inside the European Economic Area (the EEA) to outside the EEA, we may be required to take specific additional measures to safeguard the relevant personal information. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal information to these jurisdictions. In countries which have not had these approvals (see the full list here https://ec.europa.eu/info/law/law-topic/data-protection_en), we will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses, or other legal grounds permitted by applicable legal requirements.
Our retention periods for personal data are based on business needs and legal requirements. We retain your Personal Information for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When Personal Information is no longer needed, we either irreversibly anonymise the data (and we may further retain and use the anonymised information) or securely destroy the data.
We are committed to maintaining the accuracy of your Personal Information and ensuring that it is complete and up-to-date. If you discover inaccuracies in our records, or your Personal Information changes, please notify us immediately so that we can make the necessary changes. Failure to notify us of changes to your Personal Information may negatively impact the way we communicate or provide services to you. Where appropriate, we will advise others of any material amendments to your Personal Information that we may have released to them. If we do not agree to make the amendments that you request, you may challenge our decision as described on the tab.
We use physical, electronic and procedural safeguards to protect against unauthorised use, access, modification, destruction, disclosure, loss or theft of your Personal Information in our custody or control.
We have agreements and controls in place with third party service providers requiring that any information we provide to them must be safeguarded and used only for the purpose of providing the service we have requested the company to perform.
Security over the internet
No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with data protection legislative requirements.
All information you provide to us is stored on our or our subcontractors’ secure servers and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.
From time to time, we may make changes to this Privacy Policy.
The Privacy Policy on the Russell Investments website is always the most recent version.
Please visit the tab to address any questions you may have about our Privacy Policy.
- provide you with further details on the use we make of your information;
- provide you with a copy of information that you have provided to us;
- update any inaccuracies in the personal information we hold (please see paragraph 7);
- delete any personal information that we no longer have a lawful ground to use;
- where processing is based on consent, to withdraw your consent so that we stop that particular processing (see paragraph 4 for marketing);
- object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
- restrict how we use your information whilst a complaint is being investigated.
If you have any questions in relation to our use of your personal information, you should first contact us as per the tab. Under certain conditions (in particular, where Russell Investments has directed the use of your Personal Information from one of its European branch offices), you may have the right to require us to:
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.
If you are not satisfied with our use of your personal information or our response to any exercise of these rights you have the right to complain to the data protection regulator in the country where the Russell Investments branch with which you deal is established (see ).
Contact us
If you have any questions or concerns about our privacy practices, the privacy of your Personal Information or you want to change your privacy preferences, please let us know.
To contact the Data Protection Officer, please use the details below:
By post:
The Data Protection Officer
Russell Investments Limited
Rex House, 10 Regent Street
London, SW1Y 4PE
By email: info_amsterdam@russellinvestments.com
By telephone: +44 (0) 207 024 6000
If after contacting us you do not feel that we have adequately addressed your concerns, you may contact the data protection regulator in the country where the Russell Investments branch with which you deal is established:
| UK | The Information Commissioner’s Office Call: +44 1625 545 745 Visit: https://ico.org.uk/ |
| Italy | Garante per la protezione dei dati personali Call: +39 06 69677 1 Visit: https://www.garanteprivacy.it/ |
| Germany | Die Bundesbeauftragte für den Datenschutz und die Informationsfreiheit Call: +49 228 997799 0; +49 228 81995 0 Visit: https://www.bfdi.bund.de/ |
| France | Commission Nationale de l'Informatique et des Libertés – CNIL Call: +33 1 53 73 22 22 Visit: https://www.cnil.fr/ |
| Netherlands | Autoriteit Persoonsgegevens Call: +31 70 888 8500 Visit: https://autoriteitpersoonsgegevens.nl/nl |
Direct Marketing is our communication with you such as mail, telemarketing or email, using your contact information, to inform you about products and services that we think may be of interest and value to you. This does not include communications regarding products or services that you currently have, including improved ways to use the products, or additional features of the products as well as transactional information.
Personal Information is information about an identifiable individual. It includes information that you have provided to us or was collected by us from other sources. It may include details such as your name and address, age and gender, personal financial records, identification numbers including your Social Insurance Number and personal references, to the extent permitted by local laws.
Russell Investments means Russell Investments Limited and Russell Investments Implementation Services Limited and their affiliates that provide investment and other products and services, collectively “Russell Investments”.
Use of personal information under EU data protection laws must be justified under one of a number of legal “grounds” and we are required to set out the grounds in respect of each use in this policy. An explanation of the scope of the grounds available is set out below. We note the grounds we use to justify each use of your information next to the use in the “Uses of your personal information” section of this policy.
These are the principal legal grounds that justify our use of your information:
Consent: where you have consented to our use of your information (you may withdraw your consent at any time by contacting us using one of the methods described above).
Contract performance: where your information is necessary to enter into or perform our contract with you.
Legal obligation: where we need to use your information to comply with our legal obligations.
Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.
Substantial Public interest; where we use Personal Information relating to criminal convictions or political affiliations for a purpose that is expressly in the substantial public interest, including for the prevention or detection of crime or fraud.
Key areas of interest regarding your personal information
Collection/Use
- Personal information that we collect
- Purposes for which we use your personal information
Consent/Sharing
- Consent and your choices
- Sharing your personal information
Maintenance
- Retention of your personal information
- Maintaining the accuracy of your personal information
- Safeguarding your personal information
Changes
- Changes to this privacy policy
- Your rights
Contact us
- Contact us
Annex
- Definitions
- Table of legal bases