Data related to MUFG Investors Services1 provision of services is governed by multiple data protections regimes including:
- the EU General Data Protection Regulation (GDPR) as applicable
- the Irish Data Protection Acts 1988 – 2013 and the Irish Data Protection Act 2018
- the UK Data Protection Act 2018
- the Data Protection (Jersey) Act 2018
- the Bermuda Personal Information Protection Act 2016
- the Cayman Islands Data Protection Law 2017
- the Singapore Personal Data Protection Act 2012
- The Cyprus Law for the Protection of Natural Persons with regard to the Processing of their Personal Data and for the Free Movement of such Data (Law 125(I) of 2018)
- together with all applicable secondary legislation, regulations and guidance as issued thereunder, and all above as amended, supplement and replaced (“Regulation”)
Under Regulation, you have a right to be informed about how and why we process your personal data.
This notice is being provided to you as required under Regulation and its purpose is to explain how MUFG Investor Services collects and uses personal data about you and how you can contact us.
Who we are and where we obtain your personal data from
MUFG Investor Services is a Data Processor for the personal data it processes on behalf of clients. Additionally, MUFG Investor Services is the Data Controller, in respect of carrying out certain legal obligations. Primarily the data we process on you has been obtained directly from you or from our clients. Where applicable, we may utilise a third-party vendor for AML/KYC screening which collates publicly available information in an easily searchable format.
For marketing purposes, we utilise a third party who collates publicly available depository of sales contacts.
Why we process your personal data
If you are an investor, client or related party of either we process your personal data as a Data Controller for the purpose of fulfilling our legal obligation in relation to the prevention of:
- Tax avoidance
- Money Laundering and Terrorist Financing
We also have a legitimate interest in processing your personal data in order to effectively ensure the security of the Company’s network, offices and individuals on-site. In limited circumstances we will also record telephone calls. Any information provided to us will only be used for the purposes for which it was provided and any reasonably related purposes including providing you with the information that you request from us.
- We act as a Data Processor to our clients to administer the products and services that we supply to them.
- We act as a Data Controller where we act as trustee or banker to clients in respect of the products and services that we supply to them.
Where you have given us consent, we may use your information for direct marketing purposes. We endeavour to make it as easy as possible for you to opt-out of receiving direct marketing by opting out upon receipt of marketing material or contacting us.
Who can access your personal data
Your personal data is provided to our employees as required to execute the intended purposes. MUFG Investor Services may provide your details to the parent company and other group affiliates as may be required from time to time.
If you are an Investor of one of the funds we provide services to, we will also provide your personal data to that Client as the Data Controller and for the purpose of administering the contract we have with them.
Our service providers include information technologies and telecommunication service providers, software support and development contractors, cloud hosting and support providers, computer maintenance contractors, printing companies, document storage and destruction companies, archiving services providers, auditors, consultants, legal advisors, sanctions & politically exposed persons screening application support services.
Where necessary your personal data will be made available to statutory and regulatory bodies.
Countries your data may be transferred to
Personal data may be transferred to entities located in non-EEA countries or regions including: Australia, Belarus, Bermuda, Brazil, Canada, Cayman Islands, Cyprus, Hong Kong, India, Israel, Japan, Jersey, Philippines, Singapore, South Korea, UAE, USA, and any other countries as may be required depending on a Client’s or Investor’s domicile. Prior to undertaking any such transfers the company ensures it has adequate safeguards in place such as Intra-Group processing agreements and Standard Contractual Clauses.
Retention period or criteria used to determine retention period
Your personal details will be kept for the duration required to fulfill its purpose and any further regulatory or legal retention requirements.
Security measures we have in place
We know that you are concerned about the security of your personal data. This is why we take information security very seriously. We employ a range of prevention and detection tools and methods to safeguard against the loss, misuse or alteration of any information in our control and the availability of the services we provide. We are continuously improving our information security posture. All staff complete data protection training annually. In addition, targeted training and awareness exercises are provided from time to time.
Under the applicable Data Protection Regulation, you might have a number of rights as outlined below.
|Access to your personal data||You have a right to access the personal data we process on you. We will endeavor to give you as complete of a list as possible. If there is any specific information you are looking for, please outline this in your request.|
|Correct your personal data and object or restrict the processing||If any of the personal data we hold on to you is incorrect, incomplete, or out of date you have a right to have this updated. You have the right to object to the processing of your personal details where the processing is based on legitimate interest. Where you exercise this right, we will outline the reasons for processing the data and stop processing your personal details while we work through the objection. You can request that processing is restricted while we review your personal data, where you dispute the accuracy of it.|
|Erase your personal data||Where you suspect that your personal data is processed without a legitimate reason or where you believe we no longer have grounds to process your personal data you can request it to be erased. Please note that we are under no obligation to rectify or delete your personal data where to do so would prevent us from meeting our legal or regulatory obligations.|
|Rights relating to automated decision making and profiling||MUFG Investor Services does not engage in any automated decision making or profiling which could in any way adversely affect you.|
|Have your personal data ported||This allows you to reuse your personal data by having it electronically transmitted to or from another service provider or to yourself.|
|Complain to the Supervisory Authority||You have a right to complain to the relevant Supervisory Authority. You can find out more about your rights or how to complain to the Supervisory Authority by visiting your relevant supervisory authority.|
If you would like to exercise any of your rights, please e-mail [email protected]
Categories of personal data we process
|Identity & contact information||Name|
Date of Birth
Place of Birth
|Financial details/circumstances||Bank account details|
|Source of Funds & Source of Wealth|
|Marital status and/or financial associations||Marital status||Family member’s name (spouse, minors, etc.) and other beneficiaries as requested by you.|
|Special Categories||Passport Number|
|Place of birth|
Relevant or Incidental Health Information as provided by you.
Sanction screening and adverse media searches
|Video & Image Recording||Telephone and image recordings||CCTV at our premises|
How to contact us
You may contact us with questions related to personal data:
1 MUFG Investors Services is a service brand name and includes the following entities only within the MUFG global financial group – MUFG Fund Services Limited, MUFG Fund Services (Bermuda) Limited, MUFG Fund Services (Cayman) Limited, MUFG Alternative Fund Services (Cayman) Limited, MUFG Fund Services (Ireland) Limited, MUFG Alternative Fund Services (Ireland) Limited, MUFG Fund Services (UK) Ltd., MUFG Alternative Fund Services (Jersey) Limited, MUFG Jersey Management Company Limited, MUFG Fund Services (Halifax) Limited, Summit Place, MUFG Fund Services (Canada) MUFG Fund Services (Hong Kong) Limited, MUFG Fund Services (Singapore) Pte Limited, MUFG Fund Services (Cayman) 2 Limited, MUFG Fund Services (Halifax) 2 Limited, MUFG Fund Services (Halifax) 2 Limited, MUFG Fund Services (Cyprus) Limited.
This was created using a template from SEQ Legal (https://seqlegal.com).
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- https://support.google.com/chrome/answer/95647 (Chrome);
- https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
- https://www.opera.com/help/tutorials/security/cookies/ (Opera);
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- https://support.apple.com/kb/PH21411 (Safari); and
- https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.
This website is owned and operated by MUFG Investor Services
You can contact us:
MUFG Fund Services (Ireland) Limited
Data Protection Office
12 -13 Lower Leeson Street