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
- 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
MUFG Investors Services1 is an industry-leading asset services and fund financing arm within Mitsubishi UFJ Financial Group (MUFG). The firm partners with leading investment firms to provide them with holistic, customized solutions that meet their operations, financing and regulatory needs across the investment lifecycle.
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.
Where we obtain your personal data from
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, 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: Japan, Jersey, Cayman Islands, Bermuda, Hong Kong, Singapore, USA, Canada, and India (only following prior, written agreement) 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 the 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 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 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 firstname.lastname@example.org
Categories of personal data we process
Identity & contact information
- Date of Birth
- Postal address
- Registered address
- E-mail address
- Telephone number
- Legal domicile
- Place of Birth
- Bank account details
- Taxation details
- Source of Funds & Source of Wealth
- Investment Data
Marital status and/or financial associations
- Marital status
- Family member’s name (spouse, minors, etc.) and other beneficiaries as requested by you
Special Categories (Sensitive categories)
- Passport Number
- Tax ID
- Legal domicile
- Place of birth
- Relevant or Incidental Health Information as provided by you
- Sanction screening and adverse media searches
- Telephone and image recordings
- CCTV at our premises
How to contact us
You can contact us in relation to any queries or questions you may have in relation to personal data as follows:
Contact details for our office locations can be found here.
If you are an Investor of one of the Funds we provide services to, the Fund is also a Data Controller. If you require the contact details of the Fund in which you have invested, please contact us.
1 MUFG Investors Services is a service brand name and includes the following entities only within the MUFG global financial group – MUFG Fund Services (Bermuda) Limited, MUFG Fund Services Limited, MUFG Fund Services (Cayman) Limited, MUFG Alternative Fund Services (Cayman) Limited, MUFG Fund Services (Ireland) Limited, MUFG Alternative Fund Services (Ireland) Limited, MUFG Alternative Fund Services (Jersey) Limited, MUFG Jersey Management Company Limited, MUFG Fund Services (Singapore) Pte Limited, MUFG Fund Services (Halifax) Ltd, MUFG Fund Services (Canada) Ltd, MUFG Fund Services (UK) Ltd., MUFG Fund Services (Hong Kong) Ltd.