EMEA online privacy notice

Introduction, Who We Are and Definitions

Thank you for visiting our website and for using our Online Services. We would like to tell you about our Online Privacy Notice.

Who We Are

For the purpose of applicable data protection legislation, including but not limited to the Law (as defined below), the company which is the data controller (under GDPR and UK GDPR) and organisation responsible for your personal data is Invesco Ltd. and its relevant affiliates. For further details of the entity in your geographic location, please see further here.

This Online Privacy Notice:

(i) describes how members of Invesco Ltd.’s group of companies and investment funds managed by members of Invesco listed in section “Issuing Companies” below (collectively "Invesco", “we,” “our” and “us”) will collect, use, and process your personal data and satisfy the requirements set out in the Law; and

(ii) applies to users and/or recipients of Invesco's websites, online chat and other services provided by Invesco online, including online events (“Online Services”). We take seriously our responsibility to hold your personal data securely and confidentially. We are committed to protecting your privacy and personal data as you use our Online Services, that refer or link to this Online Privacy Notice. This Privacy Notice may be supplemented by additional privacy statements, terms or other notices provided to you.

Click here to visit the Invesco Privacy Portal to learn more.

In this Online Privacy Notice

We have defined some words and phrases to help make it clear what we mean: 

“personal data” means personal data as defined under the Law and includes any information about an identified or identifiable natural person. Such information may include, for example, information we collect against an identifier for you (for example, your online user ID). We also refer to personal data as “information about you”;

“controller” means controller as defined in applicable data protection legislation; 

“processor” means a third party that processes personal data on Invesco's behalf (including, but not limited to our service providers, credit reference agencies, other entities within Invesco Ltd.’s group companies, and your financial advisor or other intermediaries);

“Invesco,” “our,” “us” and “we” means Invesco Ltd.’s group of companies and investment funds managed by members of Invesco listed in section “Issuing Companies”;

“the Law” means applicable data protection legislation, including (where applicable) but not limited to:

(i) the EU General Data Protection Regulation (2016/679) (“GDPR”);

(ii) General Data Protection Regulation (Regulation (EU) 2016/679) as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018, as amended by the Data Protection Act 2018 and the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 as amended from time to time ("the UK GDPR");

(iii) Data Protection Act 2018 (“DPA”);

(iv) the Dubai International Financial Centre Data Protection Law ("DIFC DPL"), as amended;

(v) Israel’s Protection of Privacy legislation (“PPL”), as amended; and

(vi) Switzerland's Federal Act On Data Protection 2020 (“FDPA”), as amended.

The Purpose of this Online Privacy Notice

This Online Privacy Notice tells you how we process any personal data that we collect from you, or that you provide to us, online. We hope this helps you to understand how we keep your personal data safe. You can find more information about how we process your personal data in our Client Privacy Notice which also applies to the use of personal data we collect offline. This Online Privacy Notice is non-contractual, and we may amend it from time to time. Please visit this page regularly to view any changes to this Online Privacy Notice. For more information about how we process your personal data we collect offline, please read our Client Privacy Notice.

Information We Collect

Depending on your interaction with our Online Services, we collect the following categories of personal data from you:

  • For certain Online Services (such as email updates), we need to be able to identify who you are. To do this, we will ask you to register on our website by providing your name and email address, and then we will ask you to create a strong password. To register on Invesco websites, we may ask you for your mobile phone number to enable two-factor authentication. If you ask us for information by post, we will also ask you to provide your postal address. Once you have registered with our website, we will link all the personal data we collect about you via the website, and what we may know about you offline as an investor, to your registration.
  • Your audience type: we have created certain pages on our website specifically for certain types of audience. By letting us know what type of audience you are (Private Investor or Professional Client (Financial Adviser or Institutional Investor)) we can show you pages that are most relevant to that audience type. You can always change your audience type using the links at the top of each page of our website.
  • If you use the online email or the online chat services, you may choose to give us your personal data and we will also ask you to provide us with certain personal data such as your name, business email address, job title, company name, and Invesco account information. We may need your personal financial information such as bank account information when we process payments or provide financial advice. We may need to ask you for additional personal data such as your telephone number, or location to help us to meet your needs and to provide you with the Online Services you require. If you do not provide your personal data to us, it may not be possible for us to provide these Online Services to you; and
  • We use cookies on our websites and if they are not strictly necessary to operate our websites, we will only use them where you have consented to us placing these on your computer or other device. These cookies and tags collect data about your use of the website including how you arrived at our websites, which pages you click on and where you scroll on the page, the country from which you are accessing the website, which website you go to when you leave our websites and your activity on other third-party websites. This information is linked to a unique cookie ID number which is provided to you when you visit our websites or to your IP address. For more information on the cookies we use and what information is collected, together with information on how to manage your cookie settings, please see our Cookie Notice.

How We Collect Your Information

As mentioned above, we may receive your personal data directly from you (e.g. when you are registering on our website), or automatically (e.g. via cookies). We may also collect your personal data from third parties, for example:

  • from publicly accessible sources, including publicly available online profiles and databases e.g., to establish and verify your identity, to find out your contact details or to liaise with you in relation to our Online Services, or
  • by using third-party cookies. Please find more information about how we use third-party cookies in our Cookie Notice.

How and Why We Use Your Information

This section of this Online Privacy Notice explains for what purposes we use your personal data we collect and on which legal bases we rely.

How and why we process your information Types of personal data used Legal basis relied upon
(1) To service your online account 
  • name
  • email address
  • Invesco account information
  • password
  • postal address
  • location
  • contact details
  • government identifiers
  • personal identification

Legitimate interests, namely it is in our interests:

  • to maintain our account holder details;
  • to service your account and communicate with you;
  • to ensure our business runs smoothly;
  • to safeguard our business interests; and
  • to verify the people we deal with.

We may also need to process your data to comply with our legal obligations.
(2) To provide you with our online valuation service and Online Services (including to perform the services or provide the goods you reasonably expect as a consumer, such as maintaining or servicing accounts, providing customer service, processing payments, or providing financing).  
  • name
  • email address
  • postal address
  • personal financial information (e.g. bank account information)
  • company name
  • location
  • contact details
  • government identifiers
  • personal identification

Legitimate interests, namely it is in our interests and your interests:

  • to provide our services to you or answer any queries;
  • to facilitate transactions made with you and fulfil any requests; and
  • to ensure our business runs smoothly.

We may also need to process your data to comply with any contractual terms and conditions in place between us and you.
(3) To improve our Online Services to you and other website users.  
  • name
  • email address
  • audience type information
  • browsing information
  • location
  • purchasing tendencies
 Legitimate interests, namely it is in our interests to improve your experience when using the Online Services.
(4) To develop and test new products.
  • audience type information
  • browsing information
  • location
 Legitimate interests, namely it is in our interests and your interests to develop new products and services.
(5) To provide information to you about our Online Services or anything else that we think may be of interest to you (this information may be provided to you in the form of a digital advertisement or via email), and we may identify which Online Services we think you are interested in by using cookies on our website which track and analyse how you use our website; and
  • name
  • email address
  • business email address
  • job title
  • company
  • postal address
  • browsing information
  • cookies
  • location
  • contact details
  • communication preferences
  • purchasing tendencies

We send you marketing emails in reliance on your consent.

Where permitted by applicable law and unless you have opted-out, we may also send marketing communications based on our legitimate interests, namely it is in our interests to send you marketing communications where you are an existing customer who may be interested in the Online Services.
(6) To process your personal data for administration, assessment, and analysis purposes (for example, marketing and product analysis and behaviour scoring). 
  • name
  • email address
  • business email address
  • job title
  • company name
  • postal address
  • location
  • contact details
  • purchasing tendencies

Legitimate interests, namely it is in our interests:

  • to improve our products and services to our customers;
  • to provide any services to you; and
  • to help us manage the services we provide.

How We Protect Your Personal Data

We maintain strict security standards and procedures with a view to preventing unauthorised access to your personal data by anyone, including our staff. We use a variety of leading administrative, physical, and technical security measures to help safeguard your personal information. You can learn more about how Invesco keeps your data safe by reading our article Keeping safe online with Invesco. The staff of Invesco follow strict privacy standards and whenever we hire third parties to provide support services, we require them to observe the same standards and to allow us to audit them for compliance.

Sharing of Your Personal Data (Disclosure and Transfer)

Using our Email page tool, you will be able to send links to site content to another person, by providing their name, audience type, company name (if relevant) and email address. We will not use this information for any purpose other than sending the links you request. You should always get permission before providing someone else's details to us.

Disclosure of your personal data

Depending on the Online Services provided, we may share your personal information with different parties.

Where we send direct marketing materials to you, we may send your personal data to third parties with whom we have contracted to provide these materials to you on our behalf and in our name. These third parties act as our processors in relation to their processing of your personal data in this way.

We may also use other third parties to process your personal data on our behalf. For example, we may use them to provide and administer the webchat function on our website, or to drop cookies and perform analytics on our website (please see the Cookie Notice for further information about our use of cookies).

When we use third party processors, we ensure they process your personal data in accordance with our instructions and that they put appropriate technical and organisational security measures in place to adequately protect your personal data.

In certain circumstances, we may also share your personal data we collect online, for the purposes set out in this Online Privacy Notice with other third parties such as:

  • service providers (e.g. data analysis or web-hosting firms, other information technology service providers), who provide a service to us or you, their service providers, delegates, and agents;
  • credit reference agencies;
  • other entities within Invesco Ltd.’s group companies; and
  • your financial advisor or other intermediaries.

We also may disclose your personal data to courts, the police, or other law enforcement agencies where we are legally obliged to do so or in our reasonable opinion such disclosure is necessary to comply with applicable laws and legal processes, support an investigation or to protect our rights and interests in relation to any suspected misuse by you of our services.

We endeavour to prevent unauthorised disclosures of your personal data by other people, but we are not responsible for any unauthorised disclosures or other breaches of security or for the actions of others if the personal data was passed to them with your authority or with the authority of anybody other than us or our affiliates.

We may also share your personal data with a potential buyer in connection with any proposed purchase, merger, or acquisition of any part of our business.

Transfer of your personal data

As we operate globally, your personal data may be transferred to countries outside the UK, European Economic Area (EEA) or Switzerland, or outside any other country from where you may access our website, for example, to the United States, Canada, India, and Hong Kong. Where the level of protection of personal data in those countries has not been deemed adequate by the European Commission (or e.g. by relevant bodies or applicable laws in the UK or in other countries outside the EEA), we will enter into a data transfer agreement with the data recipient incorporating the standard contractual clauses published by the European Commission (found at this link) (and/or any other applicable model clauses in other jurisdictions, including the UK Addendum to the standard contractual clauses published by the UK Information Commissioner's Office (found at this link). Some of the third parties engaged by us may rely on other transfer mechanisms (e.g. binding corporate rules) to provide appropriate safeguards to ensure that your personal data will remain adequately protected in accordance with applicable data protection laws.

When we need to transfer your data, we will ensure that your personal data is transferred, processed, and maintained to the standards required by Law.

You can contact us by using the contact details provided below for further information about other appropriate transfer mechanisms we may rely on.

Data Retention

We only keep your personal data for as long as is necessary to fulfil the purposes for which it has been collected.

When determining the appropriate retention period, we consider the type of personal data, type of services provided, risks of the processing, our contractual, legal, and regulatory obligations, internal data retention policies and our legitimate business interests as described in this Online Privacy Notice.

We may be required to retain certain data for the purposes of tax reporting or responding to tax queries. In other instances, there may be some other legal or risk management requirements to retain data (including legal requirements that may require us to retain it for certain minimum periods), including where certain data might be relevant to any potential litigation.

Your Rights

Subject to the conditions prescribed in applicable Laws, in relation to the personal data we hold about you, you have the right:

  • to be informed about the collection and processing of your personal data;
  • to access and request a copy of your personal data that we have collected;
  • to rectify your personal data;
  • to request erasure of your personal data;
  • to ask us to restrict processing of it; and
  • to request portability of it.

If we have obtained your consent to process your personal data, we will make it clear to you at the time of collection of your personal data that we are relying on your consent to process your personal data, and you will have the right to withdraw your consent at any time. The withdrawal of your consent will not affect the lawfulness of processing based on your consent before its withdrawal.

Subject to the conditions prescribed in applicable Laws, in relation to the personal data we hold about you, you have the right:

  • to object, on grounds relating to your particular situation, to processing of your personal data which is based on our or a third party’s legitimate interests; and
  • to object to processing of your personal data for direct marketing purposes. 

You can exercise these rights by contacting us using the contact details provided below. We will respond to your request consistent with applicable Law. To protect your privacy and security, we may require you to verify your identity.

You also have the right to lodge a complaint with a supervisory authority about our use of your personal data in the applicable jurisdiction of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes the Law.

Using Invesco websites in an anonymised or pseudonymised manner

In accordance with applicable data protection legislation, you may choose to use our websites in an anonymised or pseudonymised manner. This applies only to the extent that anonymous or pseudonymised use of the website is technically possible and reasonable.

Children’s Privacy

We are committed to protecting the privacy of children. Our Online Services are not intended for children under the age of 18.

Contact

If you have any questions about this Online Privacy Notice, please contact us via email at emea.privacy@invesco.com or in writing at the address provided below:

Global Privacy Office
Invesco Asset Management Limited
Perpetual Park
Perpetual Park Drive
Henley-On-Thames
RG9 1HH
United Kingdom

Revisions to this Online Privacy Notice

This Online Privacy Notice was last updated on 1 March 2024. We reserve the right to revise this Online Privacy Notice at any time by posting a revised version of it online.

Issuing Companies

Invesco Ltd.’s group of companies and investment funds managed by members of the Invesco Group are each controllers of your personal data under applicable data protection Laws. We, as controllers, determine why and how we collect and use your personal data. You can find the complete list of these issuing companies in our Terms & Conditions under the Site Issuers section.