Federated Hermes, Inc. Privacy Policy

Introduction

Federated Hermes, Inc. and its subsidiaries (the “Federated Hermes Group”) are committed to protecting and respecting your privacy.  This Notice is the privacy notice of Federated International Management Limited (“FIML”) and each of the funds it manages, being Federated Hermes International Funds plc, Federated Unit Trust and Federated Alternative Funds ICAV (the “Funds”), individually and collectively as appropriate “we”, “our” and “us”.

This Notice (together with any other documents referred to in it) sets out the basis on which we collect, use and process the personal data of or relating to our clients and prospective clients (“clients”), and in the case of an institutional client, your personnel or persons connected with you, as well as users of the website (http://fiml.federatedinvestors.com) and other websites we operate (“website users”) (collectively or individually as appropriate, “you” and/or “your”) as a data controller.  Please read this notice carefully and, if you have any questions or specific concerns regarding our treatment of personal data or wish to contact us regarding your personal data, please contact us.

Contact Details

Post:

Federated International Management Limited,
c/o BNY Mellon Fund Services (Ireland) Designated Activity Company,
One Dockland Central,
Guild Street,
International Financial Services Centre,
Dublin 1,
DO1 E4X0
Republic of Ireland

Calls and communications with us will be recorded and monitored.  A copy of conversations and communications relating to products in which a client invests or services we provide to a client will be retained and may be made available to the client upon request for a period of five years.

Controllers of your data

Where we collect personal data of or relating to our clients and website users for the purposes set out in this Notice, we are the “data controller” of that personal data.  As a data controller we are subject to requirements under applicable data protection law and regulation, including the General Data Protection Regulation ((EU) 2016/679) and the Data Protection Act 2018, and any other legislation in force from time to time in the Republic of Ireland that makes provision for the regulation of the processing of personal data.

Circumstances may arise in which third parties process your personal data as data controller, including in connection with any investment you make.  Any such processing is not governed by this notice, but by the data privacy notices and policies of the relevant third parties concerned.

Personal data we may collect

Personal data refers to any data relating to a living individual where we can identify the individual from that data or from other information which is in our possession or is likely to come into our possession.  In the case of an institutional investor, the personal data we hold may relate to the institutional investor’s personnel or other persons connected with them (for example directors, officers, employees, representatives, shareholders, beneficial owners or agents).

We collect personnel data of or relating to our clients and website users in connection with the provision of investment products and services as part of our professional activities.  We may collect personal data in the following ways:

  • From application forms completed by clients and agreements we enter into with clients in relation to our investment products and services, and the products and services of the Federated Hermes Group.
  • From your communications with us whether in writing (including by email, fax and, post), by telephone or in person.
  • Through your use of our website (http://fiml.federatedinvestors.com) and the other websites we operate (see Important Legal Information and Cookie Policy).
  • Through analysis of your investments in our products and use of our services, and the products and services of the Federated Hermes Group.
  • From third parties, including: (i) service providers to our products (including any transfer agent, registrar, fund administrator, depositary, custodian and paying agent); (ii) your services providers (including any investment adviser, discretionary investment manager, distributor, platform or other intermediary); and (iii) other third parties (including credit reference agents, government agencies, company registries, and network applications such as LinkedIn).

The type of personal data we may collect includes the following:

  • Your name, title and contact details (address, e-mail address, phone number and fax number).
  • Date of birth, identification information/numbers, residency details, and copies of identification documents (such as drivers licence and/or passport).
  • Details related to your employment (such as job title, function and work related responsibilities), employment history, and professional qualifications.
  • Account numbers and other account related information, and taxation information and tax forms.
  • Details relating to your investment activity, experience, the previous transactions you have entered into, and holdings.
  • Any other personal data you may send or disclose to us, for example, via your Federated customer relationship contact.

Our use of personal data

We may use personal data in the following ways:

  1. To provide our products and services to you, including the management and administration of any investment in our products, our provision of services to you, and any related accounts on an ongoing basis in accordance with our agreement with the client.
  2. To comply with legal and regulatory obligations applicable to us, the Federated H ermesGroup and our products from time to time, including: (i) carrying out anti-money laundering checks and related actions in relation to the prevention of fraud, money laundering, terrorist financing, bribery, corruption and 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 our anti-money laundering procedures; (ii) reporting information with relevant tax authorities, and (iii) providing information to supervisory authorities or regulators such as the Central Bank of Ireland (“CBI”).
  3. For the purpose of establishment, exercise or defence of legal or regulatory claims or actions in order to pursue our legitimate interests or those of the Federated Hermes Group in such matters.
  4. To disclose information to third parties including service providers, auditors and technology providers in order to comply with any legal obligation imposed on us or the Federated Hermes Group, or in order to pursue our legitimate interests or those of the Federated Hermes Group.
  5. To identify you when you contact us or a company within the Federated Hermes Group.
  6. To update and maintain records regarding our clients and for internal records management.
  7. To carry out analysis including: (i) business and statistical analysis, and market research; (ii) to review our products and services and those of the Federated Hermes Group; (iii) to review the content of our website and other websites of the Federated Hermes Group; and (iv) for quality control and training purposes.
  8. To operate and administer our website and other websites of the Federated Hermes Group, including maintaining the safety and security of websites and IT architecture, investigating suspected security breaches, and for internal operations such as troubleshooting, data analysis, testing, research, statistical and survey purposes.
  9. To provide you with information about products and services which may be of interest to you.

For points 5 to 9 above, and wherever we otherwise act pursuant to our legitimate interests, such usage shall occur where this is necessary for our legitimate interests or those of the Federated Hermes Group or a third party and such legitimate interest is not overridden by your interests, fundamental rights or freedoms.

Given the specific purposes for which we envisage using your personal data, we do not anticipate being required to obtain your consent to do so, save for where we wish to use your personal data to provide you with information about products and services which may be of interest to you, and we are required by applicable law to seek your consent before we do so.  If you have nevertheless provided (and we have relied upon) your consent to process your personal data, you may withdraw your consent at any time by contacting us (see contact details above).  If you do so and no other legal basis exist upon which we can process your data, we will apply your preferences going forward.  This will not affect the lawfulness of any processing carried out before you withdrew your consent.  In some circumstances, withdrawing your consent or objecting to the processing of your personal data, or requesting its deletion, will mean that you cannot take advantage of certain of our products or services, and we may need to suspend or terminate your access to, our products, services and our website.

Disclosure of your personal data

We may disclose your personal data to the following recipients or categories of recipients:

  • To other companies within the Federated Hermes Group.
  • To third parties including: (i) our delegates, agents, sub-contractors, service providers, vendors and business partners; (ii) persons providing services or functions in relation to our products (including any transfer agent, registrar, fund administrator, depositary, custodian, paying agent, auditor, and legal and other professional adviser); and (iii) your delegates, agents, sub-contractors, service providers (including in relation to a client any investment adviser, discretionary investment manager, distributor, platform or other intermediary, auditor, and legal and other professional adviser) and any other person you involve in connection with our products or services.
  • In the event that the Federated Hermes Group sells or buys any business or assets, to the prospective seller or buyer, and if Federated Hermes Group sells all or substantially all of its assets, personal data held by it will be one of the transferred assets.
  • To competent authorities (including tax authorities such as the Office of the Revenue Commissioners, and regulatory bodies such as the CBI), or to other persons for the purposes of making regulatory filings, submissions or reports, or in connection with any regulatory or supervisory action or internal investigation or review.

Transfer of personal data ouside the EEA

We may transfer personal data to countries outside of the European Economic Area which may not have the same or equivalent data protection laws as Ireland.  If such transfer occurs, we are required to ensure that such processing of personal data is in compliance with applicable data protection law and regulation and, in particular, to ensure that appropriate measures are in place such as entering into model contractual clauses (as published by the European Commission).  By way of example, transfers to other companies within the Federated Hermes Group are, where necessary, made pursuant to the model contractual clauses for controller-to-controller transfers, or controller-to-processor transfers (depending on the context of the transfer).

If you wish to receive more information on the means of transfer of your personal data, please contact us (see contact details above).

Your rights

Persons about whom we hold personal data have a number of rights which may be exercised in respect of their personal data, including the following:

  • The right of access to personal data held by us.
  • The right to amend and rectify any inaccuracies in personal data held by us.
  • The right to erase personal data held by us.
  • The right to data portability of personal data held by us.
  • The right to request restriction of the processing of personal data held by us.
  • The right to object to processing of personal data by us.

These rights will be exercisable subject to limitations as provided for under applicable law and regulation.  In certain circumstances it may not be feasible for us to discharge these rights, for example because of the structure of the products in which a client is invested or the manner in which the client holds its interest in the product.  Please note, for example, that the right for your data to be erased (the "right to be forgotten") is not likely to be applicable to most, if not all, of the personal data we hold in relation to an investment given the specific nature of the purposes for which we use that data, as described above.

You may make a request to us to exercise any of your rights by contacting us (see contact details above).  We will need to verify the identity of the person making the request before we can respond to the request.

Retention of personal data

We will retain your personal data for as long as is necessary for the purposes described above, and to comply with legal, regulatory, accounting or reporting requirements, and for or in case of any legal claims.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

For more information about the retention periods which we apply for specific personal data we hold about you, please contact us (see contact details above).

Making a complaint regarding data protection

If you have any concerns about our use of your personal data or the exercise of your rights in relation to that data, you can contact us directly (see contact details above).  If you are not satisfied with the way we handle your complaint, you may raise your complaint directly with the Irish Data Protection Commission, whose details are available on its website (http://www.dataprotection.ie).

Changes to our Privacy Notice

Any changes we may make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail.  You should check this page periodically for changes.