References to “our”, “us”, “we” or “T. Rowe Price” within this Privacy Notice are to the T. Rowe Price entities identified as Controllers at the end of this Notice. This Privacy Notice addresses the collection and use of personal data by T. Rowe Price in relation to individuals outside of T. Rowe Price (referred to as “you” or “your” in this Notice). We may obtain your personal data in a variety of ways, such as in relation to a product or service you obtain from us, when you visit our websites, or when you are a representative of another person or entity, such as when you are an employee of a company that is our client, service provider, or counterparty.
The categories of personal data we may collect and use include:
- personal information, such as name and nickname, gender, date of birth, age, passport details, government-issued numbers and identification documents, photos, signature, nationality, and professional credentials or background;
- contact information, such as postal address, email address, and contact numbers for telephone, fax and mobile;
- employment/business information, such as the name of the company you work for and your title, location, and responsibilities;
- communications and information regarding interactions, such as communications with us on a recorded line, by email or other method, and notes of calls and meetings held or planned;
- transaction-related information, such as transaction details, instructions, account numbers for an investment fund we provide or other account, such as a bank or custodial account;
- financial and screening information, as needed, such as source of funds and information obtained in relation to anti-money laundering (AML) and terrorist financing due diligence, know your customer (KYC) activities, screenings against governmental lists, and similar background and screening checks;
- information relating to compliance matters, such as data subject requests and supporting documentation, complaints, investigations, incident details, and resolutions of such matters;
- special categories of personal data, such as information about your race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, health related information, sexual life or orientation, or criminal convictions and offences;
- technical information when you access our websites, including your IP address, your login information, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times and download errors;
- information about your visit to our websites, including the websites you visit before our websites and products or services you viewed or searched for, number of visits, length of visits to certain pages, pages viewed, page interaction information (such as scrolling, clicks and mouseovers) and methods used to browse away from the page, and similar information for additional content that T. ROWE PRICE | 2 can be accessed from website pages, such as opening or printing documents or which videos are played and for how long; and
- preferences and views, such as marketing preferences, preferred language, and views shared with us.
How we use personal data
Your personal data is intended for T. Rowe Price and may be shared with T. Rowe Price affiliates and subsidiaries and in certain circumstances with third parties.
- T. Rowe Price’s family of companies. We may share your personal data among our family of companies, including our subsidiaries and affiliates, in order to administer our services and products, provide you with customer support, understand your preferences, send you information about products and services that may be of interest to you (with your consent when required), and conduct the other activities described in this Privacy Notice.
- External auditors, accountants, and legal and other professional advisors.
- Our service providers.We use other companies or contractors to perform services on our behalf or to assist us with the provision of the T. Rowe Price products or services to you. We may share personal data with the following categories of Service Providers:
- Infrastructure and technology service providers;
- Marketing, advertising, analysis, research, event and communications providers;
- Providers of administrative services for T. Rowe Price products or services, such as transfer agencies, custodians, and securities’ pricing providers.
- Third parties permitted by law. In certain circumstances, we may be required to disclose or share your personal data in order to comply with a legal or regulatory obligation (for example, we may be required to disclose personal data to the police, regulators, government agencies or to judicial or administrative authorities). We may also disclose your personal data to third parties where disclosure is both legally permissible and necessary to protect or defend our rights, matters of national security, law enforcement, to enforce our agreements or protect your rights or those of the public.
- Your company or agents and other third parties. We may transfer your personal data to your company or other agent, such as when you are included on an email with others or to confirm your details or role. We also may transfer your information to third parties connected with your company or an account or in relation to business transactions we have with you or your company.
- Third parties connected with business transfers. We may transfer your personal data to third parties (including existing or newly-formed companies in the T. Rowe Price family of companies) in connection with a reorganisation, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal data in a manner consistent with this Privacy Notice.
- Access. You may have the right to confirm with us whether your personal data is processed, and if it is, to request access to that personal data including the categories of personal data processed, the purpose of the processing and the recipients or categories of recipients. We do have to take into account the interests of others though, so this is not an absolute right, and if you want to request more than one copy we may charge a fee.
- Rectification. You may have the right to rectify inaccurate or incomplete personal data concerning you.
- Deletion. You may have the right to ask us to erase personal data concerning you, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
- Restriction. In limited circumstances, you may have the right to request that we restrict processing of your personal data. This may apply where you believe such data to be inaccurate, our processing is unlawful or that we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it. In such case, we would mark stored personal data with the aim of limiting particular processing for particular purposes in accordance with your request, or otherwise restrict its processing.
- Portability. You may have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that data to another entity.
- Objection. Under certain circumstances you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling, by us and we can be required to no longer process your personal data. This may include requesting human intervention in relation to an automated decision (when applicable) so that you can express your view and to contest the decision.
- Make a Complaint. You also have the right to lodge a complaint with the competent data protection supervisory authority, which in Luxembourg is the Commission Nationale pour la Protection des Données (the ‘CNPD’) or in the UK is the Information Commissioner’s Office (the ‘ICO’). If you are T. ROWE PRICE | 6 based in, or the issue you would like to complain about took place elsewhere in the European Economic Area (EEA) or Switzerland, a list of other local data protection authorities in these locations can be found here. If you are based in, or the issue you would like to complain about relates to any other location, please contact us as stated below (Contact us).
While we endeavour to always protect our systems, sites, operations and information against unauthorised access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.
T. Rowe Price International Ltd
60 Queen Victoria Street
London EC4N 4TZ
United Kingdom
T. Rowe Price UK Limited
60 Queen Victoria Street
London EC4N 4TZ
United Kingdom
T. Rowe Price (Luxembourg) Management S.à.r.l.
35, Boulevard du Prince Henri
L-1724 Luxembourg
Grand Duchy of Luxembourg
T. Rowe Price (Switzerland) GmbH
Talstrasse 65
8001 Zurich
Switzerland
T. Rowe Price SICAV(s)*
35, Boulevard du Prince Henri
L-1724 Luxembourg
Grand Duchy of Luxembourg
T. Rowe Price FCP(s)*
35, Boulevard du Prince Henri
L-1724 Luxembourg
Grand Duchy of Luxembourg
T. Rowe Price OEIC(s)*
60 Queen Victoria Street
London EC4N 4TZ
United Kingdom
Global Privacy Office
T. Rowe Price
60 Queen Victoria Street
London
EC4N 4TZ
Global_Privacy@troweprice.com