Privacy policy

Effective date: 08/02/2019

First Sentier Investment (US) LLC, as a member of the Mitsubishi UFJ Financial Group (MUFG), a global financial group. MUFG Group respects your concerns about privacy. This Privacy Notice describes the types of personal information we obtain about users in connection with First Sentier Investments (US) LLC products and services that link to this Privacy Notice, how we may use the information, with whom we may share it, and the choices available to users regarding our use of the information. The Privacy Notice also describes the measures we take to safeguard the personal information and how individuals can contact us about our privacy practices. This Privacy Notice does not apply to other MUFG Group products and services that post separate privacy notices.

1. How is your personal data dealt with?

In the course of doing business we outsource certain tasks to third party administrators or agents. These third parties are bound by confidentiality arrangements when handling your personal data. Your personal data may also be used by us to:

• establish your identity and assess applications for products and services
• price and design our products and services
• administer our products and services
• manage our relationship with you
• manage our risks and help identify and investigate illegal activity, such as fraud
• contact you, for example if we suspect fraud on your account or need to tell you something important
• conduct and improve our businesses and improve the customer experience
• comply with our legal obligations and assist government and law enforcement agencies or regulators
• identify and tell you about other products or services that we think may be of interest to you.

We may also collect, use, and exchange your information in other ways where permitted by law.

If you used a financial advisor in relation to your investment then details of your investments may also be provided to such financial advisor (or any replacement or additional advisor which you inform us of).

We aim to ensure that the personal information we retain about you is accurate, complete, and up to date. If you provide us with incomplete or inaccurate information, we may not be able to provide you with the products or services you are seeking.

2. What personal data do we collect?

First Sentier Investors (US) LLC collects personal data on investors, clients, intermediaries and business contacts via application forms, other First Sentier Investors (US) LLC forms, investment management agreements, correspondence, business cards, phone, fax, e-mail, and on-line. Personal data collected may include:

• your name
• your mailing address
• your phone numbers
• your e-mail address
• your personal and financial information (e.g., income, net worth, marital status, etc.)
• your social security or tax identification number

3. How we protect personal information

We maintain administrative, technical, and physical safeguards designed to protect personal information we obtain in connection with the Services against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

4. Cookies

Cookies are small data files that are sent to and stored on your computer, smartphone or other device used to access the internet, whenever you visit a website. We use cookies to enable and improve certain functions on our website and gain feedback on how our website is used. If you choose to switch certain cookies off, it will affect how our website works.

Cookies are useful because they allow a website to recognize the device you are using. As First Sentier Investors (US) LLC and its associated companies are based in various jurisdictions and operate different websites for each regional business, we use cookies to store general information such as the region where you are based, the language in which the site is being viewed (for example English, Chinese), and the type of client you are. This helps us tailor our website to better suit your requirements. The cookies we use here are ‘session’ cookies and will be removed every time you leave our website.

We use analytics cookies to collect information on website activity (such as the number of users who visit our website, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site and, when entering our website from another website, the address of that web site). This information on its own does not identify an individual but it does provide us with statistics that can be used to analyze and improve our website. These cookies are ‘session’ cookies.

The browsers of most computers, smartphones, and other web-enabled devices are usually set up to accept cookies. If your browser preferences allow it, you can configure your browser to accept all cookies, reject all cookies, or notify you when cookies are set. Each browser is different; check the "Help" menu of your browser to learn about how to change your cookie preferences.

Please remember that cookies are often used to enable and improve certain functions on our website. If you choose to switch certain cookies off, it will affect how our website works and certain functionality may not work. More information about cookies can be found on allaboutcookies.org.

5. Links to other web sites

Our web site may contain links to non-First Sentier Investors (US) LLC web sites. While such links are provided for your convenience, you should be aware that the information handling practices of the linked websites might not be the same as ours. You should review any privacy policies on those linked websites. We are not responsible for any linked websites.

6. Telephone services

We may monitor and record telephone calls for training and security purposes.

7. Data transfers

We may transfer the personal information we obtain about you to countries other than the country in which the personal information originally was collected, including the United States. Those countries may not have the same data protection laws as the country in which the information initially was provided. To the extent required by applicable law, when we transfer your personal information to recipients in other countries, we will take measures to protect that information.

8. Retention of personal information

To the extent permitted by applicable law, we retain personal information we obtain about you as long as (1) it is needed for the purposes for which we obtained it, in accordance with the provisions of this Privacy Notice or (2) we have another lawful basis for retaining that data beyond the period for which it is necessary to serve the original purpose for collecting the data.

9. Updating your information

It’s important that we have your correct details, such as your current address and telephone number. You can check or update your information by contacting your relationship manager. If the information we hold is inaccurate, incomplete or outdated, please inform us so that we can correct it. If we deny access to your personal information, we will, unless prevented by law or regulation, let you know why.

If you have any questions or would like further information on our privacy and information handling practices, please contact us.

10. Children’s personal information

We do not knowingly collect or solicit personal information from children under the age of 13. If you believe that a child under the age of 13 may have provided us with personal information, please contact us as specified in the How to Contact Us section of this Privacy Notice.

11. Updates to our Privacy Notice

This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post or provide a notice to notify you of significant changes to our Privacy Notice and indicate at the top of the notice when it was most recently updated.

12. How to contact us

If you have any questions about this Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us by e-mail at [email protected], or by phone at (212) 497-9980.

You also may write to us at:

First Sentier Investors (US)
10 East 53rd Street, Floor 21
New York, NY 10022
United States of America