LAST UPDATED: September 2018
Natixis Investment Managers is dedicated to protecting your personal data in accordance with the requirements of all applicable data privacy laws. We recognize the importance of protecting your personal information when you visit one of our websites (each, a “Website
” and collectively, the “Websites
, is designed to help you better understand the information collection practices utilized by our various Websites, as required by Regulation (EU) 2016/679 of 27 April 2016, which is commonly referred to as the General Data Protection Regulation (or “GDPR
When you visit one of our Websites, certain information may be gathered for a variety of different reasons, as described below. This information could potentially include personal data about you as an individual (“Personal Data
, and to contact us directly at the details provided below should you have any questions or concerns.
Unless specifically noted under the “Exceptions/Modifications
” section below, the information contained in this Privacy Statement is globally applicable across all of our Websites and all of our Local Offices. Who We Are
Natixis Investment Managers is the France-based holding company of a diverse line-up of specialised investment management and distribution entities worldwide (collectively referred to as "we
", or "Natixis IM
"), but each respective investment management and distribution subsidiary of Natixis Investment Managers (each, a "Local Office
") conducts any regulated activities only in and from the jurisdiction(s) in which it is licensed or authorized. Please consult our Website for a list of all our Local Offices.
Our Luxembourg-based management company, Natixis Investment Managers S.A., typically acts as the primary "controller" of any Personal Data that may be obtained through our Websites. Natixis Investment Managers S.A. is registered as a data controller with the Luxembourg Commission Nationale pour la Protection des Données
(CNPD). Natixis Investment Managers S.A.'s registered address is:
Natixis Investment Managers S.A.
2 rue Jean Monnet
Grand Duchy of Luxembourg
Natixis IM has also appointed a formal data protection officer (“DPO
”) for our group of companies, whose full contact details are set out below. Types of Information Gathered
Natixis IM processes Personal Data only where we have a lawful basis to do so. The amount and type of Personal Data collected and/or processed, as well as the processing activity itself, will vary depending upon the status of our current relationship with you and the Personal Data you choose to provide to us. Through certain of our Websites, we may receive information that you submit to us directly through various forms. This could include confirmation of your investor status under local regulations. It may also include information about your selected country of residence. We also require you to provide us with your name and email address in order to send us a message through our ‘contact us’ form located within each Website. However, we recommend that you do not include any sensitive personal data or other confidential information within the ‘message’ section of this form, as these types of public electronic communication channels are generally not secure.
We generally record certain usage information, such as the number and frequency of visitors to our Websites. This information may include data about:
- Which browser you are using
- Which pages of the Website you visit
- Your default language settings on your browser
- Your IP address
- Selections and confirmations you have provided us with previously (but only if you have specifically requested that we remember such information for the next time you visit the Website)
. If we use such data at all, it will be on an aggregate basis. However, if you are a visitor who has entered a Website via a click-through link in an email which we have sent you, or through our social media pages, additional information about you, including information about the pages you visit within the Website, the documents you download and other information which can help us personalize our future interaction with you may be collected, and in this case, the information collected about you from this Website may be associated with other identifying information that we have about you.
. Legal Basis and Purposes for Collecting and Processing Personal Data
Personal Data supplied by you, including information gathered on our Websites, are processed for the legitimate interests of Natixis IM and to comply with our legal and regulatory obligations. This information is used for the purposes set out in this Privacy Statement and directly related purposes. In particular, we use the information gathered on our Websites for the following purposes:
- to ensure that each Website complies with applicable laws and regulations;
- to ensure that our Local Offices remain compliant with applicable laws and regulations, and operate within the scope of any regulatory licenses they might hold under local financial industry regulations;
- to better understand your needs and interests, and to ensure we are displaying content that is appropriate to your investor status;
- to better customize and improve your experience when visiting our Websites;
- to analyze and improve the services we provide to you, and to provide you with additional information about which products and services we are allowed to make available to you;
- for the management and administration of our business, and
- subject to the terms set out below, for direct marketing purposes, in order to provide you with additional information about relevant products and services that we believe you may be interested in based on our prior interactions with you and/or our pre-existing business or personal relationship(s) with you.
The legitimate interests mentioned above include meeting and complying with our accountability requirements and regulatory obligations globally, and the processing purposes described in the bullet points above in order to conduct our ongoing business activities in accordance with reasonable market standards. Not Providing us with Information via a Website
for more detail in that respect). In this event however, it is possible that your ability to access certain parts of a Website, or to view certain content on our Website, may be restricted. It also means you will not be able to contact us directly through our Website using the form provided in the “Contact Us” section (in which case, please note that we provide you with numerous other ways of contacting us / your relevant Local Office). Direct Marketing
We intend to use Personal Data gathered via our Website for direct marketing of relevant financial and investment products and services, as described above. However we first need to obtain your explicit consent in order to do so. We will therefore obtain your consent before using your Personal Data for direct marketing of these products and services. Once we have obtained your consent, you may request us to cease using your Personal Data for direct marketing at any time, without charge. This will not negatively impact your ability to access our Website. You may ‘opt out’ of receiving direct marketing communications from us at any time using the contact details as provided in this Privacy Statement.
We do not provide your Personal Data to third parties for their own direct marketing purposes. Duration of Storage
How long we hold your Personal Data for will vary. The retention period will be determined by the following criteria:
- the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose;
- the length and nature of your relationship with us;
- whether there are related legal obligations to which we or one of our affiliates are subject – laws or regulation may set a minimum period for which we have to keep your Personal Data; and
- whether retention is advisable in light of Natixis IM's legal position (such as with respect to statutes of limitations, litigation or regulatory investigations).
Your Personal Data will not be retained for a period longer than necessary or permitted in light of the purpose(s) for which it was obtained (as described above), subject to the statutory limitation periods and our recordkeeping obligations set out under applicable laws and regulations. Other Recipients of Your Personal Data
We do not sell your Personal Data to anyone for our own commercial gain. We do not disclose any of your Personal Data to any third party except:
- if we are required to do so by applicable law or regulation,
- to fulfill a contract with you, or entered into for your benefit;
- at your specific request (provided such request does not violate applicable laws or regulations);
- with your prior consent; or
- as further described below.
In some cases, we may rely on our third party service providers in order to conduct our ongoing business, and in particular, to help us gather and store this information from our Websites, and for the purposes set out above. As a result, Natixis IM may need to provide your Personal Data to certain of its third party service providers. Natixis IM ensures that any such data transfers are made in accordance with the requirements of applicable laws and regulations on the protection of personal data and privacy – in particular, GDPR. In this case we ensure such third parties are contractually obligated to respect the privacy and security of any Personal Data they may have access to as a result of providing us with their services in accordance with all laws and regulations applicable to such Personal Data.
We may also transfer Personal Data between our Natixis IM affiliates, if it is necessary to do so for the purposes stated above. We take appropriate and reasonable steps to ensure that only those employees and Local Offices that have a legitimate business need for Personal Data have access to that information. We also maintain physical, electronic and procedural safeguards that comply with the appropriate local laws to protect your Personal Data. For example, we take precautions to help keep our information systems secure, including the use of firewalls for our Internet-based systems. We also use encryption technologies, user authentication systems and access control mechanisms. International Transfer of Your Personal Data
The disclosure of your Personal Data to the recipients set out above may involve the transfer of Personal Data to a different country. In particular, due to our global business model it may involve the transfer of your Personal Data to and from jurisdictions in which a Natixis IM affiliate is located, including (but not limited to) France, Luxembourg, and the United Kingdom, as well as other jurisdictions located outside the European Economic Area, such as Hong Kong, Japan, Singapore, and the United States. Please click here
for a list of the countries in which we have a Local Office.
To ensure your Personal Data is always subject to an adequate level of protection, we ensure that any cross-border transfers of your Personal Data are done in accordance with the safeguards required pursuant to the GDPR (namely, adequate contractual arrangements), in addition to any other safeguards required by applicable laws and regulations. Your Rights
You have a number of rights in relation to your Personal Data, which are set out in the table below. In particular these rights include the right to object to the processing of your Personal Data where that processing is carried out for Natixis IM’s legitimate business interests (as outlined above).
Note that in certain circumstances these rights might not be absolute.
|Right of Access
||You have the right to request a copy of your Personal Data held (either directly or indirectly) by Natixis IM and to access the information that Natixis IM holds about you (either directly or indirectly), free of any charges. However, if such request is unreasonable or excessive, Natixis IM reserves the right to charge you for making such an access request.
|Right to Object
||You have a right to object at any time to the processing of your Personal Data where Natixis IM processes your Personal Data on the legal basis of pursuing the Fund's legitimate interests.
|Right to Rectification
||You have the right to have any inaccurate Personal Data which Natixis IM holds about you updated or corrected.
|Right to Erasure
||In certain circumstances, you may also have your Personal Data deleted, for example if you exercise your right to object (see above) and Natixis IM does not have an overriding reason to process your Personal Data or if Natixis IM no longer requires your Personal Data for the purposes as set out in this Notice.
|Right to Restriction of Processing
||You have the right to ask Natixis IM to restrict processing your Personal Data in certain cases, including if you believe that the Personal Data Natixis IM holds about you is inaccurate or that Natixis IM’s use of your information is unlawful. If you validly exercise this right, Natixis IM will not carry out any other processing activities with respect to your Personal Data unless and until the issue is resolved.
|Right to Data Portability
||You may request Natixis IM to provide you with your Personal Data which you have given us in a structured, commonly used and machine-readable format and you may request Natixis IM to transmit your Personal Data directly to another data controller where this is technically feasible. This right only arises where: (1) Natixis IM processes your Personal Data with your consent or where it is necessary to perform a contract with you; and (2) the processing is carried out by automated means.
As noted above, you also have the right to withdraw your consent to our use of your Personal Data for direct marketing purposes, at any time.
It is possible that we may seek to charge you a reasonable fee in connection with a request to provide you with a copy of your Personal Data if such requests are deemed excessive or unreasonable (and only to the extent such charge is permissible under local laws and regulations). Contact Details - DPO
As noted above, Natixis IM has appointed a global DPO for the Natixis Investment Managers group of companies. If you have any questions in relation to Natixis IM’s use of your Personal Data as described in this Privacy Statement, or if you would like to submit a request with respect to your rights outlined above, please contact our DPO.
||+33 1 78 40 90 00
||Natixis Investment Managers
Attn: Data Protection Officer
43 Avenue Pierre Mendes
75648 Paris Cedex 13 France
If you are not happy with how we are treating your Personal Data for any reason, we strongly encourage you to contact our DPO to discuss these concerns. Our DPO will ensure your inquiry is addressed promptly by the appropriate parties.
You also have a right to complain to your local data protection authority or other relevant supervisory authority in those European jurisdictions where a member of the Natixis IM group of companies is registered with the national data protection authority (currently, Luxembourg and the UK). More information about this topic is available on the European Commission’s website
In addition to the contact details above, residents of Hong Kong and Singapore may also reach out to the relevant Local Office to exercise these rights, at the contact details provided below. Please note that nothing in this Privacy Statement limits your rights under local data privacy laws. Australia:
||Data Protection Officer
c/o Natixis Investment Managers Hong Kong Limited
Unit 7103B, Level 71, International Commerce Center,
1 Austin Road West,
||Natixis Investment Managers
5 Shenton Way
#22-05 UIC Building
Please note that Natixis IM may also be required to process your Personal Data where it is necessary in order to perform a contract entered into with you directly or for your direct benefit. In such case, please also keep in mind that this Privacy Statement should be read in conjunction with any other applicable policies, terms, conditions, or contractual arrangements in place between you and Natixis IM.