Privacy policy

Capital Group (“CG”, “we” or “us”) considers your privacy to be of fundamental importance and has established this Privacy Policy (the “Policy”) to maintain the privacy of the information you share with us in accordance with applicable data privacy laws.

This Policy explains the collection, use, sharing and otherwise processing of your Personal Data

(i)  as a visitor of this website,
(ii) in connection with your investment in CG funds (the “Funds”):

  • for Luxembourg domiciled UCITS funds offered by Capital International Management Company Sàrl, or
  • for Australian domiciled funds offered by Capital Group Investment Management Limited (“CGIML”) ABN 73 164 174 501.


(iii)  in connection with investment services:

  • in Singapore offered by Capital Group Investment Management Pte. Ltd. (“CGIMPL”),
  • in Hong Kong offered by Capital International, Inc. (“CIInc”), or
  • in Australia offered by CIInc ARBN 148 215 570,


(iv) in connection with shareholder and local fund representative services:

  • CGIMPL and CIInc in its capacity as Representative of the Luxembourg domiciled UCITS funds in Singapore and Hong Kong respectively, or


(v) in connection with your business relationship with CG in accordance with applicable laws and regulations. CIInc, CGIMPL, CGIML, the Funds and/or any other CG company with which you have a relationship will be the data controllers or joint controllers for the purposes of this Policy.

This Policy shall further inform you about your rights and choices in connection with our use of your Personal Data.

The term “Personal Data” as used in this Policy means any information (whether recorded in an electronic means or otherwise) relating to you as an individual and from which you can be identified.

We only collect Personal Data that is reasonably necessary for us to provide our products and services. If you do not provide the information that we ask for, we may not be able to provide the products or services you have requested.

For the purposes described below, we might collect and use your Personal Data, which can be grouped in the following categories, as may be relevant:

  • Contact information: your name and contact details, including telephone number, email address, postal address and/ or business contact information.
  • Information related to regulatory requirements: in particular Anti-Money Laundering (“AML”)/ Know-Your-Customer (“KYC”) information, which may include your contact information, date of birth, passport or ID card, copies of household bills and any other information or data as required by applicable laws and regulations.
  • Information related to your relationship with us: information received through agreements, application forms (completed in writing or electronically), which may include your contact information and tax identification number, your current and historic investments (including transaction and account history), investment preferences and investment amount, communications regarding your investment, any information, data or records that relate to your CG account or use of CG’s website.
  • Information collected when you visit our website: your online identifier (IP address) and your contact details where you register for any of our events or services online.

 

CG, as well as our distributors and sub-distributors, and the Transfer and Administrative Agent of the Funds will seek to collect directly from you your Personal Data which you may provide to us in the course of our services, your investment in the Funds and when visiting our website. CG may also collect such Personal Data provided by your employer, by our Transfer Agent when you invest in the Funds, or through publicly accessible sources such as social media, subscription services, Dow Jones database, sanction lists, centralised investor database and public registers.

If you have accessed the “Institutional” or “Intermediaries” areas of our website, we will limit the collection and use of your Personal Data to what is necessary to administer our business and provide you with the highest quality service. We will not disclose any Personal Data except in the limited circumstances specifically described below. Any Personal Data disclosed to CG will be retained for so long as it is needed to fulfil any contractual obligations or services to you or comply with externally imposed legal/regulatory obligations.

We do not seek to collect and/ or process your sensitive Personal Data except where required and necessary for compliance with a legal obligation, where you have made such data publicly available or where we have obtained your explicit consent.

We may collect your Personal Data for the following purposes and processes:

    Purpose for processing                                                     Legal basis for processing

Servicing of clients and/ or shareholders in our Funds: provide sales reporting and account statements, perform account openings/ closures and invoicing, monitor cash-flows, reporting to clients/ shareholders etc.

For Australia

  •  Processing is in accordance with the stated purpose as notified to you, and is reasonably necessary for, or directly related to, one or more of our functions or activities.


For Hong Kong

  • Processing is in accordance with the stated purpose as notified to you.


For Singapore

  • We have obtained your prior consent to the processing; or
  • We have assumed deemed consent from you (i) where, without actually giving consent, you voluntarily provide your Personal Data for the stated purpose, and/or (ii) where it is reasonable that you would have voluntarily provided such Personal Data to us, and the collection, use or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract between you and us or any other organization entered into at your request.

Provision of our Funds and services: administering relationships and related services; performance of tasks necessary for the provision of the requested services; communicating with you in relation to those services.

For Australia

  •  Processing is in accordance with the stated purpose as notified to you, and is reasonably necessary for, or directly related to, one or more of our functions or activities.


For Hong Kong

  • Processing is in accordance with the stated purpose as notified to you.


For Singapore

  • We have obtained your prior consent to the processing; or
  • We have assumed deemed consent from you (i) where, without actually giving consent, you voluntarily provide your Personal Data for the stated purpose, and/or (ii) where it is reasonable that you would have voluntarily provided such Personal Data to us, and the collection, use or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract between you and us or any other organization entered into at your request.

Offering investment in shares and performing the related services as described in the relevant Fund’s prospectus, account opening forms and any other agreement with other CG companies and third parties, including but not limited to: the opening of your account with the Funds, the management and administration of your holdings and any related account on an on-going basis, and the operation of the Funds’ investment in sub- funds, including processing subscriptions and redemptions, conversion, transfer and additional subscription request, the administration and payment of distribution fees (if any), payments to shareholders, updating and maintaining records and fee calculation, maintaining the register of shareholders, providing financial and other information to the shareholders.

For Australia

  •  Processing is in accordance with the stated purpose as notified to you, and is reasonably necessary for, or directly related to, one or more of our functions or activities.


For Hong Kong

  • Processing is in accordance with the stated purpose as notified to you.


For Singapore

  • We have obtained your prior consent to the processing; or
  • We have assumed deemed consent from you (i) where, without actually giving consent, you voluntarily provide your Personal Data for the stated purpose, and/or (ii) where it is reasonable that you would have voluntarily provided such Personal Data to us, and the collection, use or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract between you and us or any other organization entered into at your request.

On-boarding of clients and/ or shareholders in our Luxembourg, Australian and United Kingdom Funds: Your Personal Data might be collected for the establishment of AML/ KYC files, to perform sanctions screenings, compliance with our internal compliance requirements, policies and procedures.

For Australia/Hong Kong

  • Processing is in accordance with the stated purpose as notified to you, and is necessary for compliance with a legal or regulatory obligation.


For Singapore

  • Processing is necessary for compliance with a legal or regulatory obligation; or
  • We have assumed deemed consent from you (i) where, without actually giving consent, you voluntarily provide your Personal Data for the stated purpose, and/or (ii) where it is reasonable that you would have voluntarily provided such Personal Data to us, and the collection, use or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract between you and us or any other organization entered into at your request.

Direct or indirect marketing activities and prospecting: preparation of mailings (information about CG, promotion of new funds/ products, etc.), events, market research, communicating with you via any means (including via email, telephone, text message, social media, post or in person), subject to ensuring that such communications are provided to you in compliance with applicable laws and regulations; and maintaining and updating your contact information where appropriate.

For Australia/Hong Kong

  • We have obtained your prior consent to the processing where it is entirely voluntary, not necessary or compulsory in any way, and in accordance with the stated purpose as notified to you.


For Singapore

  • We have obtained your prior consent to the processing where it is entirely voluntary and not necessary or compulsory in any way; or
  • We have assumed deemed consent from you (i) where, without actually giving consent, you voluntarily provide your Personal Data for the stated purpose, and/or (ii) where it is reasonable that you would have voluntarily provided such Personal Data to us, and the collection, use or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract between you and us or any other organization entered into at your request. 

Publishing: promotional material/ reports for use with clients and prospects.

For Australia/Hong Kong

  • We have obtained your prior consent to the processing where it is entirely voluntary, and not necessary or compulsory in any way; or
  • Processing is in accordance with the stated purpose as notified to you.


For Singapore

  • We have obtained your prior consent to the processing where it is entirely voluntary and not necessary or compulsory in any way; or
  • We have assumed deemed consent from you (i) where, without actually giving consent, you voluntarily provide your Personal Data for the stated purpose, and/or (ii) where it is reasonable that you would have voluntarily provided such Personal Data to us, and the collection, use or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract between you and us or any other organization entered into at your request.

Operating our website and ensuring the security of our website: operation and maintenance of websites, provision and update of website content, tracking and profiling of website visitors, log-in area for institutional clients, advertising and/ or other information to you.

For Australia

  • Processing is reasonably necessary for or directly related to the proper administration of our funds, business and website.


For Hong Kong

  • Processing is in accordance with the stated purpose as notified to you.


For Singapore

  • We have obtained your prior consent to the processing where it is entirely voluntary and not necessary or compulsory in any way; or
  • We have assumed deemed consent from you (i) where, without actually giving consent, you voluntarily provide your Personal Data for the stated purpose, and/or (ii) where it is reasonable that you would have voluntarily provided such Personal Data to us, and the collection, use or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract between you and us or any other organization entered into at your request.

Compliance with legal and regulatory obligations as per applicable laws: to carry out any form of cooperation with, or reporting to, public authorities including, but not limited to, legal obligations under applicable fund and company law, prevention of terrorism financing, anti-money laundering law, prevention and detection of crime, tax law (such as reporting to the tax authorities under FATCA and CRS Law to prevent tax evasion and fraud), and to prevent fraud, bribery, corruption and the provision of financial and other services to persons subject to economic or trade sanctions on an on-going basis in accordance with relevant internal anti-money laundering policies and procedures, as well as to retain your AML and other records for the purpose of screening in relation to other funds or clients.

For Australia/Hong Kong/Singapore

  • Processing is in accordance with the stated purpose as notified to you, and is necessary for compliance with a legal or regulatory obligation.

Managing our business relationship: communicating with you regarding your services.

For Australia

  • Processing is in accordance with the stated purpose as notified to you, and is reasonably necessary for, or directly related to, one or more of our functions or activities.


For Hong Kong

  • Processing is in accordance with the stated purpose as notified to you.


For Singapore

  • We have obtained your prior consent to the processing; or
  • We have assumed deemed consent from you (i) where, without actually giving consent, you voluntarily provide your Personal Data for the stated purpose, and/or (ii) where it is reasonable that you would have voluntarily provided such Personal Data to us, and the collection, use or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract between you and us or any other organization entered into at your request.

The purposes listed above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

Profiling means the automated processing of Personal Data, such as the use of cookies, to evaluate certain things about the users of our websites. Profiling can be part of an automated decision-making process which means that a decision is solely made by automated means without any human involvement.

We will only engage in profiling and automated decision-making where it is necessary to enter into, or to perform, a contract with you, or where you have given your explicit consent, or where it is authorised by law. You can always express your opinion or contest decisions based solely on automated processing, including profiling, if such a decision would produce legal effects or otherwise similarly significantly affect you. When using automated decision-making we will provide you with further information about the logic involved, as well as the significance and the envisaged consequences to you.

When using the public areas of our website, through the use of cookies we may track the number of users who visit the public areas of the website and may also record the location of your computer on the internet for systems administrative and trouble-shooting purposes and to report aggregate information. We may collect and store certain navigational and transactional information, such as page hits and PDF files you view, and the times and ways you use this website. We use navigational information to personalize our website, for programming, editorial and financial research and to offer new content that our users may like. For the use of cookies on our website we further refer you to our Cookie Policy.

 

We may disclose your Personal Data to other CG companies (this means our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this Policy.

To service our clients’ and shareholders’ accounts, your Personal Data may be disclosed or transferred within Capital Group and in certain circumstances to third parties and service providers, where permitted by laws and regulations. We may need to disclose your Personal Data to our auditors and/or professional advisers insofar as reasonably necessary for the purposes of the performance of our statutory or prudential audit or managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

Please note that we may use or disclose your Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal processes. In addition to the specific disclosures of Personal Data set out in this section, we may disclose your Personal Data where such disclosure is necessary for compliance with a legal obligation to which we are subject.

We restrict access to your non-public Personal Data to authorised employees. We maintain physical, electronic and procedural safeguards to guard your non-public personal information. While we strive to protect our customers' and users' Personal Data and privacy, we cannot guarantee the security of any information you disclose online. We do not accept any liability for information which has been obtained through unauthorised access to the website.

For the purposes described above, we may have to transfer your Personal Data to a CG affiliate or a third party which may be located outside of the country where your Personal Data was originally collected. To enable us to act as an integrated global business, your Personal Data may be transferred to, for example, the European Economic Area (“EEA”), United-Kingdom, Singapore, Hong Kong, Australia or the United States, or a jurisdiction which may offer a different level of protection from the source location. However, we will ensure that adequate security measures are taken, in accordance with this Policy and applicable laws and standard contractual clauses. CG further ensures that third parties with whom we share your Personal Data are under contractual obligations to protect the confidentiality of your Personal Data, and to use it solely to provide services we have mandated them with.

We will only retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying contractual obligations and legal, regulatory, accounting, tax or other reporting requirements. Where we keep your Personal Data for compliance with legal and regulatory obligations as per applicable laws and regulations, such as for AML/ KYC, we keep your Personal Data only if necessary and for the duration required under applicable laws and regulations. Please note that data retention obligations might differ within CG as they are subject to applicable local laws and regulations.

Subject to applicable laws, as an individual you have the following rights, which you can exercise under certain circumstances in relation to your Personal Data which we hold:

  • You have the right to access your Personal Data which we are keeping. Your right to access may, however, be restricted by applicable laws and regulations, the protection of other individual’s privacy and considerations for our business practices.
  • You have the right to request a copy of your Personal Data and request certain information relating to its processing.
  • You have right to receive your Personal Data in structured, commonly used and machine-readable format (right to data portability).
  • You have the right to ask us to rectify, amend, delete or have us completely remove your Personal Data from our database. We may not always be able to comply with your deletion request for specific legal reasons that will be notified to you, if applicable, when we respond.
  • You have the right to object and/or request a restriction of processing of your Personal Data.
  • You also have the right to make a complaint to us or to the competent supervisory authority for data protection issues.
  • If you have provided consent to the collection, processing and/or transfer of your Personal Data, you have the right to fully or partly withdraw your consent. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. Please note that withdrawing consent does not affect our right to continue to collect, use, disclose or otherwise process personal data where such collection, use, disclosure or processing without consent is permitted or required under applicable laws.  

We may ask you for additional information to confirm your identity and for security purposes before disclosing the Personal Data requested by you. We will not charge any administration fee for such a request unless the request is deemed unnecessary or excessive in nature.

 

Should you have any question about this Policy, wish to exercise your above listed rights, or are unhappy with how we handled your Personal Data, you can contact us by emailing  dataprotectionofficer_Asia@capgroup.com

This Policy is dated May  2024.

Any changes we make to this Policy in the future will be posted on this page, and where appropriate, notified to you by e-mail.

Australia Only

If you wish to contact us for any purpose regarding this Policy including making complaint about the way we have handled your Personal Data (including if you think we have breached the Privacy Act) you may do so to our Data Protection Officer in writing, by mail to Data Protection Officer, Capital Group, Gateway Suite 4201, Level 42, 1 Macquarie Place, Sydney NSW 2000, or by email to dataprotectionofficer_Asia@capgroup.com. When you contact us, please include your email address, name, address and telephone number and clearly describe your complaint. Our Data Protection Officer will investigate the complaint and respond to you promptly. If you consider that we have failed to resolve the complaint satisfactorily, and you are an individual located in Australia, you can complain to the Office of the Australian Information Commissioner.