At Aberdeen Asset Management PLC and all of its affiliates (hereinafter referred to as “Aberdeen”, “we” or “us”) aim to protect the privacy of every current, former and prospective client as far as possible. This Privacy and Cookies Policy (the “Policy”) describes the type of personal information we may collect, the purposes for which we use the information, the circumstances in which we may share the information and the steps we take to safeguard the information to protect your privacy.
In Canada, privacy legislation has been enacted at both the federal and provincial levels, and Aberdeen is subject to each of these laws, depending on the province of residence of its account holders.
1. The personal information we collect and how we use it
We may collect information about you and use it in the following ways:
- We may collect personal information about you from applications or forms you may complete, agreements you enter into with us or in the course of your establishing or maintaining a client relationship with us regarding an investment product or vehicle including your name, postal and email address, debit card details, ongoing statements and other related information. This is to allow us to complete your transaction and also to provide confirmation of the transaction to you.
- When you browse the website we will store information as to how you use the website in order to improve the quality of service provided to you. For example, it will allow us to decide the most appropriate site layout and navigation.
- We may collect information concerning the attachments you open with newsletters that are sent to you electronically.
- We also use the information we collect in order to inform you about changes to the website and, subject to any applicable local laws, other information that we think may be of interest and/or useful to you including our products and services.
Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may limit our ability to provide you with the full range of services and features offered by Aberdeen.
2. To whom we disclose the personal information
Aberdeen does not disclose your personal information to third parties, except as described in this Policy, or as required or permitted by law.
Third party disclosures may include sharing such information with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to Aberdeen. These companies are required to ensure appropriate security measures are in place and maintain the confidentiality of such information to the extent they receive it, and to use your personal information only in the course of providing such services and only for the purposes that Aberdeen dictates.
These non-affiliated companies, however, may be located outside of Canada. Accordingly, any transferred personal information will be subject to local laws. We may also disclose your personal information to fulfil your instructions or pursuant to your express consent.
Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations, for instance, when responding to proceedings of a court of law or similar legal process, to protect against fraud, and to otherwise cooperate with law enforcement or regulatory authorities.
You should know that Aberdeen does not sell your personal information.
3. Accessing and updating your personal information
You have the right to access your personal information at any time to check whether it is accurate and up-to-date and should contact our Data Protection Officer at email@example.com, if you wish to do so.
4. Timely processing of the information
We will retain your personal information in accordance with applicable laws for only so long as it is needed, after which it is erased or otherwise securely destroyed.
5. Cookies Policy
Cookies are small text files, which often include a unique identifier that is sent by a web server to your computer, mobile phone or any other internet enabled device (“device”) when you visit a website. Cookies are widely used in order to make websites work efficiently and help provide us with business and marketing information to enable us to make informed decisions on the development of our websites. We may collect information about your computer, including your IP address, operating system and browser type, for system administration and in order to create reports. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
We use three main types of cookies: (1) ‘Performance’ cookies (2) ‘Identification’ cookies (3) ‘Targeting’ cookies
‘Performance’ cookies are used to help us see how you use our website e.g. which pages you visit. These cookies don't collect any information that could identify you – all the information collected is anonymous and is only used to help us improve the performance of our website, understand what interests our users and measure how effective our advertising is. We use performance cookies to analyse the performance of our website, to help us improve the website by measuring any errors that occur and to see how effective our adverts are (this isn’t shared with 3rd parties). Sometimes cookies are managed for us by third parties, but we don’t allow the third party to use the cookies for any purpose other than those listed above. By using our site, you accept the use of ‘Performance’ cookies.
‘Identification’ cookies are used to help us customize website content based upon your selections. We use identification cookies to remember choices you have made, to show you when you’re logged in to the website and to target you with adverts on other websites. You can control whether or not these cookies are used, but preventing them may mean you are unable to access certain features or services. Preventing these cookies may stop us remembering that you didn't want a specific feature or service. By using our site you accept the use of 'Identification' cookies.
‘Targeting’ cookies are used to send you relevant information and see which content you use. We use targeting cookies to send you customised news content via email, to track which content you use and to target you with adverts on other websites. By using our site you accept the use of 'Targeting' cookies.
The site also has Social Interaction links (such as Facebook or YouTube). Aberdeen does not control any cookies that may be sent when using these external websites. For more information on these it is advised to check their cookie policies.
At any point, you have the right to request that we do not use or process your personal information for any purpose; however doing so may limit our ability to provide you with all services and features offered by Aberdeen.
You can opt-out of the Google Display Advertising Features and customise Google Display Network ads using the Ad Settings. As an added privacy measure, you can also use the Google Analytics opt-out browser add on. However, please note that if you do this you may not be able to use the full functionality of this website.
You have the ability to accept or decline cookies by modifying the preference settings for your browser. Our site is viewable even if you disable the cookie function on your browser. However, if you disable cookies, some advanced and customized features may not be available to you. To remove other cookies from your device, you can use these guides:
- Internet Explorer: https://support.microsoft.com/en-us/kb/278835#/en-us/kb/278835
- Chrome: https://support.google.com/chrome/answer/95647?hl=en
- Safari: https://support.apple.com/kb/PH17191?locale=en_GB
- Firefox: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
- Guidelines on Privacy and Online Behavioural Advertising: https://www.priv.gc.ca/information/guide/2011/gl_ba_1112_e.asp
- Information about cookies: http://www.allaboutcookies.org
- Internet Advertising Bureau (Canada): http://iabcanada.com/guidelines/adchoices
We utilise a number of different cookie variations that serve a number of different functions. These tables identify the types of cookies that we use and why we use them.
Google Analytics Premium
This website uses Google® Analytics Premium, a web analytics service provided by Google Ireland Limited (“Google”). Google Analytics Premium uses “cookies”, which are text files placed on your computer, to help the website interact how users use the site. On behalf of the operator of this website Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. The IP address collected through Google Analytics will not be associated with any other data held by Google.
Google is a registered trademark of Google, Inc. Google, Inc. is not affiliated with Aberdeen Asset Management PLC, nor does it sponsor or endorse Aberdeen Asset Management PLC products or services.
Uses of Google Analytics Premium
In order to improve our users’ experience, we may use Google Analytics features such as Remarketing, DoubleClick Campaign Manager Integration, Google Display Network Impression Reporting and/or Google Analytics Demographics and Interest Reporting (Google Display Advertising Features).
Information collected by our cookies will not personally identify you. It does, however, identify your computer and connection to the Internet. We only collect general information about your computer settings, connection to the Internet (e.g. operating system and platform), IP address, browsing patterns, and interactions within our site.
With regards to Google Analytics Demographics and Interest Reporting, we may use data from Google's Interest-based advertising and/or third party audience data (e.g. age, gender and interests) with Google Analytics to target and optimise our marketing campaigns, strategies and our site content.
|Google Analytics||doubleclick.net||id||Analytics - DoubleClick’s integrated and open platform lets you bring all your audience insights together in one place. With a complete, real-time view of your audience, you can engage the people you care about most to maximize the impact of your advertising dollars. Channel ID - purpose is for local storage. id - This cookie is used for re-targeting, optimisation, reporting and attribution of online adverts.|
|accounts.google.com||GAPS||GAPS = Google calendar. Google set a number of cookies on any page that includes a Google Calendar. While we have no control over the cookies set by Google, they appear to include a mixture of pieces of information to measure the number and behaviour of Google Calendar users, as well as information about which calendar you are viewing, and which tab you are currently on. Also, Google uses these cookies to improve your user experience.|
|Country Site||_ga||ga - This cookie is used to distinguishes unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. By default it is set to expire after 2 years, although this is customisable by website owners.|
|_gat||_gat - This cookie name is associated with Google Universal Analytics, according to documentation it is used to throttle the request rate - limiting the collection of data on high traffic sites. It expires after 10 minutes.|
|Cookie Compliance||Where applicable||app-decibel-compliance-cookieacceptance||This cookie is used to record the types of cookies a user is willing to accept on this web site.|
|Browser cookie||bam.nr-data.net||JSESSIONID||Session based cookie used by the Browser you are using e.g. Chrome or Internet Explorer|
|BIGipServerPOOL-184.108.40.206-80||Acceptance of the audience type disclaimer|
|UKInstitutional_TC||Acceptance of the site terms and conditions (Where applicable)|
|Aberdeen-asset||civicCookieControl||This cookie is used to remember a user’s choice about cookies on this website. Where users have previously indicated a preference, that user’s preference will be stored in this cookie.|
6. Privacy and the Internet
Aberdeen is committed to ensuring that your personal information is secure. In order to prevent unauthorised access or disclosure, we have in place appropriate physical, electronic and managerial procedures to protect and secure your personal information.
(a) How we secure information transferring to our web server
All forms containing sensitive personal information, such as payment or bank details, are transmitted, after we authenticate your details, to the web server using a 'secure form' in which your details are encrypted using strong encryption.
You should notify us immediately if you have any reason to suspect that someone else may be using your details.
An encryption certificate can be viewed by double clicking on the padlock icon displayed within the web browser window when you are on a secure page.
(b) How we hold your personal information on our web server
In most cases your personal information is passed immediately to our customer service centre without any personal information being stored on the web server at all.
Where it is necessary to store personal information temporarily, any sensitive personal information is securely encrypted and stored away from publicly-accessible areas of our web server.
(c) How we transmit your personal information to our customer service centre
Once we have received your personal information, the web server, located in a secure area of the network, immediately passes your personal information through an additional firewall into an application server and onto a server to allow us to execute your order within the customer service centre. The personal information is itself protected so that only authorised staff can access the personal information.
7. Personal information and marketing purposes
If you want Aberdeen to not use or cease using your personal information for marketing purposes, please contact our Data Protection Officer at firstname.lastname@example.org.
8. Changes to the Policy
Please be aware that this Policy may be updated at any time. As such, please ensure that you regularly read the latest version of this page.
If you have any questions or complaints relating to the Policy or how we use the personal information we have about you, please contact our Data Protection Officer at email@example.com, who will try to respond to you promptly.
A cookie is information that a web server stores on your hard disk so that it allows a web site to store your preferences on your machine and later retrieve it.
An IP address is a 32-binary digit number that identifies each sender or receiver of information that is sent in packets across the Internet.
A session is a series of interactions between two communication end points that occur during the span of a single connection and is related to a particular session number.