Privacy & Cookie Notice
Version effective date: April 2023
At Alcentra, we care about your privacy and value the trust you place in us when you share your personal information.
This notice is for Individual(s), defined as shareholders, investors, potential clients, brokers/distributors, advisors, business contacts, business peers and partners, vendor providers, website users and the general public.
From time to time, we may update this notice and any new version is always available on our website: https://www.alcentra.com/privacy-notice/
For job candidates, refer to our Candidate Privacy Notice.
For employees including external directors, refer to our Employee Privacy Notice. This link is only accessible, if you are on an Alcentra/Franklin Templeton device or within the Alcentra/Franklin Templeton network. Former employees may contact Human Resources for a copy of the Employee Privacy Notice.
1. Web-related privacy issues
Certain sections of our websites allow you to sign up for email alerts, request information about our corporate stock and sign up for electronic delivery of stockholder material. If you sign up for any of these options, we will ask you to provide information necessary for us to fulfil your request, such as name, contact details, your tax identification number (i.e. social security number “SSN” or local equivalent). We use your information to complete your request and only share it with third parties who assist us with that.
Our website may contain links to third-party websites or content, over which we have no control. Please review the privacy notices of these third-party sites for their privacy practices and the way they manage your personal information.
Cookies and similar technologies
Some of our web pages may contain cookies (a text file which identifies your device to our network) and/or web beacons, clear GIFs, tags or pixels (electronic image files that track navigation through our sites) placed by Alcentra or third-party advertisers.
For simplicity, we refer to all these technologies as “cookies”.
We also do not look for web browser “do not track” signals.
We may also engage third party tracking and advertising providers to act on our behalf to track and analyse your usage of our website using cookies. These third parties collect, and share with us, usage information about visits to our website and may correlate this information with other information (e.g. your IP address) to track page usage, help us target our recommendations and advertising and measure and research the effectiveness of our advertisements.
Enabling and disabling cookies
You can learn more about the cookies we use and choose which cookie categories you wish to allow by visiting the Privacy Preference Centre on our website www.alcentra.com and clicking the “Manage Cookies” section located in the footer of the page.
2. Privacy notice
This notice describes the categories of personal information we collect and for which purposes. By personal information, we mean information that is reasonably capable of being directly associated to you or in other ways be reasonably linked, directly or indirectly, to you.
Personal information we collect
Your personal information is either provided by you, created by us (or on our behalf) in connection with your Individual relationship with us, or obtained from third parties.
We may collect the following types of personal information:
- Contact information such as name, phone number(s), physical and email addresses;
- Account information such as account identifying numbers, transactions, holdings and balances information, banking information, fee history, fund selections or other account history;
- Associated account information this information is about others who may be connected with your account such as your professional representative (broker/dealer/advisor/attorney), joint account holders, parents/guardian for minor’s accounts, beneficiaries;
- Account onboarding information such as tax or government identification documents and/or numbers, place of birth, nationality, birthdate, marital/civil partner status, beneficiary information, gender, source of wealth/funds, profession, other information necessary to conduct our obligations;
- Screening information collected or generated in connection with your Individual relationship such as Know Your Customer (KYC), Anti-Money Laundering (AML), Politically Exposed Persons (PEP), criminal convictions (in certain circumstances, under applicable law) and results of those obligations and references;
- Biometric and/or pictorial Information such as photos identifying you that you voluntarily provide and with your consent;
- Professional and business contact information such as job title/role, your company, professional credentials such as financial licence, dealer number;
- Communications, defined as: emails, telephone calls, web platform (Skype/MS Teams, etc) calls, chats or Instant Messenger (IM), events and webinars, and letters generated/from you or by us. All Communications may be recorded and/or archived;
- Other information collected or generated in connection with your Individual relationship such as your responses to our surveys, your opinions about our services, preferences for marketing and/or other contact, demographic information;
- Information captured by online account access such as log-in information and similar credentials, we may also collect information with your interaction with our websites;
- Information captured by our websites such as web logs, cookies, and information about your interactions with our websites and Alcentra webpages on social media sites such as Twitter and LinkedIn;
- Information collected when attending an in-person event or webinar such as your registration details, engagement with/follow up to the webinar, event or if you are invited for marketing/website development, information to arrange travel services (where applicable), information to allow us to analyse and make improvements to our offerings and services;
- Information about your use of company premises such as a visitor log which may contain the time, location and purpose of your visit. Alcentra offices contain landlord-controlled CCTV.
How we use your personal information
We may use your personal information for the following purposes:
- creation and account maintenance;
- manage and protect your account, transactions, holdings and investments;
- communicate with you about your account/holdings;
- testing and enabling online services;
- perform obligations to which we are subject such as KYC, AML, PEP, or other screenings and checks;
- live testing (on an exceptional basis) to resolve issues;
- internal analysis and research to improve our services;
- invitations and connected management of our events and webinars;
- marketing and/or other Communications about our services (you can unsubscribe or withdraw your consent to marketing communications);
- planning and monitoring marketing campaigns;
- business management and other legitimate business purposes in compliance with our policies and procedures, or as otherwise permitted or required by law.
We consider our legitimate interests to be:
- promotion of our business and our brand;
- tracking and improvement of fund performance;
- ensuring the resilience and reliability of our services;
- improvement and management of our services;
- tracking effectiveness of our mailing and marketing campaigns;
- facilitation of ongoing, existing relationships and potential new opportunities in connection with those relationships.
Data retention and protection
We keep your personal information for as long as necessary in connection with the purposes identified within this notice, and for a reasonable period thereafter, in accordance with local retention periods.
It may differ from jurisdiction to jurisdiction however, in the majority of cases, this will be during our relationship and then for 10 years after the end of the relationship. If you have invested in funds based in the United Kingdom or the Republic of Ireland, then your information is retained for 6 years or 7 years, respectively.
In certain circumstances, data may be retained for a longer period of time, for example, where we are in ongoing correspondence or there is a continuing claim or investigation.
Our web logs are kept for 60 days for security reasons.
We have implemented reasonable administrative, technical, and organizational measures, including physical, electronic, and procedural safeguards, based on our Corporate Information Security policy, which is designed to secure your personal information. For example, access to your personal information is limited to authorized Alcentra employees, and Alcentra employees are required to follow specific procedures with respect to maintaining the confidentiality of your personal information.
Information that we share
Your personal information may be transferred to, and stored, outside the country where you reside, within our group of companies and/or service providers. Please refer to Third parties and other recipient categories for the categories of potential third-party recipients.
Alcentra and its affiliates (including Franklin Templeton) have offices in the following countries: Argentina, Australia, Bahamas, Canada, China, Cayman Islands, Dubai International Financial Centre (DIFC), Countries within the European Economic Area, Hong Kong, India, Israel, Japan, Korea, Malaysia, Singapore, South Africa, Switzerland, Turkey, United Arab Emirates, United Kingdom, and the United States.
Some of these countries may not have the equivalent level of data protection laws as those in your location. If we need to transfer your personal information internationally, we will take steps to make sure that it is protected and safeguarded.
In addition to sharing information with other Alcentra group companies and third-parties, we may also share or transfer your personal information to a prospective or actual purchaser or transferee, in the event that a Franklin Templeton company or its assets is/are merged or sold or a sale or transfer is intended.
Why do we collect your personal information?
Your personal information is collected (including sharing such information with third parties) where we have a legal reason to do so:
- To fulfil a contract we have with you;
- When it is our legal duty;
- When you consent to it;
- When it is in our legitimate interest*;
(*) Our legitimate interest is when we have a valid business or commercial reason to use the information and the use does not negatively impact your personal rights and freedoms.
You may have the following rights, under certain circumstances, in relation to your personal information:
- Ask whether Alcentra has personal information about you and for what purpose and if it is disclosed to third parties;
- Access to your personal information including copies of that information;
- Rectify inaccurate/incomplete personal information about you;
- Request deletion of your personal information;
- Raise a complaint to a supervisory authority;
- Additionally, you may have the right to request a restriction, objection or data portability in certain circumstances.
If you wish to exercise a right, download the applicable Privacy Rights Request form at: https://www.alcentra.com/privacy-notice/
The information will be provided free of charge, except where local laws allow for charges.
3. How to contact us
Contact us at one of the following addresses to exercise a privacy right, ask a question, share a concern, or make a complaint regarding this notice and/or our privacy practices:
FAO: Data Protection Officer
Franklin Templeton Global Investors Limited
5 Morrison Street
Edinburgh EH3 8BH
For a full list of Franklin Templeton companies (controllers), visit: www.franklintempletonglobal.com/privacy/fund-entities
4. Third parties and other recipient categories
The following categories of third parties associated with the recruitment/hiring process may receive your personal information as applicable:
- Account processing system suppliers – provide services or maintain systems processing account information (Candidate applications), such as suppliers systems supporting Alcentra’s Website.
- Administrators / transfer agents – provide account maintenance and service accounts.
- Asset management services – provide asset administration, transfer or asset management services.
- Banking platforms/custodians – providing banking administration, transfer or asset management services.
- Brokers – instruct on the Individual’s behalf regarding their account/holdings.
- Business contact database administrators – provide services or maintain business contact databases, and systems processing business contact information, such as suppliers’ systems supporting Alcentra’s Website(s).
- Cloud-based solution providers – provision of services such as where data is held on a cloud system.
- Couriers/postage services – provide courier services/ mailing/ postage/ delivery services.
- Courts/police, regulators & tax authorities – Competent third-party authorities (government bodies) where requested, required by law, or where we consider it necessary, information may be shared.
- Document archive, storage, and destruction suppliers – offsite document archive and storage services.
- Events management providers – provide services to plan, organise and facilitate events (in person or online, such as webinars).
- Financial services providers – offer banking, trust and custodial products and services in order to process the data, including access through our portal.
- IT systems suppliers – provide technical services specifically for IT systems.
- Parties representing an account holder or investor – Third parties representing an account holder or investor, e.g. in response to a legal process.
- Other professional or business services – such as translations services, training solutions, other ad hoc business services.
- Print services suppliers – provide technical services specifically for print services.
- Professional advisors, i.e. auditors and lawyers – Third parties who provide professional and/or legal services to Franklin Templeton group companies.
- Security – provide services to monitor Alcentra’s physical premises.
- Social media and website providers – support Alcentra-branded web pages and can include platforms promoting Alcentra content such as Twitter, LinkedIn and Facebook.
- Trade messaging system suppliers – operate systems relevant to performing transactions for account holders, investors or institutional clients.