Privacy policy
At Janus Henderson Investors, maintaining your privacy is important to us and we take precautions to safeguard your information. After all your relationship with us is built on trust and our goal is to preserve that trust. This policy applies where we are acting as a data controller with respect to your information; in other words, where we determine the purpose and means of the processing of that information. This policy sets out the basis on which your information is collected, stored and used by us.
Contents of this Privacy policy
· Who we are and how to contact us
· Information we collect
· How and why we use information
· Sharing of your information
· Your rights
· Storage, transfers and retention
· Security
· Important information for California residents
· Making changes to this information
Who we are and how to contact us
This is the Privacy policy of Janus Henderson Investors (also referred to throughout this policy as ‘Janus Henderson’, ‘we’, ‘us’, or ‘our’). By Janus Henderson Investors we mean Janus Henderson Group Plc (reg. 101484) and its subsidiaries together with Janus Henderson Horizon Fund, Janus Henderson Fund and Janus Henderson Capital Funds plc. Janus Henderson collects and uses information in the ordinary course of business and is therefore responsible for ensuring that it uses that information in compliance with all applicable data protection laws. This Privacy policy governs the handling of your information by Janus Henderson. This Privacy policy explains how your information may be held and used by companies within Janus Henderson. Note that information may be shared between Janus Henderson’s UK and international subsidiaries.
If you have any questions or concerns regarding our Privacy policy, or how we process your information, please contact us via email at privacy@janushenderson.com or by postal service at:
Janus
Henderson Investors
Data Privacy Office
201 Bishopsgate
London
EC2M 3AE
United Kingdom
Information we collect
By “information” we mean all of the personal and financial information about you that we collect, use, share and store. Most of the information collected by us is information which you have provided to us directly, whether this is from you signing up online to receive information from us or by your providing information to us when becoming a client of ours.
Information we collect from you when you visit and/or request to receive information from our website (by way of a non-exhaustive list):
Information that we collect or generate about you includes (by way of a non-exhaustive list):
If you are looking to become a client of ours, or are already a client of ours, in addition to the above, we may also collect or generate additional information about you. This includes (by way of a non-exhaustive list):
There may be some instances where we receive information about you from a third party. This includes (by way of a non-exhaustive list):
In addition to the categories of information described above, Janus Henderson will also process further anonymised information and data that is not processed by reference to a specific individual. Your information may be converted into statistical or aggregated data which cannot be used to re-identify you. It may then be used to produce statistical research and reports which may be shared within Janus Henderson.
How and why we use information
We process your information to the extent necessary for us to carry out investment activities, provide communications to you, meet our regulatory obligations and for other legitimate purposes permitted by applicable law. Your information may be stored and processed by us in the following ways and for the following purposes (by way of a non-exhaustive list):
Whenever we use information, we make sure that the usage complies with all applicable laws. Data protection laws require us to have one or more of the following reasons:
Sharing of your information
We may share your information within Janus Henderson (both in the UK and internationally) for the purposes described above. All of our employees and contractors are required to follow our data privacy and security policies when handling information.
We may also share your information outside of Janus Henderson under the following circumstances.
Legal obligations: we share information: (i) to the extent that we are required to do so by applicable law, by a governmental body or by a law enforcement agency, or for crime prevention purposes (including fraud protection); (ii) in connection with any legal proceedings (including prospective legal proceedings); or (iii) in order to establish or defend our legal rights.
Service providers: we share information with service providers who perform services for us (including cloud services, data storage, sales, marketing, investigations, and customer support). Our contracts with our service providers include commitments that they agree to limit their use of information and to comply with privacy and security standards at least as stringent as the terms of our Privacy policy.
Third-party relationships: we share your information with affiliated third parties including financial institutions such as investment advisors and transfer agents. These third parties will be subject to appropriate data protection obligations and they will only use your information as described in our Privacy policy.
Consent: when you request that we share your information with someone else (for example if you engage the services of a professional advisor after you have become a client of ours and request that we provide information about your account to that professional advisor) or when we have otherwise obtained your consent. If we share information other than as permitted or described above, we will provide you with a choice to opt in to such sharing and you may choose to instruct us not to share the information.
Business sale: if we sell some or all of our business or assets we may need to disclose your information to a prospective buyer for due diligence purposes. If we are acquired by a third party, the information held by us about you will be disclosed to the third party buyer.
Your rights
You have the following rights under applicable data protection laws. In most cases you can exercise them free of charge. If your investment is through one of our non-EU companies, you may not be entitled to all of the rights set out in this section.
You have the right to:
You can exercise your rights by submitting an online request or contact us by emailing us at privacy@janushenderson.com
Please note that if you withdraw your consent for the future processing of your information we may be unable to send you some marketing communications or information regarding events sponsored by Janus Henderson. Additionally note, when we send you marketing, you will always be provided with an option to unsubscribe or opt out of receiving further marketing from us.
If you have any questions or concerns regarding our Privacy policy, or how we process your information, you may contact us by, emailing us at privacy@janushenderson.com, or via postal service at:
Janus
Henderson Investors
Data Privacy Office
201 Bishopsgate
London
EC2M 3AE
United Kingdom
Storage, transfers and retention
The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (the “EEA”) and/or outside your country of citizenship or residency. It may be processed by staff operations who work for us or for one of our service providers.
Where we transfer your information to another country outside the EEA, and/or outside your country of citizenship or residency, we will ensure that it is protected and transferred in a manner consistent with legal requirements. For example, this may be done in one of the following ways:
You can obtain more details of the protection given to your information when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your information) by contacting us via email at privacy@janushenderson.com or by postal service at:
Janus
Henderson Investors
Data Privacy Office
201 Bishopsgate
London
EC2M 3AE
United Kingdom
We will retain information as needed to fulfil the purposes for which it was collected. We will retain and use your information as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements. We will not retain your information for longer than is reasonably necessary.
Security
We have physical, administrative, procedural and technical safeguards in place to protect your information from unauthorised access, use or disclosure. We also contractually require that our third party service providers protect such information to the standard required by applicable data protection laws. We regularly adapt these controls to respond to changing requirements and advances in technology.
As a condition of employment, Janus Henderson employees are required to follow all applicable laws and regulations, including data protection laws. Access to sensitive information is limited to those employees who need it to perform their roles. Unauthorised use or disclosure of confidential client information by a Janus Henderson employee is prohibited and may result in disciplinary measures.
Important information for California residents
This additional information is being provided as required by the California Consumer Privacy Act (the “CCPA”). The CCPA provides California residents with specific privacy rights, including the right to:
If you are a California resident, please refer to our Privacy Policy located on our U.S. facing website to learn how you may exercise your rights or authorise another person to act on your behalf.
Making changes to this information
We’ll keep this information up to date and it will always be available at janushenderson.com or on request at any time.