Your privacy is very important to us. In this notice (this "Privacy Notice"), "we", "us" and "our" means MetLife Investment Management Limited ("MetLife"). We are registered in England and our registered address at 8th Floor, 1 Angel Lane, London EC4R 3AB.
1. ABOUT THIS PRIVACY NOTICE
1.1 For the purposes of the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 No. 419 ("UK GDPR") and the Data Protection Act, 2018 ("DPA", together "Applicable Data Protection Laws"), we are a controller in respect of your personal data. We are responsible for ensuring that we process your personal data in compliance with Applicable Data Protection Laws. The terms "controller", "processor", "data subject", "personal data", and "processing" used in this Privacy Notice have the meanings given to them in the UK GDPR. This Privacy Notice is issued on behalf of MetLife Investment Management Limited and its affiliates.
1.2 This Privacy Notice applies to:
1.2.1 visitors to our website: investments.metlife.com (the "website");
1.2.2 visitors to our premises; and
1.2.3 officers, directors, employees, advisors, intermediaries and other representatives of our suppliers, advisers and other service providers, ("you", "your" or "data subject").
2. PERSONAL DATA THAT WE COLLECT ABOUT YOU
2.1 We will collect the following personal data about you:
2.1.1 Information that you provide to us or one of our affiliates. This includes information that you provide us directly, through face-to-face discussions, giving us a business card (or similar), during a telephone conversation, through our website or any other means of correspondence, such as email or forms we may ask you to complete.
2.1.2 Information we collect or generate about you. This is information which we might generate ourselves in relation to you, such as emails (and related data), telephone conversations, website usage data, or other electronic communications with our employees and other staff members, through which our information technology systems may record details of for the purposes of entering into a business arrangement with you.
2.1.4 Information that our other systems collect about you. If you exchange emails or other communications with us, our information technology systems may record details of those conversations, sometimes including their content. Some of our premises have CCTV systems which may record audio and visual information about you if you visit our premises, for security and safety purposes.
2.1.5 Information collected from other sources. We may collect some information from other sources. For example, if we have a business relationship with the organisation that you represent, your colleagues or other business contacts may give us information about you such as your contact details or details of your role in the relationship.
2.2 Examples of the personal data that we may collect about you:
2.2.1 identifiers: for example, name, postal address, email address, telephone number;
2.2.2 internet or other network activity: for example, browsing or search history, information regarding interaction with the website or related applications or advertisements, as well as online identifiers such as cookies;
2.2.3 professional or work-related information: for example, your professional role, occupational history, business relationship with MetLife, and any other personal data which may be incidentally processed if you contact us; and
2.2.4 identification information: information we need in order to identify you and complete necessary security checks if you visit our physical premises.
3. USES OF YOUR PERSONAL DATA
3.1 Your personal data may be processed by us for the following purposes:
3.1.1 to provide you with information, products and services that you request from us;
3.1.2 to operate, manage, develop and promote our business and, in particular, our business relationship with you or the organisation you represent;
3.1.3 to operate, administer and improve our website and premises, including to protect the security of our website and premises;
3.1.4 to monitor the quality of our products and services;
3.1.5 to train our staff;
3.1.6 to protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes;
3.1.7 to confirm your identity and to comply with our legal and regulatory obligations and bring and defend civil, regulatory and criminal claims;
3.1.8 to investigate any complaint you may make;
3.1.9 to provide evidence in any dispute or anticipated dispute between you and us; and
3.1.10 where you have given us your permission to do so, we will use relevant personal data to enable us to provide you with information about products and services that may be of interest to the organisation you work for, represent, or similar.
3.2 Where we process your personal data in relation to the above purposes, we do so by relying on one of a number of lawful bases under Article 6 UK GDPR, depending on the nature and purposes of processing carried out. Our basis for processing may include:
3.2.1 Pursuing our legitimate interest or those of a third party. The lawful basis of such processing is Article 6(1)(f) of the UK GDPR, namely the processing is necessary for the purposes of our legitimate interests or those of a third party, except where such interests are overridden by your interests, fundamental rights and freedoms which require protection of personal data;
3.2.2 Complying with legal obligations. The lawful basis of such processing is Article 6(1)(c) of the UK GDPR, namely the processing is necessary to discharge a relevant legal or regulatory obligation to which we are subject; and
3.2.3 Performance of a contract. The lawful basis of such processing is Article 6(1)(b) UK GDPR, namely the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.
3.4 Some recipients will process your personal data on our behalf as processor. Others will determine the purposes and means of processing of your personal data as controller and may be permitted to disclose your personal data to other parties in accordance with applicable law.
4. DISCLOSURE OF YOUR PERSONAL DATA TO OTHERS
4.1 We may share your personal data with affiliates or third parties for the following purposes:
4.1.1 the other members of the MetLife group of companies;
4.1.2 third party agents and contractors, including IT and communications service providers, law firms, accountants, auditors, and administrators. These third parties will be subject to confidentiality requirements and they will only process your personal data as described in this notice (or as otherwise notified to you);
4.1.3 governmental, judicial, or prosecution bodies, tax authorities, regulators and courts;
4.1.4 third parties for the purposes of establishing, exercising or defending our legal rights;
4.1.5 third parties in connection with investments in, or the sale of, our business or assets or an acquisition of our business (or a part of our business) by a third party; and
4.1.6 your colleagues within the organisation that you represent.
4.2 Some recipients will process your personal data on our behalf as processor. Others will determine the purposes and means of processing of your personal data and may be permitted to disclose your personal data to other parties in accordance with applicable law.
4.3 You should be aware that when you are on the website, you could be directed to other websites that are beyond our control. Our website may contain links to other websites operated by third parties. We cannot guarantee that the privacy policies of these third parties meet our standards. You should read the privacy notice of any new website you visit.
5. PERSONAL DATA OF THIRD PARTIES
5.1 To the extent that you provide us with personal data of third parties, you agree and acknowledge that you have informed them of, and they have agreed to, our use, collection and disclosure of their personal data including the purposes of such use, collection and disclosure of personal data as set out in this notice.
6. TRANSFERS OF YOUR PERSONAL DATA OUTSIDE THE UK AND EEA
6.1 Your personal data may be transferred to, or stored in, a destination outside the UK in countries which may not have similarly strict data protection and privacy laws. It may also be processed by individuals operating outside of the UK who work for us or for one of our service providers.
6.2 To the extent required by law, where personal data is transferred outside the UK, we will ensure that our arrangements to transfer such personal data are governed by appropriate safeguards or data transfer agreements, designed to ensure that your personal data is protected as required under applicable data protection law (including, where appropriate, under an agreement on terms approved for this purpose by the relevant authority in the UK).
6.3 The disclosures described above may involve transferring your personal data overseas. If you are dealing with us within the UK, you should be aware that we may transfer your data outside of the UK. Some of these countries do not have similarly strict data privacy laws. Equally, if you are dealing with us within the EEA you should be aware that this may include transfers to countries outside the EEA, including the UK.
6.4 We will ensure that any such transfers are carried out in compliance with applicable law, including, where necessary, being governed by data transfer agreements (such as the European Commission approved model clauses) designed to ensure that your personal data is protected on terms approved for this purpose by the ICO or as otherwise required under Applicable Data Protection Laws. If you want to request a copy of any such agreements, please contact us using the details set out in "Contacting Us" below.
7. RETENTION OF PERSONAL DATA
7.1 Subject to applicable law, we retain your information for (as the case may be):
7.1.1 as long as it is required for our legitimate purpose;
7.1.2 as long as it is required to perform our contractual obligations;
7.1.3 as long as we have your consent; or
7.1.4 such period as is required or required by law or regulatory obligations which apply to us; and
7.1.5 we will delete or anonymise your personal data when it is no longer required.
8. AUTOMATED DECISION-MAKING (INCLUDING PROFILING)
We do not currently use any processing systems which make decisions and produce legal effects for you, or which may otherwise significantly affect you, based solely on automated processing of your personal data.
9. YOUR RIGHTS
9.1 You have a number of legal rights in relation to the personal data that we hold about you. These rights include:
9.1.1 the right to obtain information regarding the processing of your personal data and access to the personal data that we hold about you; in some circumstances, the right to receive personal data in a structured, commonly-used and machine-readable format and/or to request that we transmit that data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
9.1.2 the right to request that we rectify your personal data if it is inaccurate or incomplete;
9.1.3 in some circumstances, the right to request that we erase your personal data. Please note that your right to erasure that applies in certain circumstances under the Applicable Data Protection Laws is not likely to be available in respect of the personal data we hold, given the purposes for which we collect such data, as described above. Additionally, please note that there may be circumstances where you ask us to erase your personal data, but we are legally entitled or required to retain it;
9.1.4 in some circumstances, the right to object to our processing of your personal data. Again, there may be circumstances where you object to our processing of your personal data, but we are legally entitled or required to continue processing your personal data;
9.1.5 in some circumstances, the right to request that we restrict our processing of your personal data;
9.1.6 the right not to be subject to solely automated decisions, including profiling, which have a legal or similarly significant effect on you; and
9.1.7 the right to lodge a complaint with the data protection authority (details of which are provided below) if you think that any of your rights have been infringed by us.
9.2 You can exercise your rights by contacting us using the details set out under "Contacting Us" below. When exercising any of these rights, we may request specific information from you to prove your identity to our satisfaction so that we can safeguard your personal data from unauthorised access by someone impersonating you.
9.3 You can lodge a complaint or find out more information about your rights by contacting the UK's Information Commissioner's Office, or by searching its website at https://ico.org.uk.
9.4 We review and verify data protection rights requests. We apply non-discriminatory principles when we action requests relating to your data, in accordance with Applicable Data Protection Laws and principles.
9.5 If you do not want MetLife to send you e-mail or postal mail, you can opt out at any time by contacting MetLife by e-mail at MIMLPrivacyChampion @metlife.com.
10. CONTACTING YOU
10.1 We may contact you through one or more of the following communications channels: by telephone, mail, email, text (SMS) message, instant messaging or other electronic means.
10.2 We record some telephone calls and other electronic communications for regulatory reasons and for audit purposes. We store call and other communication recordings securely in accordance with our retention policies and Applicable Data Protection Laws. Access to those recordings is restricted to those individuals who have a need to access them for the purposes set out in this notice.
11. CONTACTING US
If you would like further information on the collection, use, disclosure, transfer or processing of your personal data, or to exercise of any of the rights listed above, please address questions, comments and requests to MIMLPrivacyChampion@metlife.com.
We may amend this Privacy Notice from time to time. Any material changes we make to this Privacy Notice in the future will be posted to our website (https://investments.metlife.com/regulatory-disclosures/metlife-investment-management-limited/). This Privacy Notice was last updated on 20 September 2021.