Legal information

A. Use of and access to this website are subject to acceptance of the terms and conditions set out in the following "Legal Information".

1.  Company information : On this website, "Candriam" (also called "Candriam Investors Group") is the name used to designate all companies within the group Candriam. Candriam comprises the following entities:

• Candriam Luxembourg : 
  a partnership limited by shares ("société en commandite par actions") under Luxembourg law and approved asset management company under Trade Register No. R.C.S.B. 37.647; its registered office is located at L-8009 Strassen, Serenity - Bloc B, route d'Arlon 19-21.
• Candriam Belgium:
  a limited liability company under Belgian law and approved asset management company, registered in the Brussels Register of Legal Persons (Register des Personnes Morales in French) under No. RPM 0462.569.739; its registered office is located at B-1000 Brussels, Avenue des Arts 58.
• Candriam France:
  aa simplified joint-stock company ( “société par actions simplifiée”) under French law, and approved asset management company under Trade Register R.C.S. Paris 344 032 743; its registered office is located at F-75408 Paris, rue Washington 40.
• Candriam Suisse Sàrl (Candriam Switzerland LLC): 
  registered under Trade Register No. CHE-227.651.154, located at rue du 31 décembre 40-42, CH–1207 Geneva, Switzerland
• Candriam Luxembourg – Succursale italiana (Italy): 
  registered under Trade Register No. 13228410158, located at Corso Italia 1, I-20122 Milan.
• Candriam Luxembourg – Nederlands bijkantoor (The Netherlands): 
  registered under Trade Register KVK 24364887, located at Gustav Mahlerplein 3 (26th floor) 1082 MS Amsterdam.
• Candriam Luxembourg – Sucursal en España (Spain): 
  registered under Fiscal Identification Code W0181119I, located at Pº Castellana, 141 - Planta 18, 28046 Madrid.
• Candriam Luxembourg – Zweigniederlassung Deutschland (Germany): 
  registered under Fiscal Identification Code HRB 78020, located at Fellnerstraße 5, D-60322 Frankfurt am Main.
• Candriam Luxembourg, – UK establishment (United Kingdom): 
  registered under Fiscal Identification Code BR015843, located at 200 Aldersgate Street, 13th Floor, EC1A 4HD London.
• Candriam Luxembourg – Branch in the Dubai International Financial Centre(DIFC): 
  registered under Fiscal Identification Numbers F001592 (DFSA) and CL1095 (DIFC) located at Dubai International Financial Center, Office 24, The Gate Village, Building 10, Level 3, Office 24, P.O. Box 506665, Dubai.

You can contact Candriam:

• https://contact.candriam.com

The editor responsible at law for this site is Naïm Abou-Jaoudé (40, rue Washington, F-75008 Paris).

For any information related to the conditions under which Candriam may process your personal data and the exercise of your individual rights on your personal data please refer to section 10

2.  Target groups and purpose of this website
This website, its contents, the results of automated processing, data and information made available are exclusively intended for use by:

(1) private investors, i.e. individuals habitually resident in the country specified by themselves in the appropriate part of this website, or
(2) professional investors, i.e. professional clients in the sense of Directive 2004/39/CE of 21 April 2004 on the financial instrument markets; prior to accessing this website, professional investors must register in accordance with the terms and conditions set out in the relevant web pages of this website.

PLEASE NOTE : By registering, registered professional investors acknowledge and accept that the part of this website specifically dedicated to them is only intended for professional investors, including, in particular but not exclusively, institutional investors, investors with a certain amount of specialisation and expertise in the area of financial markets and instruments, such as collective investment undertakings (UCIs), and others. Such professional investors are aware that a measure of risk is involved in investing in some of these UCIs in view of their characteristics and/or the particular degree of expertise and knowledge required for investment in such UCIs.

By registering, visitors registering as professional investors acknowledge and accept that Candriam supplies access to the part of its website which supplies information concerning the full range of UCIs for information purposes. This means registered professional investors have access to information concerning UCIs which:

(1) may not be commercialised in the jurisdiction where the professional investors' registered office or habitual place of residence are located (hereafter referred to as "their jurisdiction"), or
(2) cannot be traded in their jurisdiction, or 
(3) do not have the European passport required by the applicable legal and regulatory requirements for those UCIs.
For this reason, this website does not comment on the ability of visitors to this website registered as professional investors to invest in such UCIs on the basis of their location and/or capacity and the applicable laws, regulations and fiscal provisions.

The contents of this website cannot at any time substitute for readers' own research or their technical and/or business judgement based on their personal situation. In no way should the information on this website be considered to be an offer to buy or sell any financial instrument, neither should it be considered to be advice of any kind, whether legal, accounting, fiscal or other. For an offer and/or customized advice, do not hesitate to contact the institutions dealing with financial services concerning our products.
Neither the information nor the results supplied to visitors are intended to encourage the latter to undertake a particular transaction, or advise in favour of or against a particular transaction. Links to websites not controlled by Candriam are intended only as a service to the visitor and do not constitute advice, a form of advertising or a value judgement.

For any information related to the conditions under which Candriam may process your personal data and the exercise of your individual rights on your personal data please refer to section 10

3.  Services available on this website
This website contains both informative data and a number of interactive applications.
The interactive applications on this website are those which supply applications on or via this website which enable visitors to enter certain kinds of information and be notified of the result of their automated processing.
The results supplied to visitors are generated automatically on the basis of the data supplied by the latter. Candriam is therefore not in a position to verify data in any way.
All publications and information available on this website are for information only, whether they have been supplied by Candriam or its selected third parties. Candriam has exercised the utmost care as to the contents of the information and data supplied as well as to the results of all automated processes, and regularly updates this website. However, Candriam does not explicitly or implicitly guarantee the completeness, accuracy and current applicability of these data and applications, or of the results supplied to visitors via any automated process.

4.  Advertising
The current website comprises advertisements issued by Candriam concerning Candriam services and products. Links and other references to third parties which are not companies linked or associated with Candriam should not be considered to be advertisements for such third parties.

5.  Cookies
When you visit this website, Candriam will, in certain circumstances, automatically send cookies to your computer. These are small applications which are written on to your hard disk. They are quite harmless and intended to make the site easier for you to use. For instance, this is how your choice of country and language are recorded when you first visit the website, so that thereafter you automatically access the website in the language you selected at the time of your first visit. If you do not want these cookies written on to your hard disk, you can set your browser in such a manner that they do not gain access to your hard disk. However, in such cases, Candriam is not in a position to guarantee the correct operation of the websites under its control. You can also delete the cookies from your hard disk after each visit to the website.
Candriam will treat the information collected via these cookies in a fully confidential manner, in accordance with the applicable best practices and with the provisions of the law of 8 December 1992 concerning the laws on privacy as releated in particular to the processing of personal information.

6. Viruses, Trojan horses and other malware
Candriam guarantees that all the data it includes on its website have been previously checked to ensure that they are free of all viruses and/or malicious software (e.g., malware, and Trojan horses). Candriam regularly inspects all items on the website which can be downloaded by customers to their computer systems to ensure that they are free of the virusesand/or malicious software.
Despite the high degree of caution exercised by Candriam, the swiftness of change on the Internet and on Internet applications, as well as the development of related risks means that Candriam is unable to guarantee that all information is completely free of viruses at all times.
In view of the risks of Internet use, Candriam strongly advises visitors to regularly scan all downloaded information, including that supplied by suppliers the visitor considers to be trustworthy.

7.  Liability : Candriam shall not be held liable for any of the following, except in cases of malicious intent or gross negligence:

• any technical difficulty experienced by visitors to this website, whatever the cause, including bugs, inadequate capacity, the visitors' own hardware, software, browser, computer systems and their extensions, whatever their nature, and the software which enables them to access the Internet and this website; the customization, installation, maintenance, processing and updating of the software, hardware, and computer systems and extensions concerned by this point shall remain the visitor's sole responsibility;
• the consultation and/or use of the information on this website;
• any damage attributable to events or third party manipulations over which it has no direct control, or force majeure, including damage relating to the use of links providing access to the Candriam website from other websites not under the control of Candriam, or to a website which looks like a Candriam website, etc.
• any damage attributable to the exiting of the website or incurred after the website has been exited, even when the website has been exited via a link on the website;
• damage caused by errors, whatever their origin, which occur during the automated processing of the data entered by the visitor in the interactive applications, in so far as the interactive applications have not been developed by Candriam and this is clearly specified by means of a logo or other information;
• illegal access by a third party to, or illegal alteration by a third party of the visitor's or Candriam's computer systems, programming, programming code or software, as well as the ensuing direct or indirect damage;
• incomplete, inaccurate or obsolete data entered by the visitor when using the interactive applications;
• websites and website applications which are not managed by Candriam.

8.  Applicable law and jurisdiction : Visitors agree that, insofar as allowed by law, the supply of service and product information on this website, as well as the publication thereof, are performed under Belgian law. The Brussels law courts alone shall have jurisdiction in case of any dispute arising from the information on this website, the following websites and web pages, and their use by the reader. In such cases, only Belgian law shall apply.

9.  Intellectual property rights : The contents of the Candriam website as well as the information supplied therein, programmes, applications, trademarks and logos are protected by intellectual property rights belonging to Candriam or its suppliers. Readers/visitors to this website shall comply with these intellectual property rights at all times and shall refrain from any infringement thereof and from any other use for which prior authorisation has not been obtained from Candriam.
No links whatsoever may be created from any other website to Candriam's websites and/or web pages without the express written consent of Candriam. 
This prohibition applies to all link types or techniques in which the name, address or any other element belonging to Candriam is included or displayed on another website, or which enable surfers to enter the Candriam website via this other website.

10.  Website/Client Privacy Notice [Date of Issue : May 2018]

Candriam Luxembourg (registered office: 136, route d'Arlon L-1150 Luxembourg), Candriam France (registered office: 40 rue Washington – 75008 Paris), Candriam Belgium (registered office: Avenue des Arts/ Kunstlaan 58, 1000 Brussels) and Candriam Switzerland (registered office: rue du 31 décembre 40-42, CH–1207 Geneva, Switzerland) and its subsidiaries (referred to collectively as "Candriam" or "we" or "our") is committed to respecting the privacy of individuals, including its clients.

Candriam owns and operates the web site (https://www.candriam.com)

This Privacy Notice ("Notice") sets out the basis on which Candriam processes personal data. Please read the following carefully to understand our views and practices regarding how we handle personal data.

For the purposes of applicable data protection law (in particular, the General Data Protection Regulation (EU) 2016/679 (the "GDPR"), each Candriam entity referred to above is the "data controller" of your personal data.

Candriam Switzerland, has appointed as EU representative for GDPR matters Candriam Group S.a.R.L. with registered address at 19-21 Route d’Arlon, L-8009 Strassen Luxembourg; registered no. R.C.S. Luxembourg : B 180524.

Personal Data We collect

We may collect and process the following personal data:

• Information you give us:
  • If you are enquiring about Candriam capabilities (including where you are inquiring on behalf of your employer) then we may process your personal data - including your name, gender, address, personal or professional e-mail address and personal or professional phone number, financial information, personal description, photograph, ID documentation (including your passport or ID card), professional activity, marital status, information about you dependents or beneficiaries.
  • You or your employer may give us information about you during our due diligence of your employer , when you complete a form on our site or by corresponding with us by phone, e-mail or other electronic means, or in writing. This includes information you provide when you create an account on our site, subscribe to any of our services, search our site, make enquiries, , submit information or content to our site, when you report a problem with our site – including your name, email address, gender, postal address, telephone and fax.
• Information we collect about you: With regard to each of your visits to our site we may automatically collect the following information:
  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products, services or issues you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call us.
• Information we receive from other sources:
  • We may also receive information about you if you use any of the other websites we operate or the other services we provide.
  • We are part of a global group of companies which manage funds and provide other financial services. Where you have requested services which involve one or more of our subsidiaries and/ or affiliates, we will tell you, and we may receive relevant information from our subsidiaries and/ or affiliates for the purposes of those services.
  • We work closely with third parties (for example, banks and other financial institutions, business partners, legal or other consultants, sub-contractors in technical, analytics providers, search information providers,) and may receive information about you from them.
• Information about other people: If you provide information to us about any person other than yourself, such as other employees of your employer, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.

Purposes and Legal Basis for processing

We may ask you for consent to collect or process your personal data on certain occasions, for example, and as stated below, where necessary in order to contact you with information about products and services or events that might be of interest to you or your employer.

We process your personal data when we need to do this to fulfil a contract with you, including processing your personal data to give effect to your investment in a Candriam fund, to verify your identity, or to otherwise provide services to you.

We process your personal data when required by law to do so, such as if we receive a request from law enforcement or other government officials.

We process your personal data when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this Notice.

In particular:

• we use your personal data in order to effectively administer the Candriam funds and our business;
• we use your personal data to undertake commercial and legal due diligence on our clients and investors, in order to assess their activities and condition in relation to their investments and the provision of our services;
• we monitor use of our websites, and use your personal data to help us monitor, improve and protect our services and websites, both online and offline;
• we monitor investor accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law; and
• we will use personal data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).

Disclosure of Your Personal Data

We may share your personal data with our subsidiaries and/ or affiliates¹.

Personal data will also be shared between the Candriam entities referred to above, which manage Candriam funds, and the Candriam fund legal entities which are SICAVs (Société d'investissement à Capital Variable).

We may also share your personal data with trusted third parties including:

• Legal or other advisers, consultants and other professional experts, complainants, correspondents and enquirers, and suppliers and service providers of any of the above, and each of their associated businesses;
• Business partners, suppliers and sub-contractors only for the purposes of performance of any contract we enter into with them or you or your employer. We take reasonable steps to ensure that our staff protect your personal data, and are aware of their information security obligations; and
• Analytics and search engine providers that assist us in the improvement and optimisation of our site.

We may disclose your personal data to third parties:

• If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• If Candriam, its business, or its assets are acquired by a third party, in which case personal data held by it about its users, suppliers, or customers will be one of the transferred assets;
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce agreements; or if we reasonably consider this necessary; or to protect the rights, property, or safety of Candriam, our users, our customers, or others; and
• For the purposes of crime prevention and fraud protection.

Marketing Communications

We, or trusted third parties on our behalf, may contact you by email or post with information about products, services and events that might be of interest to you. Where necessary, at the time that you provide your personal data to us, you will be given the opportunity to indicate whether or not you are happy for us to use your personal data in order to tell you about such products or services or events.

You can unsubscribe from this at any time by emailing us using the contact details provided below.

Where We Store Your Personal Data and How We Protect it

Some of the Candriam subsidiaries and/ or affiliates and third parties to whom Candriam discloses your personal data (as described above) may be located in countries which are located in any country of the European Union but also countries outside EEA that do not provide a level of protection to personal data equivalent to that provided by your home country.

In order to provide adequate protection for these transfers, Candriam utilizes transfer mechanisms recognized by your home country, which may include executing appropriate contractual clauses based on and conforming to the EU model clauses. To obtain a copy of the transfer mechanism, please contact us using the details provided below.

We take reasonable steps to protect your personal data from loss or destruction.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our site; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

Your Rights

You have various rights with respect to our use of your personal data:

• Access: You have the right to request a copy of the personal data that we hold about you. Please note that there are exceptions to this right, so that access may be denied if, for example, making the information available to you would reveal personal data about another person, or if we are legally prevented from disclosing such information. You are entitled to see the personal data held about you. If you wish to do this, please contact us using the contact details provided below.
• Accuracy: We aim to keep your personal data accurate, current, and complete. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date. You can also review and correct/ update some of your personal data by logging-in to your account on our site.
• Objecting: In certain circumstances, you also have the right to object to processing of your personal data and to ask us to block, erase and restrict your personal data. If you would like us to stop using your personal data, please contact us using the contact details provided below.
• Porting: You have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format.
• Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority or to seek a remedy through the courts.

Please note that there are exceptions to these rights, if, for example, we are under a legal obligation to continue to process your personal data.

As a reminder, in France by application of article 40-1 of the Law n°78-17 of 6 January 1978 on Information Technology, Data Files and Civil Liberties, you have also the right to give instructions on the management of your personal data after you death.

When we ask you to supply us with personal data we will attempt to make it clear whether the personal data we are asking for must be supplied so that we can provide the products and services to you or your employer, or whether the supply of any personal data we ask for is optional.

How Long We Keep Your Personal Data

We will retain your personal data for as long as we believe it necessary or desirable to fulfil our business purposes or to comply with applicable law, audit requirements, regulatory requests or orders from competent courts.

Personal data collected will be retained pursuant to our record retention policy, and in most instances will not be retained longer than ten (10) years from the date of last use.

Changes to our Privacy Notice

Any changes we may make to our Notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Policy.

Contact Details

If you wish to exercise any of your legal rights, write to us at DPO[@]candriam.com.

¹List of subsidiaries and affiliates are available on the following link:
https://www.candriam.be/en/private/legal-and-disclaimer/informations-juridiques/

B. Compte rendu relatif aux frais d'intermédiation de Candriam (only for France)