Privacy Policy and Cookie Statement

Thank you for visiting our website and for using our services. We’d like to tell you about our privacy policy and how we use cookies on our website. We have defined some words and phrases to help make it clear what we mean:

In this Privacy Policy and Cookie Statement:

“personal data” means personal data as defined under the Law, we also refer to personal data as “data about yourself”, “personal information”, “your information”, “personal details” and “information about you”;

“data controller” means data controller as defined in applicable data protection legislation

“Source UK Services Limited” and “Invesco Asset Management Limited” are also referred to as “Source”, “Invesco”, “Us” and “We”.

“the Law” means applicable data protection legislation.

This Privacy Policy and Cookie Statement (together with our Terms of Conditions of Use) tell you how we will process any personal data that we collect from you, or that you provide to us. The Law says we must provide you with this information and we hope this will help you to understand how we will keep your personal data safe.

The Law says that Source and Invesco are the data controllers. We are committed to protecting your privacy and personal data as you use our website and web services. We take seriously our responsibility to hold your personal data securely and confidentially.

If you use the online email or the online chat facilities, we will ask you to provide us with certain up to date personal data and we will handle this personal data in accordance with the Law. We may need to ask you for your personal data to help us to meet your needs and to provide you with the services you require. If you do not provide your personal data to us, it may make it impossible for us to provide these services to you.

We maintain strict security standards and procedures with a view to preventing unauthorised access to your data by anyone, including our staff. We use leading technologies such as (but not limited to) data encryption, firewalls and server authentication to protect the security of your data. The staff of both Source and Invesco follow strict privacy standards and whenever we hire third parties to provide support services, we require them to observe the same standards and to allow us to audit them for compliance.

Your Personal Data

We use your personal data to service your account, improve our services to you, to provide information to you about our services and to inform you about additional products or services that may be of interest to you. We may identify these products or services by using cookies on our website which track and analyse how you use our website.

We may collect, process, use and store your personal data electronically or on paper and in written or digital formats. We collect, process and use your personal data with automated tools and only keep it for as long as is necessary to fulfil the purposes for which it has been collected.

Sharing your personal data in order to send you marketing information

Where you opt in to receive direct marketing materials from us, we may send your personal data to third parties with whom we have contracted to provide these materials to you on our behalf and in our name. By opting in to receive direct marketing from us, you agree that we may send your personal data to these third parties who may be based in the country where you live or elsewhere.

Sharing your personal data with Source Schweiz GmbH

We may use and share your personal data with other entities within the Invesco Group to help us and them:

  • assess financial risks;

  • develop customer relationships, services and systems;

  • prevent and detect crime;

Sharing your personal data with other organisations

In certain circumstances we may also send your personal data to other third parties such as:

  • where we have your permission;

  • where we are required or permitted to do so by Law; or

  • other companies who provide a service to us or you where we may transfer rights and obligations.

This may mean we send your personal data to these organisations outside Europe (the European Economic Area (EEA)) or outside any other country from where you may access our website, to countries where the Law may not guarantee the protection of your personal data. However, we will ensure that your personal data is transferred, processed and maintained to the standards required by Law.

We transfer your personal data to the United States for own analysis purposes by employing the Google Analytics technologies. We also transfer your personal data to the United States to HubSpot (HubSpot, Inc. First Street, 2nd Floor, Cambridge, MA 02141 USA.) for storage purposes.

We may forward your personal data to the Police or another regulatory body if we are asked to do so or wish to do so in order to comply with the Law or in relation to any suspected misuse by you of our web site or any of our web site services. We endeavour to prevent unauthorised disclosures of your personal data by other people, but we are not responsible for any unauthorised disclosures or other breaches of security or for the actions of others if the personal data was passed to them with your authority or with the authority of anybody other than us or our associated companies.

How to access your personal data

The Law says you have the right to ensure your personal data is kept up to date and accurate, and for some jurisdictions the right to find out from where your data was originally collected, where it has been transferred to and for which purposes it is now stored. You have the right to have your personal data deleted if it has been collected or processed unlawfully, and you may object to us processing your personal data at any time. If you want to do any of these things or you would like a copy of the personal data we hold, please write to:

Source UK Services Limited,

Perpetual Park

Perpetual Park Drive

Henley-On-Thames

RG9 1HH,

If you prefer, please send us an email invest@sourceetf.com.

Or

Invesco Asset Management Limited

Perpetual Park

Perpetual Park Drive

Henley-On-Thames

RG9 1HH

Where the Law permits, we may charge you a small fee to cover the costs of sending this personal data to you.

Anonymous or pseudonymized use

In accordance with applicable data protection legislation, you may choose to use the website in an anonymised or pseudonymized manner. This applies only to the extent that anonymous or pseudonymized use of the website is technically possible and reasonable.

Data Retention

We will retain your personal data while we are providing our services to you and we will not retain your personal data for longer than is strictly necessary.

Intellectual Property

All intellectual property rights in any part of the world which subsist in the contents of this website and which belong to Invesco, save as expressly granted, hereby reserved.

Cookies

By accepting this Privacy Policy and Cookie Statement when you enter our website and by continuing to access our website in the future you acknowledge and agree that we may track and record information for systems, marketing, trouble shooting, administrative and reporting purposes, including, for instance, the aggregate number of visitors to the website and the sections of the site visited by visitors using cookies. Cookies are small text files placed on your computer and are commonly used on the internet.

We use cookies to:

  • operate our website, for example by directing you to the right area depending on what country you have selected. We call these cookies “strictly necessary”;

  • analyse our website, for example to collect information that will help us understand visitors' browsing habits on our website;

  • compile statistical reports on website activity, e.g. number of visitors and the pages they visit;

  • improve the functionality of our website by temporarily storing any information which you may enter in tools, such as calculators or demonstrations on our website; in some cases, remember information about you when you visit our site. We may need to do this to provide some of our services

  • record your visit to our website, the pages you have visited and the links you have followed. We use this information to make our website more relevant to your interests and identify products or services that may be of interest to you. We may also share this information with third parties for these purposes.

We do not use cookies to track you after you leave our website and we do not store any personal data in cookies in a format that can be read by anyone else.

We use two types of cookie:

Session cookies: These are temporary and are deleted as soon as you close your browser; and

Persistent cookies: These are stored on your computer until they expire or you remove them. Persistent cookies store your personal preferences such as your language preferences on multi-lingual sites to make subsequent visits easier. They also remember questions we have asked you previously, such as a request to complete an online survey.

You can find more information about the individual cookies we use, when they expire and the purposes for which we use them in the table below:

Country
Expires: session only.

Used to pre-populate user country on the landing page

This cookie is used to predict the country that a user of our website is from and it pre-populates the country location field that appears when users first access our website.

We collect this data on the very first page of our website. We only collect this once.

We use this data to improve the user experience of the website (this means users do not have to search for their country if the information is available from their IP address)

Drupal.visitor.user-language
Expires: 3 months

Tracking of language selected by user

This cookie remembers the language the user selects when they come into our website.

We collect this data the first time the user comes to our website.

We use this data to improve the user experience of the website (this prevents a returning user from having to reselect their language choice each time they enter our website).

Drupal.visitor.user-type
Expires: 3 months
Tracking of investor type (private or professional)

This cookie remembers the user type the user selects when they first some to the website. They either select Private Investor or Professional Investor. The cookie remembers which one they selected.

We collect this data the first time the visitor comes to our website.

We use this data to improve the user experience of the website (this prevents a returning user from having to reselect their user type (Professional Investor/Private Investor) each time they enter our website).

Cookies set by Snap Engage (Chat):
SnapABugRef
Expires: 120 min

This cookie tracks the country the user is from (best prediction) and also what page on our website the user hits the chat button.

We only collect data using this cookie when a user who has stated that they are a Professional Investor clicks the "online chat" button.

We use this data to enable web chat to function - This helps us route the chat to the right chat operator with the correct language skills. For example we route French visitors to a chat operator fluent in French. This cookie is also used for regulatory compliance purposes as it allows the chat operator to ensure we are not selling to an investor claiming to be in Europe that is actually based in, for example, the USA.

SnapABugChatSession
Expires: 16 min

This cookie tracks a live chat that is in progress.

We only use this cookie when a user who has selected they are a Professional Investor clicks the "online chat" button.

This allows a chat to continue when the user starts to browse different pages on the website whilst they are having a live chat with us.

SnapABugNoProactiveChat
Expires: 30 min (but to be configurable)

This cookie is used once we have proactively approached a user and asked them "do you want to livechat with us", if they say “no”, this cookie ensures this will not happen again.

We use this cookie on the Product Page when we proactively approach a user for the first time.

This data enables web chat to function and avoids prompting a user to chat when they have finished a chat / declined to chat earlier in that session.

SnapABugChatPoll
Expires: 16 min

This cookie tracks web chats in progress and the transcript position

We use this cookie when a user engages in web chats with one of our chat operators .

This data enables web chat to function.

SnapABugChatMessage
Expires: 16 min

This cookie tracks the message type by user persistence across pages

We use this cookie when a user engages in web chat with a chat operator at Source.

This data enables web chat to function.

SnapABugChatView
Expires: 16 min

This cookie checks logic handling - needed to run web chats

We use this cookie when a user engages in web chat with a chat operator at Source.

This data enables web chat to function.

SnapABugHistory
Expires: 1 year

This cookie keeps track of the user visits and previous chats to present history to agent

We use this cookie when a visitor engages in web chat with a chat operator at Source.

This data is used to provide a better user experience as we will be able to review your chat history and previous visits to our website.

SnapABugVisit
Expires: session only

This cookie detects the start of a new session

We use this cookie when a user engages in web chat with a chat operator at Source.

This data enables web chat to function.

SnapABugUserEmail
Expires: 1 year

This cookie remembers a user’s email address and pre-populates this address in the pre-chat window

We use this cookie on the web chat function. If the user gives us their email address we will store this.

This information

is stored in our client relationship management database so that we can help you with the query you raise with us using the chat window and to keep a record of the action we took to resolve your query. Where we collect your email address using this cookie we will not add your email address to any direct marketing lists.

SnapABugBanned
Expires: 30 days

This cookie keeps track of any users banned from web chatting

We use this cookie on pages of our website used by Professional Investors.

This data enables web chat to function and prevents a web chat window being opened with banned users (e.g. by visitors blocked by Source web chat team)

Cookies set by HubSpot:
__hstc
Expires: 2 years

This cookie is the main cookie for tracking users on our website. It contains: the domain, utk (see below), initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session)

We use this cookie when users first come to our website.

This data is matched with incoming user information to the HubSpot database (please see the row below for further information on the purpose for which we use the Hubspt database)

hubspotutk
Expires: 10 years

This cookie is used to keep track of a user’s identity by giving the user a unique ID (ID44692, for example)

We use this cookie when a user first enters the website and when the user fills out a web form.

We pass data collected using this cookie to HubSpot on form submission and use this data when deduplicating contacts. This cookie does not store personal data.

__hssc
Expires: 30 min

This cookie keeps track of sessions (number of visits to the Source website).

We use this cookie on site entry.

This data is used to determine if we should increment the session number and timestamps in the hstc cookie. It contains: the domain, viewCount (increments each pageView in a session), session start timestamp.

__hssrc
Expires: None. Session cookie

Whenever HubSpot changes the session cookie, this cookie is also set.

We use this cookie on site entry.

We use this data to determine if a user of our website has restarted their browser. We set it simply to the value "1", and use it to determine if the user has restarted their browser. If this cookie does not exist when we manage cookies, we assume it is a new session.

GOOGLE _ga
Expires: 2 years

This cookie uses a client ID, to distinguish users.

We use this cookie on site entry.

We use this data to help to confirm returning/unique users.

GOOGLE _gat
Expires: 10 min

This cookie is used to throttle request rate.

We use this cookie on site entry.

This cookie does not store any personal data, it's just used to limit the number of requests that have to be made to doubleclick.net.

Drupal: has_js
Expires: session only

This cookie is used to check if Javascript is enabled on the user’s system. This cookie indicates if the user’s browser supports Javascript

We use this cookie on site entry.

We use this data as part of our content management system, which needs this to serve web content (such as the performance charts on the product pages).

Third party cookies

We work with third parties who, on our behalf, research the use of our website and activities on it. In doing so they may place a cookie on your computer. However, it would not contain any personal data in a format that can be read by anyone else.

We also work with third parties to evaluate the effectiveness of our advertising and promotions on third party websites. Again, the cookie would not contain any personal data in a format that can be read by anyone else.

Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Accepting or rejecting cookies

You can refuse, accept or remove cookies at any time by using the settings on your internet browser. You can configure your internet browser to warn you each time a new cookie is about to be stored on your computer so that you can decide whether to accept or reject it. Please refer to your internet browser's help section for further information. Please note that some parts of our website may not function properly if you reject cookies.

Use of Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc. (Google). Google Analytics uses cookies, which are text files stored on your computer or mobile phone to help analyse how the website is used by you. As a rule, the information generated by the cookie about your use of the website is transmitted to and stored by Google on a server in the United States. If IP anonymisation is activated on this website, however, your IP address will be truncated by Google in Member States of the European Union or in other states party to the Agreement on the European Economic Area prior to transmission. Only in exceptional cases will the complete IP address be transmitted to a Google server in the United States and truncated there. Google will use this information on behalf of the operator of this website for the purpose of evaluating your use of the website, compiling website activity reports and providing other services to us relating to the use of this website.

The IP address transmitted by your browser within the scope of Google Analytics will not be associated with any other data held by Google.

You can prevent the storage of cookies by selecting the appropriate settings of your browser software; however, please note that if you do this, you may not be able to use the full functionality of this website.

You can also prevent the data (including your IP address) generated by the cookie relating to your use of this website from being collected and processed by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

This website uses Google Analytics with the extension "_anonymizeIp()". This means that only truncated IP addresses will be further processed so as to prevent them from being linked to a specific user.

The use of Google Analytics is made in line with the requirements agreed between the German data protection authorities and Google. Third-party provider information: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Terms of Service: http://www.google.com/analytics/terms/de.html, Overview - Safeguarding your data: http://www.google.com/intl/de/analytics/learn/privacy.html and Privacy Policy: http://www.google.de/intl/de/policies/privacy

 

Use of HubSpot

We use the web analytics technology of HubSpot to enable a statistical analysis of how this website is used by visitors. Such data are used to continuously improve the website, our service and make it more user-friendly. If you do not consent to such use, please untick this box .

For this purpose HubSpot creates pseudonymized user profiles to form the basis for statistics. You may at any time object with future effect to the creation of pseudonymized user profiles by unticking the box above.

You will only be personally identifiable once you fill out our contact form on the website. In this case only, we link the analytic data collected, processed or used via HubSpot to your personal data. You may at any time object with future effect to the matching of your pseudonymized user profiles with your personal data by unticking the box above.

Direct Marketing

We will only send direct marketing to you if you have given your consent for us to do so and we will not supply your personal data to third parties for their direct marketing activities, without your consent, other than in the context of a sale of this web site or a sale of our business. If you change your mind later on and you would like us to stop sending direct marketing to you, we offer simple ways to do this. Whenever you receive direct marketing by email you will be told how to unsubscribe electronically. You can also unsubscribe by contacting us at invest@sourceetf.com.

Revisions to the Privacy Policy and Cookies Statement

We reserve the right to revise this policy at any time by posting a revised Privacy Policy and Cookies Statement online (of which you will be made aware when you next access this web site after such revisions have been made) and your continued access to or use of the website will mean that you agree to these changes. If you have any questions about this Privacy Policy and Cookies Statement please email us at invest@sourceetf.com.

Issued and approved in the United Kingdom by Source UK Services Limited which is authorised and regulated by the Financial Condut Authority. © 2017 Source UK Services Limited. All rights reserved.

Issued and approved in the United Kingdom by Invesco Asset Management Limited which is authorised and regulated by the Financial Conduct Authority.