Robeco, The Investments Engineers

Privacy and Cookie Statement

Robeco Holding B.V. in Rotterdam and/or its related, affiliated and subsidiary companies (hereinafter ‘Robeco’) is responsible for the processing of your personal data as described in this Privacy and Cookie Statement.

We consider it important to ensure that we provide our services in a transparent, personal and reliable manner. Therefore, Robeco handles your personal data with care and ensures that your personal data is always processed in accordance with applicable privacy and data protection legislation.

This Privacy and Cookie Statement describes, among other matters, the processing objectives, the data categories, the use of cookies by Robeco and how you can exercise your rights with regard to your personal data.

For whom

If you are a visitor of our website, an investor, a prospect, a representative or former representative, executive or Ultimate Beneficial Owner of a client or business partner of Robeco, we will process your personal data.

Definitions

Personal data is information relating to an individual, which can be used either alone or with other sources of information to identify that individual. Personal data does not include information where the identity of the individual or the specific detail of the information has been removed and is therefore anonymous. Sensitive personal data is a sub-category of personal data that includes information relating to race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data.

Personal data we collect and process about you

The nature of the information that we collect and process will depend on the services we provide and our relationship with you. It can consist of:

  • identification data: full name, title, gender, date of birth, passport number, national identification number, signature;

  • professional information: organization, position/job title, work address, telephone number, email address;

  • electronic monitoring data: to the extent permitted by law, we may record and monitor your electronic communications with us;

  • marketing and communications data: marketing and communication preferences, tracking data relating to whether you have read marketing communications from us;

  • technical data: a number of technical details will also be registered including your IP address, the type of connection, the browser you use, your device’s operating system, the pages you visited on the website and your username and password; and/or

  • sensitive personal data: in limited circumstances, and where allowed by law, we may collect your photo on a copy of your passport or information about your political affiliations for us to determine whether you are a politically exposed person.


How do we collect your personal data

We collect personal data in relation to you in a number of ways, including:

  • if you are representative of an organization that is a client or business partner of Robeco and that organization provides us with your personal data;

  • when you provide personal data to us in connection with a Robeco product or service;

  • from public sources where you have manifestly chosen to make your personal data public, including via public profiles on social media;

  • from third parties such as seminar/webinar organizers, company registers and online search engines and platforms (open or otherwise accessible); and/or

  • from visits to our websites.


Unless we otherwise indicate that the provision of specific personal data is optional, any personal data we request is necessary for us to provide you or your organization with the services requested. If you do not provide the personal data requested, we may not be able to provide those products and services to you.

Why do we process your personal data?

If you are a prospect and not in the process of becoming a client, we will process your personal data (including name, contact details and professional data) to build a relationship and provide you with targeted communication about Robeco services that might suit your needs. This processing is based on the legitimate interest of both Robeco and the prospect. In the case of untargeted communication, such as newsletters, Robeco always requests your consent to receive untargeted communication. This consent can be withdrawn at any time.

If you are a prospect in the process of becoming a client, we will process your personal data (including identification data, professional data and in select cases sensitive personal data) as part of our customer due diligence process. This processing activity is necessary to comply with our legal obligations regarding anti-money laundering (AML) and Sanctions.

If you are an investor, representative, executive or Ultimate Beneficial Owner of a client of Robeco, we will process your personal data on the basis of the agreement we have and also to comply with our legal obligations including our anti-money laundering (AML) and Sanctions obligations and those under tax legislation.

When you are visiting Robeco’s website, we process your personal data in order to make the website function properly and to decide what content to show and in which language. Technical personal data is logged for performance and security purposes, which is the legitimate interest of Robeco. When consenting to analytical or marketing cookies, we use your personal data to further improve our communications and services (also see the section “What are cookies” in this statement).

If you are visiting the Robeco website and share your personal data with Robeco through a web form (for instance when signing up for a webinar), we will use the web form or web page to inform you about the purpose of that specific data processing.

Marketing and exercising your right to opt out of marketing

If you are a prospect, we will only use your personal data for marketing purposes if you explicitly gave your consent to do so. This consent can be given in two different ways:

  1. when we receive the personal data directly from you (the data subject) via a form on our website, we will ask for your consent in the associated web form;

  2. when we receive the personal data from external organizations (e.g. from a seminar organizer), we will send you a one-time email asking for your consent to receive marketing materials. This one-time email is sent based on legitimate interest, as the data subject has expressed interest in the services Robeco offers or knowledge that Robeco shares.


We will stop processing your personal data for marketing purposes if you have informed us you do not wish to receive marketing materials anymore. You can request that we stop processing your personal data for marketing purposes at any time by clicking on marketing opt-out links in any electronic marketing materials we send you, by making a request to your usual contact person at Robeco or by using the contact details set out in the “Contacting us” section of this statement.

Third parties

Robeco Holding & ORIX Corporation

To provide global services and in the course of running our business, we may transfer personal data to another company within Robeco Holding B.V. or to another company within ORIX Corporation (Robeco’s parent company) that is based at a location outside of the country where you reside or where services are provided to you or to the organization or entity you work for. Although the country to which personal data may be transferred may not have the same level of privacy and data protection laws, we apply the same level of security and organizational controls to the processing of personal data wherever it is processed.
We only share your personal data with another company within ORIX Corporation if you have expressed interest in one or more services that the external organization offers. In those cases, we will only share your full name, title and professional information.

Other third parties

We do not share your personal data with any other third parties outside ORIX Corporation, except when it’s necessary to execute our professional services, or when we are required to do so by law, a government body or a private party in connection with a lawsuit, court decision, investigation or similar proceedings. This includes our third party service providers, such as our IT systems providers, hosting providers, consultants and other goods and service providers.

Security of personal data

We have measures in place to guarantee that your data is kept up to date and processed safely. Robeco takes appropriate technical and organizational measures to protect your personal data. All employees have signed a confidentiality agreement. Access to your data is limited to what is strictly necessary for the delivery of our services.

Our IT security meets international standards and is constantly adapted to new technical and legal requirements. We require by contract that our third party service providers processing personal data on our behalf comply with Robeco’s standards for processing personal data.

Personal data retention period

We will process your personal data for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory, accounting, reporting, internal policy requirements or for the establishment or defense of legal claims.
At Robeco, we use the following retention periods:

  • prospects who did not or not yet give their consent to receive marketing materials: 24 months after their personal data was collected1;

  • prospects who did give their consent to receive marketing materials: 24 months after the revocation of their consent via opt out1;

  • investors, representatives or former representatives, executives or Ultimate Beneficial Owners of a client or business partner of Robeco: 7 years after the termination of the last agreement with the investor, client or business partner. Voice recordings will be deleted 5 years after the recording. In Switzerland the retention period is 10 years after the termination of the last agreement with the investor, client or business partner due to local regulations;

  • website visits from identified prospects or clients will follow the abovementioned retention periods;

  • technical data of all other visitors will be deleted 2 months after the visit.


1 If we process the personal data of a prospect based on a legal basis other than consent (e.g. prior to an agreement or based on legitimate interest), the personal data will not be deleted after 24 months. In that case, we will stop using the personal data for untargeted marketing messages.

Your rights

In certain circumstances you may have the following rights in relation to the processing of your personal data:

  • right to access: to request a copy of the personal data we process in relation to you and to be informed about how we use and share your personal data;

  • right to rectification: to request we update your personal data or to correct your personal data that you think is incorrect or incomplete;

  • right to erasure: to ask that we delete personal data that we process in relation to you where we do not have a legal or regulatory obligation or other valid reason to continue to process it;

  • right to restriction of processing: to request that we restrict the way in which we process your personal data, for example, if you dispute the accuracy of your personal data or have raised an objection which is under consideration;

  • right to object to processing: to object to the processing of personal data if (i) we are processing your personal data on the grounds of legitimate interests or for the performance of a task in the public interest (including profiling); or (ii) if we are processing your personal data for direct marketing purposes;

  • right to data portability: to request a copy of your personal data that you have provided to us in a commonly used electronic format;

  • right not to be subject to automated decision making: to request manual intervention if you are subject to automated decisions where the decision results in a legal or similar effect to you.


You may exercise your rights at any time by following the instructions set out in the “Contacting us” section in this statement.

To the extent permitted by applicable law or regulation we reserve the right to charge an appropriate fee in connection with you exercising your rights.

We may need to request specific information from you to help us confirm your identity and ensure your right to access to the personal data requested, or to exercise any of your other rights.

Contacting us

If you wish to exercise any of your rights, or have questions about the information above, please contact Robeco via your usual contact person at Robeco or contact one of Robeco’s privacy officers at privacy@robeco.com.

Complaints

If you have any concerns or complaints about the way your personal data is processed, please contact Robeco’s Data Protection Officer at DPO@robeco.com.

You also have a right to complain to a data protection or other competent authority with jurisdiction over privacy and data protection laws in the country where you live or work, or in the country where you believe an issue in relation to the processing of your personal data has arisen. Please contact DPO@robeco.com for further details.

Cookies, similar technologies

What are cookies and similar technologies?

Robeco's websites make use of cookies. A cookie is a small file that is transferred between the server and your system and enables the recognition of a specific device or browser. Cookies enable recognition of a specific device or browser and do not necessarily contain information that personally identifies a user. However, personal data that we or third-party providers commissioned by us store from you (e.g., if you have a user account with us or these providers) may be linked to the information stored in and obtained from cookies and thus possibly to your person. Cookies can collect data that is linked to the use of our websites. This enables Robeco to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

How does Robeco use cookies and similar technology?

When using the website, data is generated that is stored in logs (esp. technical data). Furthermore, cookies and similar technologies are used to recognize website visitors, evaluate behavior and recognize preferences. When you use Robeco’s websites, the cookie sends information back to us or to a third party who placed the cookie on our behalf. Robeco uses cookies to analyze your visit to this site, to recognize returning visitors and learn which topics they are interested in, to personalize the site and advertisements in line with your own preferences. Both the technical data we collect and cookies generally do not contain any personal data. However, personal data that we or third-party providers commissioned by us store from you (e.g., if you have a user account with us or these providers) may be linked to the technical data or to the information stored in and obtained from cookies and thus possibly to your person.


Cookie settings / reject cookies

You can set your browser to automatically reject, accept or delete cookies. You can also disable or delete cookies on a case-by-case basis. You can find out how to manage cookies in your browser in the help menu of your browser.
Robeco asks for your consent to use the cookies generated by your visit to Robeco’s websites. A pop-up cookies message appears when you land on the site. By clicking on the word “settings”, you can modify your preferences. You may return to the menu at any time to adjust your preferences.
If you have any further questions, please reach out to us by using the details set out in the “Contacting us” section of this statement.


Types of cookies

Robeco uses (1) strictly necessary cookies, (2) analytical cookies and (3) marketing cookies:

(1) strictly necessary cookies | Required cookies to ensure that this website functions properly;
(2) analytical cookies | Cookies to improve the website and to optimize your experience;
(3) marketing cookies | Cookies with which we can show relevant advertisements and information to you on our website, on other websites and via social media.

(2) Analytical cookies and (3) marketing cookies are not strictly necessary for the functionality of the Robeco websites. If you do not agree to the placement of these cookies, they are blocked.

Cookie overview

An overview of the cookies used by Robeco is available. The cookies placed on your computer or mobile device by this website will not be used for any purposes other than those stated in this data privacy statement.

Data processing on social media

Robeco operates pages and other online presences on social networks and other platforms operated by third parties and processes data about you in this context. In doing so, Robeco receives data from you (e.g. when you communicate with us or comment on our content) and from the platforms (e.g. statistics). The providers of the platforms may analyze your usage and process this data together with other data they have about you. They also process this data for their own purposes (e.g., marketing and market research purposes and to manage their platforms) and act as their own data controllers for this purpose. For more information on processing by the platform operators, please refer to the privacy statements of the respective platforms

We currently use the following platforms, whereby the identity and contact details of the platform operator are available in the privacy policy in each case:


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Important information
The Robeco Capital Growth Funds have not been registered under the United States Investment Company Act of 1940, as amended, nor or the United States Securities Act of 1933, as amended. None of the shares may be offered or sold, directly or indirectly in the United States or to any U.S. Person (within the meaning of Regulation S promulgated under the Securities Act of 1933, as amended (the “Securities Act”)). Furthermore, Robeco Institutional Asset Management B.V. (Robeco) does not provide investment advisory services, or hold itself out as providing investment advisory services, in the United States or to any U.S. Person (within the meaning of Regulation S promulgated under the Securities Act).
This website is intended for use only by non-U.S. Persons outside of the United States (within the meaning of Regulation S promulgated under the Securities Act who are professional investors, or professional fiduciaries representing such non-U.S. Person investors. By clicking “I Agree” on our website disclaimer and accessing the information on this website, including any subdomain thereof, you are certifying and agreeing to the following: (i) you have read, understood and agree to this disclaimer, (ii) you have informed yourself of any applicable legal restrictions and represent that by accessing the information contained on this website, you are not in violation of, and will not be causing Robeco or any of its affiliated entities or issuers to violate, any applicable laws and, as a result, you are legally authorized to access such information on behalf of yourself and any underlying investment advisory client, (iii) you understand and acknowledge that certain information presented herein relates to securities that have not been registered under the Securities Act, and may be offered or sold only outside the United States and only to, or for the account or benefit of, non-U.S. Persons (within the meaning of Regulation S under the Securities Act), (iv) you are, or are a discretionary investment adviser representing, a non-U.S. Person (within the meaning of Regulation S under the Securities Act) located outside of the United States and (v) you are, or are a discretionary investment adviser representing, a professional non-retail investor.


Access to this website has been limited so that it shall not constitute directed selling efforts (as defined in Regulation S under the Securities Act) in the United States and so that it shall not be deemed to constitute Robeco holding itself out generally to the public in the U.S. as an investment adviser. Nothing contained herein constitutes an offer to sell securities or solicitation of an offer to purchase any securities in any jurisdiction. We reserve the right to deny access to any visitor, including, but not limited to, those visitors with IP addresses residing in the United States. This website has been carefully prepared by Robeco. The information contained in this publication is based upon sources of information believed to be reliable. Robeco is not answerable for the accuracy or completeness of the facts, opinions, expectations and results referred to therein. Whilst every care has been taken in the preparation of this website, we do not accept any responsibility for damage of any kind resulting from incorrect or incomplete information. This website is subject to change without notice. The value of the investments may fluctuate. Past performance is no guarantee of future results. If the currency in which the past performance is displayed differs from the currency of the country in which you reside, then you should be aware that due to exchange rate fluctuations the performance shown may increase or decrease if converted into your local currency. For investment professional use only. Not for use by the general public.