Privacy Policy

Marshall Wace LLP, Marshall Wace North America LP, Marshall Wace Asia Limited, Marshall Wace Investment Management (Shanghai) Limited, Marshall Wace Singapore Pte Ltd and Marshall Wace Middle East Limited (together “we”, “us”, “our” or “Marshall Wace”) are committed to respecting your privacy.

 

Addresses:

Marshall Wace LLP: 131 Sloane Street, London, SW1X 9AT.

Marshall Wace North America LP: 66 Hudson Boulevard East, 32nd Floor, New York, NY 10001.

Marshall Wace Asia Limited: 23/F, LHT Tower, 31 Queen’s Road Central, Hong Kong.

Marshall Wace Investment Management (Shanghai) Limited: Unit 4301, Level 43 HKRI Taikoo Hui Tower 1, 288 Shimen Yi Road, Jing`An District, Shanghai, China.

Marshall Wace Singapore Pte Ltd: 27F, Unit 1, 18 Robinson Road, Singapore 048547.

Marshall Wace Middle East Limited: Unit 37 & 38, Level 25, Al Sila Tower, Abu Dhabi Global Market Square, Abu Dhabi, Al Maryah Island, United Arab Emirates.

 

About this privacy notice

For the purposes of data protection law, we are a controller in respect of your personal data. Marshall Wace is committed to respecting the confidentiality of your personal data. It is responsible for ensuring that it uses any personal data provided by you in compliance with data protection law. It does not sell, nor has it previously sold, your personal data to third parties.

This privacy notice applies if you are an existing or prospective client, or you otherwise interact with us or our technology agents through our website or in other business settings. This privacy notice sets out the basis on which any personal data that you provide to us, that we create or that we obtain about you from other sources, will be processed by us. Please take the time to read and understand this privacy notice. If you are an applicant applying for any roles with us, please refer to our Applicant Privacy Notice.

 

Personal data that we collect about you

We will collect and process the following personal data about you:

Information that you provide to us or one of our affiliates. This includes information about you that you give to us by filling in forms (including those on our website) or by communicating directly or indirectly with us, whether face-to-face, by telephone, e-mail or otherwise, including if you apply (or are referred to apply) for a position with us. This information may include your name, address, email address, telephone number, IP address, any financial information and other information provided by you in connection with:

  1. any due diligence;
  2. a prospective investment in any funds managed by us;
  • completing any forms or other materials sent by or on behalf of us to you in relation to any prospective investment or investment made;
  1. any ongoing communications with us regarding any prospective investment or investment made;
  2. by attendance at a webinar, conference call (whether or not video), broadcast or similar virtual meeting us or our technology agents are also attending or
  3. any related matters.

Our ability to provide our services to you may be impacted if specific personal data needed to perform those services is not provided (e.g. name, address, etc.).

Information we collect or generate about you. This includes:

  • information in any client relationship management notes;
  • recordings of telephone conversations or conferences calls (whether or not video) or notes derived from same, including transcription data, whether verbatim or transcribed, from such calls;
  • notes or summaries of meetings, events, conference calls (whether or not video) or other communications, whether we host or not;
  • information derived from audio and transcription data or notes of meetings, conference calls (whether or not video) or other calls;
  • information you provide to us in the completion of any documentation, whether through our website, by email (or other means of online communications) or in-person at any conferences, meetings or other events;
  • data generated from our on-premises security, such as CCTV footage or records of visitors and usage of guest passes; and,
  • information about how you use and interact with our website, as further described under Use of Cookies in the Terms of Use for our website.

Information we obtain from other sources. This includes information received from any distributor, placement agent, custodian, fund of funds or management or other company acting on your behalf.

Uses of your personal data

Your personal data may be stored and processed by Marshall Wace in the following ways and for the following purposes:

  • sending you information in relation to the funds we act as investment manager for, facilitating an assessment of your eligibility to invest, processing any subscription, redemption, withdrawal, exchange or transfer request, and communicating with any third parties you may ask us to communicate with;
  • transcribing or summarising audio from meetings and conference calls, using artificial intelligence; and
  • other legitimate business purposes, such as due diligence, undertaking business or investment research and analysis and managing the operation of our website and our business.

We use your personal data in these ways because that use is necessary:

  • to perform the obligations set out in any subscription, redemption or withdrawal, exchange or transfer request, i.e., in a contract between you, as the data subject, and the fund we act as investment manager for, as the controller;
  • for our legitimate business interests or the legitimate interests of one or more of our affiliates, such as maintenance of client records, communicating with clients in relation to funds we act as investment manager for that clients or prospective clients have expressed an interest in, processing certain types of data, including communications, such as conference calls (whether or not with video), undertaking our functions as an investment managers, including performing investment research and due diligence on service providers, and where necessary for the purpose of assessing accommodations or adjustments in our recruitment process;
  • for us to comply with our legal and regulatory obligations; and
  • for us to establish, exercise or defend our legal rights or for the purpose of any legal proceedings.
  • In some circumstances, we process personal data based on the relevant individual’s consent. This includes when we collect personal data from you at events we host.

We may use artificial intelligence or other machine learning tools to process your personal data in the course of our business.

Some processing activities may involve automated analyses or limited automated decisions that support our business purposes. Where automated decision-making is used, it is appropriate to the context and subject to safeguards designed to protect your rights and interests. Decisions we make based on this processing will not be based solely on automated decision-making.

Disclosure of your information to third parties

We may disclose, and have in the previous 12 months disclosed, your personal data to our affiliates in order for us to discharge our obligations to the funds we act as investment manager for, and/or in order for us to communicate effectively between related parts of our business.

We will take steps to ensure that personal data is accessed only by staff that have a need to do so for the purposes described in this notice.

We may also share, and have in the previous 12 months shared, your personal data outside of Marshall Wace and our affiliates for legitimate business purposes, including, without limitation, with:

  • the board of the funds we act as investment manager for;
  • the board of any external AIFM or management company of the funds we act as investment manager for;
  • any regulators applicable to our business or to the funds we act as investment manager for;
  • the administrator and/or custodian of the relevant funds we act as investment management for;
  • any third parties you ask us to communicate with;
  • charities with which Marshall Wace may work;
  • third party agents or contractors (for example, the providers of our electronic data storage services and applicant portal), for the purpose of providing services to us. We note that these third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice, and
  • other recipients to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation, or to establish, exercise or defend our legal rights.

We do not sell your personal data to third parties and have not previously sold your personal data.

 

Transfers of personal data outside the United Kingdom and European Economic Area

Please note that this section only applies to you if UK or EU data protection laws apply to our handling of your personal data.

The personal data that we collect from you may be transferred to, and stored at, a destination outside the UK and the European Economic Area (“EEA”). It may also be processed by staff operating outside of the UK and the EEA who work for our affiliates or for one of our third-party agents or contractors.

Where we transfer your personal data outside the UK and the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the UK and the EEA. This can be done in a number of ways, for example:

  • the country that we send the data to might be approved by a UK government or European Commission adequacy decision (as applicable); or
  • where the country that we send the data to has not been approved by an applicable adequacy decision, we ensure appropriate safeguards are in place in respect of such transfer, such as “standard contractual clauses” approved by the UK Information Commissioner’s Office or the European Commission (as applicable), obliging the recipient to protect your personal data.

In other circumstances, the law may permit us to otherwise transfer your personal data outside the UK and the EEA. However, in all cases, we will ensure that any transfer of your personal data is compliant with data protection law.

You can obtain more details of the protection given to your personal data when it is transferred outside the UK and the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Contacting us” section below.

 

Transfers of personal data outside of Singapore

Please note that this section only applies to you if Singapore law applies to our handling of your personal data.

The personal data that we collect from you may be transferred to, and stored at, a destination outside of Singapore.  It may also be processed by individuals outside of Singapore who work for us or one of our suppliers.

Where we transfer your personal data out of Singapore, we will ensure that it is protected in a manner that is protected with how your personal data will be protected by us in Singapore.

Transfers of personal data outside of Mainland China

Please note that this section only applies to you if Chinese law applies to our handling of your personal data.

The personal data that we collect to you may be transferred to, and stored at, a destination outside of Mainland China, for the same purposes and in the same manners as set out in this privacy notice.  It may also be processed by individuals outside of Mainland China who work for us or one of our suppliers.

By accessing this website and/or submitting your personal information to us, you will be deemed to have expressly consented to the transfer of your personal data outside of Mainland China as required.

Retention of personal data

How long we hold your personal data for will vary. The retention period will be determined by various criteria including:

  • the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
  • legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.

 

Your rights

Please note that this section only applies to you if UK / EU / Mainland China / HK / Singapore data protection laws apply to our handling of your personal data.

You have a number of legal rights in relation to the personal data that we hold about you. These rights include:

  • the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
  • where you have actively provided your valid consent for us to process your personal data, the right to withdraw your consent to our processing of your personal data at any time. However, please note that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so;
  • in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those 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;
  • the right to request that we rectify your personal data if it is inaccurate or incomplete;
  • the right to request that we erase your personal data in certain circumstances. However, please note that there may be circumstances in which you ask us to erase your personal data but we are legally entitled to retain it;
  • the right to object to, and the right to request that we restrict our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to either continue processing your personal data and / or to refuse that request.

In addition to the above, you retain the right to lodge a complaint with us or the applicable data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details set out in the “Contacting Us” section below. You can find out more information about your rights by contacting (1) the UK Information Commissioner’s Office at https://ico.org.uk/; (2) the Office of Privacy Commissioner for Personal Data Hong Kong at https://www.pcpd.org.hk/; or (3) the Singapore Personal Data Protection Commission at https://www.pdpc.gov.sg/Overview-of-PDPA/The-Legislation/Personal-Data-Protection-Act or (4) checking your corresponding EU Member State Data Protection Authority details at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

 

Your rights (California)

Please note that this section only applies to you if the California Consumer Privacy Act of 2018 (the “CCPA”) applies to our handling of your personal data (i.e., if you are a California, USA resident).

Right to Know

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will provide you with:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information is collected;
  • Our business or commercial purpose for collecting or selling personal information;
  • The categories of third parties with whom we share personal information, if any; and
  • The specific pieces of personal information we have collected about you.

Please note that we are not required to:

  • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
  • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
  • Provide the personal information to you more than twice in a 12-month period.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

  • Delete your personal information from our records; and
  • Direct any service providers to delete your personal information from their records.

Please note that we may not delete your personal information if allowed under the CCPA, including if retaining your personal information is necessary to:

  • Complete the transaction for which the personal information was collected, provide a service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Comply with the California Electronic Communications Privacy Act;
  • Enable solely internal uses that are compatible with the context in which you provided the information or reasonably aligned with your expectations based on your relationship with us; or
  • Comply with an existing legal obligation.

Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

  • Deny services to you;
  • Charge different prices or rates for services, including through the use of discounts or other benefits or imposing penalties;
  • Provide a different level or quality of services to you; or
  • Suggest that you will receive a different price or rate for services or a different level or quality of services.

Please note that we may charge a different price or rate, or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to us by your personal information.

You can exercise your rights by contacting us using the details set out in the “Contacting us” section below. If you choose to exercise any of the rights you have under the CCPA, you will need to provide us with:

  • Enough information to identify you (e.g., your full name, address and customer or matter reference number);
  • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
  • A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

You have the right to appoint an authorized agent to exercise your rights on your behalf. If you want your authorized agent to exercise your rights on your behalf, we reserve the right to require that you:

  • Provide the authorized agent to act for you; and
  • Verify your own identity directly with us as described above.

 

Contacting Us

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please send your query to your usual Marshall Wace contact,  or email [email protected]. For CCPA requests you may also call +1 212 235 2845.

 

Accessibility Information

For consumers with disabilities who need to access this Policy in an alternative format, please contact: +1 212 235 2845.