Legal notice

Company Name
This website was created by Ostrum Asset Management. It is managed and updated by Ostrum Asset Management.
Ostrum Asset Management

Asset management company regulated by AMF under n° GP-18000014 – Limited company with a share capital of 50 938 997 euros – Trade register n°525 192 753 Paris – VAT: FR 93 525 192 753 – Registered Office: 43, avenue Pierre Mendès-France, 75013 Paris – www.ostrum.com

Details of the regulatory authority:
Autorité des Marchés Financiers (AMF)
17 Place de la Bourse
75082 Paris cedex 02, France

Publication Director: Olivier Houix, Head of Communications and CSR: Stéphanie Kowalski
Host: Alterway Hosting, 227 Bureaux de la colline, 1 rue Royale - Bât. D, 92210 Saint-Cloud
Telephone: +33 (0) 1 41 16 34 95

General conditions of use
This website and the information it contains may only be used subject to full compliance with these user conditions.
The information on this website or offered via this website is of a general nature; consequently, it should not be considered as tailored to your personal needs or specific circumstances.

Ostrum Asset Management  is entitled to change the information on this website at any time, at its own discretion and without prior notice.

Ostrum Asset Management  will do its utmost to ensure that the information published is as comprehensive, correct, accurate and up-to-date as possible. Ostrum Asset Management  cannot be held liable for any errors on or shortcomings of this website or for any damages resulting from use of the information it contains.
However, if it appears that the published information contains any errors, or if any information reasonably to be expected on the website is missing, Ostrum Asset Management  undertakes to rectify the situation as soon as possible after receiving notification of such shortcomings. To inform of us of any errors, please use the following address: [email protected].
 
Disclaimer in relation to the products and services presented on the website
The information (data, graphs and documents) displayed on this website, although issued by reliable sources, does not constitute investment advice in any way. Moreover, you are solely responsible for consulting this website.

If you wish to invest, please contact your usual advisor, who will help you assess the products that are best suited to your needs and who will also inform you of any potential risks.

The fact that you agree to continue consulting this website releases Ostrum Asset Management  from any present or future liability regarding your potential use of this information. The information that appears on this website is not intended to be distributed or used by any person or entity in a country or jurisdiction where such distribution or use contravenes any legal or regulatory provisions, or which require Ostrum Asset Management  or its subsidiaries to comply with registration formalities in such countries or jurisdictions. Not all of the products and services may be registered or authorised in all countries or available to all customers.

The data and information appearing on the website are supplied for information purposes only.

No information displayed on the website constitutes an offer to purchase, an invitation to sell shares or investment advice regarding the purchase or sale of equities, or an offer or invitation from Ostrum Asset Management  or its subsidiaries to supply investment advice or financial, legal, tax, or investment services connected with the purchase or sale of equities or other financial instruments.

Neither Ostrum Asset Management  nor any of its subsidiaries offer any guarantees or make any declarations, either expressly or tacitly, that the information supplied on this website is accurate, comprehensive or up-to-date.

One should only invest in a UCITS after consulting the simplified prospectus/key investor information documents pertaining to the Fund and the annual and half-yearly reports, where available. These documents may be obtained from this website or directly through the management company of the UCITS concerned.
 
Offers and promotions from third parties
Offers relating to products or services from third parties may be published on this website in the form of banners. If you click on one of these banners, you will be sent to a third-party website. Ostrum Asset Management  is not responsible for the content of any third-party promotions or the conditions applicable to their offers. These offers are presented on behalf of the third parties. If you wish to subscribe to these offers or enter into a contract in any form with such third parties, or if you wish to make a complaint about such offers or promotions, please contact these third parties directly.
 
Links to websites managed by third parties
This website may contain links to websites managed by third parties. These links are offered on this website for information purposes only. Ostrum Asset Management  provides no guarantees regarding the content, quality or comprehensive nature of such websites, and, consequently, may not be held liable in any way. The presence of a link to a third-party website does not imply that Ostrum Asset Management  has entered into any collaboration agreement with such third parties or that Ostrum Asset Management  has approved the information published on such websites.
 
Availability – compatibility
Ostrum Asset Management  will endeavour to provide access to the website at all times; however, it declines all responsibility for any damages resulting from any intentional or unintentional disruptions in the website’s availability.
Ostrum Asset Management  offers no guarantees that the files on the website will be compatible with your infrastructure and hardware. As a user, you must ensure that you have the appropriate computer equipment and the necessary software, including security programs (firewall, antivirus, etc.).
 
Intellectual property rights
Users expressly recognise that the information and data communicated is and shall remain the property of Ostrum Asset Management  or its partners, as mentioned on the website. Any texts, drawings, photos, images, data, corporate or domain names, brands, logos and other elements are protected by intellectual property rights.

No one may reproduce or distribute such elements to the general public without the prior written and express authorisation of Ostrum Asset Management , unless copyright laws or similar rights state otherwise. As a user, you are entitled to download information from the website, copy it for private use and distribute it free-of-charge within your family circle.

Although Ostrum Asset Management  allows you to upload your own contributions or images to the website, you may not upload elements protected by intellectual property rights unless you own the necessary rights or have received all the necessary authorisations from the eligible parties regarding the use of such items on the website. By uploading your own contributions or photos onto the website, you expressly grant Ostrum Asset Management  the right to publish these contributions or photos on the website and do not have the right to claim any payment for it. In any event, users provide full guarantees to Ostrum Asset Management  that no claims shall be brought against it by third parties.

Unauthorised use of the website
As a user of this website, you undertake not to:
- Use the information published on this website in an illegal or unlawful manner;
- Use this website in such a way that the website is damaged, altered, disrupted or rendered less effective in any way whatsoever;
- Use this website to transfer or send computer viruses, or to transmit or send illegal or unlawful material, or material that is inappropriate in any way, including, though not limited to, material of an outrageous, obscene or threatening nature;
- Use this website in such a way that it infringes the rights of a physical person, a legal entity or an association, including, though not limited to, the rights attached to respect for privacy and intellectual property;
- Use this website to send or transfer material for promotional or advertising purposes.

Ostrum Asset Management  reserves the right to issue a formal notice to the user and/or to bring a civil action in the event of an infringement of its rights or those of a third party following a breach of the aforementioned provisions or any other type of breach.

Personal Data

Personal data processing (“Personal Data Processing”) carried out by Ostrum Asset Management complies with applicable legal requirements, including in particular Regulation (EU) 2016/679 (generally referred to as the “General Data Protection Regulation” or “GDPR”), “Personal Data Processing Act no. 78-17 of 6 January 1978” and “Digital Republic Act no. 2016-1321 of 7 October 2016”.
We recognise the importance of protecting your Personal Data when you visit the website https://www.ostrum.com/ (“Website”). This notice is intended to provide you with clear, precise and accessible information on the processing we carry out when you browse our Website.

1-    Why do we collect your personal data?
Ostrum Asset Management collects Personal Data for specified, explicit and legitimate purposes in relation to the activities carried on. Ostrum Asset Management, in its role as data controller, pursues the following purposes by operating its Website:

• Placing cookies required to ensure the proper functioning of the Website;
• Processing data provided on a voluntary basis by a user who wishes to benefit from the subscription service;

Additional information is provided to you in the section on “Cookies”.

2-    The reason for data collection is lawful and restricted to what is strictly necessary
In the role as “Data Controller”, Ostrum Asset Management ensures that the processing which it implements is lawful by making sure that each legal basis for personal data processing is determined on a case-by-case basis. The main legal reasons linked to the Website’s activities are:

The processing carried out by Ostrum Asset Management on its Website restricts personal data collection to what is strictly required. We only process data which is adequate, relevant and restricted to what is necessary for the purposes of the processing.

3-    Types of data collected
The quantity and type of Personal Data processed vary according to the given processing on the Website. For example, we process your name or even your e-mail address which you provide to us on a voluntary basis in relation to our subscription service.
In any event, we only process data which is adequate, relevant and limited to what is necessary for the purposes of the processing.

4-    Data storage period
Storage periods for personal data collected and processed by Ostrum Asset Management are restricted and determined on a case-by-case basis according to the purpose of the processing and regulatory requirements (recommendations by the CNIL (French Data Protection Authority), legal provisions, etc.). Cookies which are “essential” to use the Website stored on your computer are not kept longer than one (1) month.  Data which you provide on a voluntary basis when you sign up for our subscription offer is only kept for the term of your subscription.

5-    Security of your personal data
Ostrum Asset Management implements technical and organisational measures to ensure the security of your personal data. All measures are taken in order to ensure the availability, integrity and confidentiality of your personal data which you provide to us. These measures help us to ensure that your personal data is not damaged or distorted or consulted by an unauthorised third party.
We are required to promptly report any breach of your personal data to the CNIL (French Data Protection Authority) and to inform you.

6-    Recipients or categories of recipients of data
We only transmit data to recipients (“Recipients”) for legitimate reasons. Such transmission of your Personal Data is essential to run our Website’s activities, or to comply with legal obligations.  We do not sell or lease your Personal Data under any circumstances.
When a third party is granted access to our information system, the rights that are granted to such third party are strictly restricted to his/her remit for action (principle of least privilege). All action taken by third party is tracked to make sure that they comply with his/her assignment.

7-    Your rights
You have the right to make the following requests, as the case may be:

• Access your personal data stored by Ostrum Asset Management;
• Correct your personal data: you may request correction of your personal data stored by Ostrum Asset Management which is inaccurate, out-of-date or incorrect;
• Delete your personal data (“right to be forgotten”): you are entitled to ask Ostrum Asset Management to delete your personal data based on legal reasons.  For example, if some data collected is no longer required in relation to the purposes for which it was collected;
• Withdraw consent: relating to processing based on such consent;
• Portability of your personal data in digital format: this right only applies to cases where the Personal Data is provided by you and processed based on your consent or performance of a contract;
• Object to processing of your data: you may object to processing of your data at any time based on reasons relating to your specific situation;
• Restrict processing of your data: when you consider that your Personal Data held by Ostrum Asset Management is incorrect;
• Give instructions on storage, deletion and disclosure of your data after your death.

We use our best efforts to promptly reply to your requests. You may be asked, where applicable, to attach proof of ID to your request.

8-    How to exercise your rights
You can exercise your rights by sending a letter attaching proof of ID to Ostrum Asset Management, for the attention of the Data Protection Officer (“DPO”), at the following address:
Ostrum Asset Management
43 Avenue de Pierre Mendes France
75648 Paris Cedex 13 France
Or by e-mail to the following address: [email protected]
Protecting your personal data and ensuring the effectiveness of your rights are priorities for Ostrum Asset Management. Nevertheless, if you are not satisfied with the way in which we process your Personal Data, we encourage you to contact our Data Protection Officer so that we can deal with your concerns. You also have the right to file a complaint with the local data protection authority (the “CNIL” in France).

9 – Glossary
Personal Data Processing
Any information directly or indirectly relating to an identified or identifiable person, in particular by preference to an identifier such as a name, an identification number, location data or an online identifier.
Processing
Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, deletion or destruction.
Recipient
Any natural or legal person, public authority, agency or another body, to which personal data is disclosed.
Data Protection Officer
The data protection officer is also referred to as the “DPO”.  He/she is your preferred contact person if you wish to raise a question on processing carried out by Ostrum Asset Management. He/she is also your contact person if you wish to exercise your rights.
Data Controller
The organisation which collects and processes your data and also determines the and purposes of the processing.
Commission Nationale Informatique et Libertés (CNIL)
The CNIL is the French data protection authority. It provides support to companies relating to compliance and assistance to individuals with controlling their personal data and exercising their rights.

Mediation by the Autorité des Marches Financiers (French Financial Markets Authority)
The Autorité de Marchés Financiers (AMF) offers a mediator that can hear the case of any interested party, whether a physical person or a legal entity, and settle individual disputes whose nature falls within the scope of its remit, that is, financial investments.

To use the mediation service, send a letter by post to the following address:
Médiateur de l’AMF (AMF Mediator)
Autorité des Marchés Financiers
17 Place de la Bourse
75082 Paris cedex 02, France

A mediation request form is available online from the AMF’s website  ( www.amf-france.org ).