At Franklin Templeton (FT), we care about your privacy and value the trust you place in us when you share your personal information.
This notice is for the Tenant(s) (defined as the tenants and/or lawful occupiers of the real estate assets directly or indirectly owned by the Franklin Templeton Social Infrastructure Fund) (referred to as our Properties).
From time to time, we may update this notice and any new version is always available on our website:
www.franklintempletonglobal.com/privacy
Refer to the link called: FTSI Tenants under the “FT Affiliates & Subsidiaries” tab of the website
The entity responsible (controller) for the collecting and processing of your personal information is:
Franklin Templeton Social Infrastructure Fund (FTSI)
8A, rue Albert Borschette
L-1246 Luxembourg
Grand Duchy of Luxembourg
For a full list of FT companies (controllers), visit:
www.franklintempletonglobal.com/privacy/fund-entities
If you have any questions about data protection, you can contact us via the details listed in section 3 of this notice.
This notice describes the categories of personal information we collect and for which purposes. By personal information, we mean information
that is reasonably capable of being directly associated to you or that is reasonably linked, directly or indirectly, to you.
Sources of Personal Information
We may collect personal information from the following sources:
- From you, directly, or from those acting on your behalf;
- Automatically collected from the internet or other network activity, internal monitoring activities, or closed-circuit television (CCTV) located in our offices and/or our Properties;
- Other parties that perform services for us or on our behalf (including our property managers); or
- Publicly available sources of information.
Personal Information We Collect
We may collect the following types of personal information:
- Contact information such as name, phone number(s), physical and email addresses;
- Pictorial Information such as CCTV monitoring, when visiting our offices and/or our Properties;
- Communications such as emails, telephone calls, web platform (Skype/MS Teams, etc) calls, texts, chats or Instant Messenger (IM), events written communication between us or between you and our property managers. All communications may be recorded and/or archived;
- Information captured by our websites such as web logs, cookies, and information about your interactions with our websites and FT webpages on social media sites such as Twitter and LinkedIn;
- Information collected when attending an in-person event or webinar such as your registration details, engagement with/follow up to the webinar or event, or information to allow us to analyse and make improvements to our offerings and services;
- Information collected by our property manager(s) in connection with your potential and/or actual occupation of the Properties such as proof of identity (passport/ photographic identification, confirming your full legal name, date of birth and signature), proof of eligibility criteria (if relevant), proof of financial status (e.g. credit checks, payslips, employment contracts, financial aid statements, guarantors, security deposits etc.), the terms of your lease/ tenancy agreement (Lease), any on-going dialogue about the terms of your Lease, any disputes, legal action, complaints, inquiries, rent and/or service charge payments and/or arrears, insurance coverage and/or claims and physical inspection reports (including damage logs).
- Other information collected or generated in connection with your relationship with FTSI such as your responses to our surveys, your
opinions about our services and/or other contact or demographic information.
How We Use Your Personal Information
We may use your personal information for the following purposes:
- perform FTSI’s legal and compliance obligations;
- perform actions necessary to fulfill a Lease that we have with you;
- internal analysis and research to improve our services;
- invitations and connected management of our events at the Property;
- business management and other legitimate business purposes in compliance with our policies and procedures, or as otherwise permitted or required by law.
We consider our legitimate interests to be:
- promotion of our business at a Property level and to our actual and/or potential investors;
- improvement and management of our services at the Properties; and
- facilitation of ongoing, existing relationships and potential new opportunities in connection with those relationships.
Data retention and protection
We keep your personal information for as long as necessary in connection with the purposes identified within this notice, and for a reasonable period thereafter, in accordance with local retention periods.
It may differ from jurisdiction to jurisdiction however, in the majority of cases, this will be during our relationship and then for 10 years after the end of the relationship.
In certain circumstances, data may be retained for a longer period of time, for example, where we are in ongoing correspondence or there is possible litigation, a continuing claim, or investigation.
Our web logs are kept for 60 days for security reasons.
We have implemented reasonable administrative, technical, and organizational measures, including physical, electronic, and procedural safeguards, based on our Corporate Information Security policy, which is designed to secure your personal information. For example, access to your personal information is limited to authorized FT employees, and FT employees are required to follow specific procedures with respect to maintaining the confidentiality of your personal information.
Information that we share
Your personal information may be transferred to, and stored, outside the country where you reside within our group of companies and/or service providers. We may also provide your personal information to local government and regulatory agencies or law enforcement to meet legal or regulatory obligations. Please refer to Third parties and other recipient categories (section 4) for the categories of potential third-party recipients.
FTSI has offices in the following countries: The European Economic Area, United Kingdom and United States.
FT has offices in the following countries: Argentina, Australia, Bahamas, Canada, China, Cayman Islands, Dubai International Financial Centre (DIFC), Countries within the European Economic Area, Hong Kong, India, Israel, Japan, Korea, Malaysia, Singapore, South Africa, Switzerland, Turkey, United Arab Emirates, United Kingdom, and the United States.
Some of these countries may not have the equivalent level of data protection laws as those in your location. If we need to transfer your personal information internationally, we will take steps to make sure that it is protected and safeguarded].
In addition to sharing information with other FT group companies and third- parties, we may also share or transfer your personal information to a prospective or actual purchaser or transferee, in the event that a Franklin Templeton company or its assets is/are merged or sold or a sale or transfer is intended.
Why do we collect your personal information?
Your personal information is collected (including sharing such information with third parties) where we have a legal reason to do so:
- To fulfill a contract we have with you;
- When it is our legal duty;
- When you consent to it;
- When it is in our legitimate interest*;
(*) Our legitimate interest is when we have a valid business or commercial reason to use your information and the use does not negatively impact your personal rights and freedoms.
Your Rights
You may have the following rights, under certain circumstances, in relation to your personal information:
- Ask whether FTSI has personal information about you and for what purpose and if it is disclosed to third parties;
- Access to your personal information including copies of that information;
- Rectify inaccurate/incomplete personal information about you;
- Request deletion of your personal information;
- Raise a complaint to a supervisory authority;
- Additionally, you may have the right to request a restriction, objection or data portability in certain circumstances.
If you wish to exercise a right, download our Individual Rights Request Form (www.franklintempletonglobal.com/rightsrequestforms) or you may contact us via the details provided in section 3 below.
The information will be provided free of charge, except where local laws allow for charges.
Contact us at one of the following addresses to exercise a privacy right, ask a question, share a concern, or make a complaint regarding this notice and/or our privacy practices:
FAO: Data Protection Officer
Franklin Templeton International Services S.à r.l.
8A, rue Albert Borschette
L-1246 Luxembourg
Grand Duchy of Luxembourg
The following categories of associated third parties may receive your personal information, as applicable (some of the systems or applications used in connection with these recipients may be cloud-based):
- Account processing system suppliers – provide services or maintain systems processing account information.
- Administrators/transfer agents – provide account maintenance and service accounts.
- Asset management services - provide asset administration, transfer or asset management services.
- Back-office service providers – provide applications to assist and support the administration and operations activities related to running FT’s business.
- Banking platforms/custodians - providing banking administration, transfer or asset management services.
- Business contact database administrators - provide services or maintain business contact databases, and systems processing business contact information.
- Couriers/postage services- provide courier services/ mailing/ postage/ delivery services.
- Courts/police, regulators & tax authorities- information may be shared with competent third-party authorities (government or regulatory bodies) where requested, required by law, or where we consider it necessary.
- Document archive, storage, and destruction suppliers – offsite document archive and storage services.
- Events management providers - provide services to plan, organise and facilitate events (in person or online, such as webinars).
- IT systems suppliers - provide technical services specifically for IT systems.
- Parties representing an account holder or investor - Third parties representing an account holder or investor, e.g. in response to a legal process.
- Other professional or business services - such as translations services, training solutions, other ad hoc business services.
- Print services suppliers - provide technical services specifically for print services.
- Professional advisors, i.e. auditors and lawyers - Third parties who provide professional and/or legal services to Franklin Templeton group companies.
- Property manager – Third parties providing property level services and/or facilities management to the Properties.
- Security – provide services to monitor FT’s physical premises.