We invest across all asset classes worldwide, with a strong track record of innovation and client support.
We aim to work closely with the media wherever we can - sharing our views, comment and insight on investment and industry issues.
BMO Financial Group appreciates the
opportunity to help you meet your financial needs. From the day Bank of
Montreal was founded in 1817, earning and keeping your trust has been at the
very core of our business. We are committed to respecting and protecting your Personal
Data. It is important for you to
understand what Personal Data we will collect, how we will use it and who may
This Privacy Code applies to the BMO
Financial Group operations that take place in Europe. Data protection contact
details of these companies can be found Contact Us. Defined terms are listed in
This Privacy Code outlines our
commitment to you and incorporates the following 10 key privacy principles:
We have strict
policies and procedures governing how we deal with your Personal Data. Every
employee is responsible for respecting and protecting the Personal Data that they
have access to.
Protection Officer oversees how we deal with your Personal Data. Please see Contact us for information
on how to reach our Data Protection Officer.
When we collect
your Personal Data, we may use or disclose it for the following purposes. Below each purpose,
we note the lawful basis that allows that use of your Personal Data. There is
often more than one lawful basis for each purpose. Annex B provides further
detail on the scope of the lawful bases.
Lawful bases: contract performance; consent; legitimate interests
(to enable us to perform our obligations owed to you)
Lawful bases: legal obligation; contract performance; legitimate
interests (to ensure that you fall within our acceptable risk profile and to
assist with the prevention of crime and fraud); public interest
Lawful bases: legal obligations; legal claims; legitimate interests (to cooperate with
law enforcement and regulatory authorities); public interest
Lawful bases: legitimate interests (to provide you with opportunities that may be of
Lawful basis: legitimate interests (to ensure the quality and legality of our services,
to allow us to improve our services and to enable us to offer content and
services via a wider range of channels)
Lawful basis: legitimate interests (in order to allow us to change our business)
To respond to any questions you may
have ► we may be required to process your Personal Data to conduct, and keep a
record of, our correspondence with you.
Lawful basis: legitimate interests (to respond to
queries and deliver our products and services)
We may monitor calls and transactions to ensure service quality, to comply with law and regulation and our internal procedures and to combat fraud and other criminal activity.
If a new purpose for using your Personal Data develops, we will update this policy to identify that purpose.
Some of our processing is permitted by legal bases other than consent (see section 2 above). in relation to Direct Marketing, where we must do
so, we will obtain your consent before using your Personal Data for this
purpose. If you do not want to receive our Direct Marketing communications
and/or do not want your Personal Data shared among relevant members of BMO
Financial Group in Europe for the purpose of marketing, you can have your name
deleted from our Direct Marketing and/or shared information lists. If you want to
change your privacy preferences, please contact the BMO Financial Group
company that you do business with or using the unsubscribe link provided in any
of our electronic marketing communications.
In relation to the
processing of criminal convictions data and politically exposed persons’ Personal
Data to the extent another legal basis cannot be applied, we rely on your
consent. Such consent is necessary for us to provide our services; if you
withdraw this consent, we may have to stop providing certain services to you.
We only collect
the Personal Data that we determine we need for one (or more) of the purposes set out in Principle
For example, we may collect:
We will only use or
disclose your Personal Data for the purpose(s) it was collected for and as
otherwise identified in this Privacy Code.
Sharing outside the BMO Financial Group: Personal
Data may be provided to third parties, including regulatory or law enforcement
authorities, court services, and anti-fraud organisations:
cases of suspected criminal activity or contravention of law
detect and prevent fraud
required to satisfy the legal or regulatory requirements such as a court order.
by law, we can give you details of any such third party disclosures upon
Sharing within the BMO Financial Group: we may share your Personal Data within
the BMO Financial Group, including locations outside of the European Economic
Area (EEA) for marketing purposes, for legal and regulatory purposes, to manage
business risks, to perform analytics, to ensure we have correct or up-to-date
information about you (such as your current address or date of birth) and to
better manage your relationship with us.
Business sale or re-organisation: over time, we may buy new business or sell some of our business. Personal data associated with any accounts, products or services of the business being sold will be reviewed as part of the due diligence process and subsequently transferred as a business asset to the new business owner. We may also transfer Personal Data as part of a corporate re-organisation or other change in corporate control.
Sub-contractors and agents: we may
use affiliates or other companies to provide services on our behalf or to
enable us to offer and provide our products and services to you, such as data
processing, account administration, fraud prevention and detection, analytics
and marketing. We will only give these companies
the Personal Data needed to perform those services. We do not authorise them to use or disclose your
Personal Data for their own marketing or other purposes. We have contracts that
hold these companies to the same standards of confidentiality and information
security that govern us.
Transfers outside the EEA: your
Personal Data may be accessed by staff or suppliers in, transferred to, and/or
stored in a country outside the EEA, in which data protection laws may be of a
lower standard than within the EEA. Regardless of location, we will impose the
same data protection safeguards that we use inside the EEA.
Certain countries outside the EEA have
been approved by the European Commission as providing essentially equivalent
protections to EEA data protection laws (see the full list here) and therefore no
additional safeguards are required to export Personal Data to these
jurisdictions. In countries which have not been approved, we will
establish a legal basis to justify transferring Personal Information, such as
contractual terms approved by the European Commission that impose equivalent
data protection obligations directly on the recipient.
Please Contact Us if you would like to see a copy of the specific
safeguards applied to the export of your Personal Data.
We are committed to keeping your Personal Data accurate, complete and up-to-date. If you discover inaccuracies in our records, or your Personal Data changes, please notify the BMO Financial Group company that you do business with immediately so that we can make the necessary changes. Failure to notify us of changes to your Personal Data may negatively impact the way we communicate or provide services to you. Where appropriate, we will advise others of any material amendments to your Personal Data that we may have released to them. If we do not agree to make your requested amendments, you may challenge our decision as described in Contact Us.
We use an extensive range of safeguards to protect your Personal Data.
We have agreements and controls in place with third party service providers requiring them to safeguard any Personal Data we provide to them and use the Personal Data only for the purpose of providing the service we have requested them to perform.
From time to time, we may make changes to this Privacy Code. Where we have your email address, we may email you if the changes are material. Otherwise, we will not. We therefore recommend that you check the Code from time to time.
This Privacy Code at http://www.bmogam.com or http://www.bmorep.com (as applicable) is always the most recent version.
Please see Contact Us to answer any questions you may have about our Privacy Code.
The BMO Financial
Group company that you correspond with will usually determine the purpose of processing
your Personal Data and the way in which it is processed. Sometimes the company
will do it jointly with others, depending on the products and services you use.
Data protection contact details of these companies can be found in the Contact Us section.
Personal Data must be processed in line with
your rights as a Data Protection Officer. In the EU, Data Subjects generally have the rights
listed below. However, these are subject to certain exceptions and variations
in different EU member states. If in doubt, please contact the Data Protection Officer
Data Subjects can:
Subject access: be provided access
to a copy of any Personal Data held about them.
Rectification: require inaccurate
Personal Information be amended.
Erasure: require erasure of Personal Data in certain circumstances.
Where the data has been disclosed to third parties for processing, Data
Subjects can require us to take reasonable steps to inform them that they have
requested its erasure of any links to copies of or replication of it.
consent: withdraw any consent to processing that they have given us and prevent
further processing if there is no other ground under which we can process their Personal Data.
Restriction: require certain
Personal Data to be marked as restricted while complaints are resolved, and
also restrict processing in certain other circumstances.
Portability: have their Personal
Data transmitted in a commonly used machine-readable format to them or another company
the purposes and means for which Personal Data is processed.
Prevent processing: require us to
stop any Personal Data processing based on the legitimate interests ground,
unless our reasons for undertaking that processing outweigh any prejudice to their
data protection rights.
Marketing: require us to prevent processing (including
profiling) of Personal Data for direct marketing purposes.
Your exercise of these rights
is subject to certain exemptions under EU or local law, such as exemptions to
safeguard the public interest (e.g. the prevention or detection of crime) and
our interests (e.g. the maintenance of legal privilege). If you exercise any of
these rights, we will check your entitlement and will aim to respond within a
If you are not satisfied with
our use of your personal information or our response to any exercise of these
rights, you can complain to the relevant Data Protection Regulator.
If your complaint remains unresolved after speaking to a representative of the BMO Financial Group entity that you deal with, please contact the Data Protection Officer at:
Office of the Data Protection Officer
95 Queen Victoria Street
London, EC4V 4HG.
If, after contacting us, you do not feel that we have adequately addressed your concerns, please contact the Data Protection Regulator in the country where the BMO Financial Group entity that you deal with is established, as set out in the chart above.
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The cookies that we use on our website can be categorised into the
By using our website, you agree that we can place these types of cookies
from us and third parties (such as Google Analytics, Hotjar and Flashtalking)
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Amending cookie preferences
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them. The instructions for removing cookies from your computer or mobile device
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could impair its functionality.
Click here for further
information about cookies in general and instructions for managing cookies on
many commonly used browsers. Alternatively, you can consult your browser
provider for such instructions.
Our emails may contain a single, campaign-unique “web beacon pixel” to tell
us whether our emails are opened and, combined with other technology, verify
any clicks through to links within the email. We may use this information for
determining which of our emails are more interesting to you and to query
whether users who do not open our emails wish to continue receiving them. The
pixel will be deleted when you delete the email. If you do not wish the pixel
to be downloaded to your device, please select to receive emails from us in
plain text rather than HTML, choose not to click links that we send you, or
unsubscribe from the receipt of our emails. This information may be connected
to your personal identity.
If you have any questions or concerns about our privacy practices, the privacy of your Personal Data or you want to change your privacy preferences, please let us know.
The company that you correspond with or do business with will usually be the data controller in respect of your Personal Data and can answer any questions you may have about our Privacy Code or our use of your Personal Data. If your concerns are not resolved, please contact:
BMO Financial Group business
Business Unit Contact
Data Protection Regulator Contact
BMO Global Asset Management
F&C Management Ltd
F&C Managers Ltd
F&C Asset Managers Ltd
Client Services+44(0)20 7011 4444
Information Commissioner’s Office0303 123 1113
Rogier Van Harten+31 20 582 3795
Austrian Data Protection AuthorityE-Mail: firstname.lastname@example.org
Commission for the Protection of Privacy+32 (0)2 274 48 00
Robert Elfström+46 (0) 856646501
Data Protection Ombudsman+358 29 56 66700
Jean Michel Bongiorno+44 207 011 5233
Commission Nationale de l'Informatique et des Libertés+33 (0)188.8.131.52.22
Elmar Rathmayr+49 69 22228 3613
The Hessian Data Protection Officer
PO Box 3163
+49 611 1408 – 0
State Street Fund Services (Ireland) Limited+353 1 242 5529
Office of the Data Protection Commissioner+353 (0761) 104 800
Giampaolo Giannelli+39 020068 1619
Italian data protection authority+39-06-6967 71
State Street Bank Luxembourg S.A+352 46 40 10 7460
National Commission for Data Protection(+352) 26 10 60 - 1
Data Protection Authority
Luis Martin-Hoyos+34 91 419 89 01
Spanish Data Protection Agency (AEPD)Spanish Agency for Data ProtectionC / Jorge Juan, 628001-Madrid
Data Inspection Board (DIB)+46 8 657 61 00
Rochus Appert+41 44 488 1951
Federal Data Protection and Information Commissioner (FDPIC)+41 (0) 58 462 43 95
F&C Portugal S.A.
Joao Santos+351 21 003 3220
Comissão Nacional de Protecção de Dados (CNPD)(+ 351) 21 392 84 00
F&C Netherlands B.V.
Marco Mante de Vreede+31 20 582 3074
The Dutch Data Protection Authority0900 200 12 01
Thames River Capital LLP
Thames River Multi-Capital
Business Unit Compliance Officer email@example.com
+44 (0) 20 7495 4641
Information Commissioner’s Office
0303 123 1113
BMO Real Estate Partners
+44 207 499 2244
+49 (0) 89 614 651 - 11
The Bavarian State Commissioner for Data Protection (BayLfD)0981 / 53-1300
+33 01 70395992/+33 01 70395993
BMO Real Estate Partnersenquiries@bmorep.com
Gibraltar Regulatory Authority(+350) 20074636
BMO Financial Group means Bank of Montreal and all of its subsidiaries
Data Subject the person to whom the Personal Data relates. A BMO Financial Group entity established in the EEA determines the purposes and means for which this person’s Personal Data is processed.
Direct Marketing is our communication with you such as mail, telemarketing or email, using your contact information, to inform you about products and services that we think may be of interest and value to you. This does not include communications regarding products or services that you currently have, including improved ways to use the products, or additional features of the products as well as transactional information.
EEA means the European Economic Union
Personal Data is any information relating to an identified or identifiable Data Subject, i.e. one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual. For the purposes of this Privacy Code, Personal Data is that which a BMO Financial Group entity established in the EEA processes.
Please find below a description of the
various legal bases that we rely upon to justify our processing of your Personal
Data, with a description of each basis.
You have given your explicit consent
to the processing of those Personal Information for one or more specified
You are free to withdraw your consent, by
visiting Contact Us. Where you do so, we may be unable to provide a service
that requires the use of such Personal Information.
By using the site you are accepting this policy.