Website Privacy Statements

Privacy Policy
General Data Protection Regulation (GDPR)
CCPA Privacy Notice

Privacy Policy

AS USED HEREIN, THE TERMS “YOU” AND “USER” SHALL MEAN ANY VISITOR TO PINEBRIDGE INTERNET WEBSITES.

PineBridge recognizes the importance of protecting your non-public information when you visit https://www.pinebridge.com/ or its regional websites (individually and collectively, the “Website”). This Privacy Policy (“Policy“) applies to the collection, use, disclosure and protection of personal data, relating to customers of PineBridge Investments LLC and its subsidiaries and related entities (collectively, “PineBridge”) through its Website. By visiting the Website, you are accepting the practices described in this Policy. If you do not agree to this Policy, please refrain from using the Website. Additionally, certain terms and conditions applicable to your use of the Website can be found under the Website Terms of Use link. Regional disclosures that may apply per jurisdiction can be found under the privacy policy link on the PineBridge website designed for that region.

“Personal Data” means information pertaining to specific individuals, or by which specific individuals can be identified, including by name, identification number, address, or other personal characteristics or attributes. Personal Data does not include aggregated statistics, compilations, anonymous data, or other derivative data that does not, alone or with other data, identify a specific individual.

“Data Subject” means an individual who is the subject of personal data.

Changes to this Policy

PineBridge reserves the right to change, modify, add or remove portions of this Policy at any time and for any reason. Such changes will become effective upon posting. We suggest that you review this policy periodically for changes. You will be able to determine when this Policy has been revised by checking the Last Revised legend at the top of this Policy. You acknowledge that by accessing our Website after changes have been posted to this Policy, you are agreeing to the terms of the Policy as modified.

Basic Principle

PineBridge will not collect or maintain Personal Data that is not relevant to or required for the conduct of PineBridge business and will take reasonable steps to assure that Personal Data remains accurate.

Personal Data will be treated as confidential and internal procedures and controls will be employed to prevent unauthorized access, disclosure, use, copying, modification, or destruction. Personal Data maintained by PineBridge will not be used for purposes that are incompatible with the purposes for which it was collected. Personal Data will not be transferred to third parties, except as required for the conduct of PineBridge business, and only to third parties who have agreed in writing to protect such Personal Data.

Information Collected

PineBridge may collect personal information about you (such as your name, title, address, email address and telephone number) that you provide voluntarily. For instance, if you choose to contact us through our “contact us“ feature, we will collect your personal information so that we can respond to your inquiry.

Your Rights

You may contact us to:-

  • Request that we amend, rectify, delete or update the personal data we hold about you;
  • Where possible (e.g., in relation to marketing) amend or update your choices around processing; and
  • Request a copy of personal data held by us.

Where you would like to receive a copy of all personal data held, such request should be in writing (email or post), addressed to our Global Privacy Officer at privacyofficer@pinebridge.com and should contain as much information as possible to facilitate our dealing with this request.

Disclosure to Third Parties

Except as provided herein, PineBridge will not intentionally sell, share or rent your personally identifiable information to others in contravention of this Policy. We may share personally identifiable information provided through the Website with companies that are controlled, owned or operated by PineBridge or its subsidiaries and affiliates. Your information will not be disclosed for marketing purposes without your consent.

PineBridge may employ other companies and individuals to perform functions on our behalf including operating certain features of the Website, or hosting/maintaining servers used in connection with the Website. These companies and individuals have agreed, and are not permitted, to use your personally identifiable information for any other purpose.

PineBridge may disclose aggregate data about its Website and its visitors, provided however that PineBridge will not disclose to third parties any information that could be used to identify you personally.

Security of Your Personal Information

No data transmission over the internet can be 100% secure, as such PineBridge cannot ensure or warrant the security of any information you submit to through the Website. However, PineBridge takes measures to prevent unauthorized intrusion to the Website and the alteration, acquisition or misuse of personally identifiable information by unauthorized persons. PineBridge restricts access to non-public information about you to those employees who need to know the information in order to provide products or services to you. PineBridge maintains physical, electronic, and procedural safeguards that comply with federal standards to guard your non-public personal information. PineBridge strives to keep its records about you accurate and up-to-date. Please contact us by email or telephone as specified below to update your account information whenever such information ceases to be complete or accurate.

Cookies

When you view the Website, certain information may be stored in your computer’s memory and hard drive, in your mobile device or tablet when you visit certain web pages in the form of a small text file called a “cookie“. Cookies are used to enable websites to function or to provide information to the owners of a website, or other third parties that receive data obtained from that website. In general, PineBridge uses cookies to help improve your experience with our Website and understand how and when areas of our Website are visited. Cookies are read only by the server that placed them, and are unable to execute any code or virus. For more information about cookies, how the Website uses them, and your options with respect to Cookie generally, please see the PineBridge Cookies Policy.

Compliance with Laws

PineBridge does not automatically collect personally identifiable information from visitors to our Website, except to the extent required to do so by statute or regulation applicable to us. We will not provide any personally identifiable information to any other persons, except (a) if we are required to make disclosures to the government or private parties in connection with a lawsuit, subpoena, investigation, similar proceedings or regulatory examination, (b) to comply with applicable laws or regulations, (c) to enforce the Terms of Use, (d) to our legal advisors, (e) when PineBridge, in its sole discretion, believe it reasonably necessary to protect the rights, property, safety or security of PineBridge, Website visitors, or the public, or (f) to share information with our affiliates or service providers in connection with providing services to you. We can (and you authorize us to) disclose any such information in those circumstances.

Business Transfers

PineBridge may provide your personally identifiable information concerning Website visitors to a purchaser or successor entity in connection with the sale of PineBridge, a PineBridge subsidiary or line of business.

Third Party Websites

PineBridge may establish links between the Website and websites operated by third parties. PineBridge has no control over any such other websites, the contents therein or the products/services offered. Your access to and use of such linked websites is governed by the terms of use and privacy policies of those sites, and shall be at your own risk. PineBridge disclaims responsibility for the privacy policies and customer information practices of third-party internet websites hyperlinked from our Website. Links on the Website are provided only as a convenience, and the inclusion of such links does not imply endorsement of the linked site.

Offline vs. Online Practices

This Policy applies solely to online information collection and use practices in connection with the Website.

Children’s Privacy

Although this Website is not targeted toward children, we are concerned about the safety and privacy of children who use the Internet. Consistent with the Children’s Online Privacy Protection Act of 1998, we will never knowingly request or collect personally identifiable information from anyone under 13 without prior verifiable parental consent. If we become aware that a child under 13 has provided us with personally identifiable information without verifiable parental consent, we will use our best efforts to remove such information from our files. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without verifiable parental consent, please contact our Global Privacy Officer at privacyofficer@pinebridge.com.

Contact Us

If you have questions or concerns about this Policy or our privacy related practices, collection or use of your information, please contact our Global Privacy Officer at privacyofficer@pinebridge.com.

Last Revised: February 20, 2018

General Data Protection Regulation (GDPR)

Privacy Notice

This Privacy Notice explains how PineBridge (“the Company”) collects, uses and discloses your personal data, and your rights in relation to the personal data it holds.

In this Privacy Notice, “us”, “we” and “our” refers to the Company.

If you are an individual, this will affect you directly. If you are an institution that provides us with personal data on individuals connected to you for any reason, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.

Your Rights

Under the General Data Protection Regulation (EU Regulation 2016/679) (“GDPR”) and if you are a European data subject you have the following rights including:

  • To obtain access to, and copies of, the personal data that we hold about you;
  • To require that we cease processing your personal data if the processing is causing you damage or distress;
  • To require us to erase your personal data;
  • To require us to restrict our data processing activities;
  • To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
  • To require us to correct the personal data we hold about you if it is incorrect.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact our Data Privacy Coordinator via email: privacyofficer@pinebridge.com.

How We Collect Your Data

We may collect your personal data in a number of ways, for example:

  • From information you provide to us when you meet with one of our employees or when we communicate with you by telephone, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
  • When we complete due diligence on you;
  • When we enter into a contract and during the provision of services;
  • From third parties.

The Categories of Data We Collect

We may collect the following categories of data about you:

  • Personal Data (including but not limited to name and contact information); and
  • Sensitive Personal Data (where you volunteer to provide such information to us)

The Basis for Processing Your Data, How We Use That Data and Whom We Share It With

1. We may process your personal data because it is necessary for our legitimate interests.

  • This may include sharing your personal data with the following:
    • other companies in our Group; and
    • third party service providers as may be necessary.
  • This may also include carrying out marketing activities, which are in our or our affiliates’ legitimate business interest.

2. We may also process your data for our compliance with a legal obligation which we are under.

3. To perform our contractual obligations to you. This may also entail sharing your personal data with companies, which assist us in performing our contractual obligations.

4. We may use your personal data to meet our regulatory obligations, with regard to conducting due diligence. In this respect, we may share your personal data with the following:

  • Our auditors where it is necessary as part of their auditing functions;
  • With relevant regulators where we are required to do so; and
  • third party service providers as may be necessary.

In sharing your personal data for the reasons set out elsewhere in this Privacy Notice, we may need to transfer it to other Group companies located in the European Economic Area as well as Switzerland, which are countries, which provide the same or a similarly adequate level of protection for your personal data as is provided within the jurisdiction in which the Company is incorporated. We may also share your personal data with Group companies located in locations including the United States of America, Hong Kong, and Japan, which do not have laws which provide the same level of protection to your personal data as are provided within the jurisdiction in which the Company is incorporated. However, these companies are subject to our Group-wide data sharing arrangements which offer a common level of protection across the Group.

Retention of Your Data

We may retain your personal data only for so long as is necessary for the purposes for which the personal data in collected and afterwards in accordance with the Company’s legal and regulatory obligations, including but not limited to the Company’s record retention policy.

CCPA Privacy Notice

This CCPA Privacy Notice for California Residents supplements the information contained in the Privacy Policy of PineBridge (“us”, “we” and “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumer” or “you”). We have adopted this disclosure to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

If you are an individual, this will affect you directly. If you are an institution that provides us with personal data on individuals connected to you for any reason, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.

How We Collect Your Data
We may collect your personal data in a number of ways, for example:

  • From information you provide to us when you meet with one of our employees or when we communicate with you by telephone, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
  • When we complete due diligence on you;
  • When we enter into a contract and during the provision of services; and
  • From third parties.

The Categories of Data We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

  • Identifiers: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
  • Information in Customer Records: name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, and financial information.
  • Internet or other similar network activity: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
  • Enquiry Data: Information contained in any enquiry you submit to us regarding our services.
  • Correspondence Data: Information contained in or relating to any communication that you send to us.
  • Sensory data: Audio and visual data recorded at our physical offices and locations.
  • Professional or employment-related information.
  • Education information.

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA's scope.

Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the information and to perform our contractual obligations to you. This may also entail sharing your personal information with companies, which assist us in performing our contractual obligations.
  • Processing for our compliance with a legal obligation which we are under, including to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To meet our regulatory obligations, with regard to conducting due diligence (including complying with anti-money laundering or know your customer laws and regulations). In this respect, we may share your personal data with the following:
    • Our auditors where it is necessary as part of their auditing functions;
    • with relevant regulators where we are required to do so; and
    • third party service providers as may be necessary.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

These uses may include sharing your personal data with the following:

  • Other companies in our Group (our affiliates)
  • Third party service providers as may be necessary which may include carrying out marketing activities, which are in our or our affiliates’ legitimate business interest

When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

  • Identifiers
  • Information in Customer Records
  • Internet or other similar network activity
  • Enquiry Data
  • Correspondence Data
  • Professional or employment-related information
  • Education information

We disclose personal information for a business purpose to the following categories of third parties:

  • Our affiliates
  • Service providers
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you

In the preceding twelve (12) months, we have not sold any personal information. Likewise, we do not have any future plans to sell personal information. However, we respect and understand that you may still want to ensure your personal information is not sold. Therefore, you may make a “do not sell my data” request on our DO NOT SELL MY DATA page.

Your Rights and Choices
The CCPA provides Consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists:
    • Personal Information Sold: identifying the personal information categories that each category of recipient purchased; and
    • Personal Information Disclosed for a Business Purpose: identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  • We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website.

Contact Information
If you have any questions or comments about this notice, our Privacy Notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-833-595-0805

Email: privacyofficer@pinebridge.com

Postal Address:

Privacy Officer
PineBridge Investments
65 East 55th Street, 6th Floor
New York, NY 10022

Last Revised: May 26, 2020