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.
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.
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.
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.
You may contact us to:-
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.
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.
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.
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.
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.
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.
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.
This Policy applies solely to online information collection and use practices in connection with the Website.
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.
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
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:
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:
The Categories of Data We Collect
We may collect the following categories of data about you:
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.
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:
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.
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:
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:
Personal information does not include:
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
These uses may include sharing your personal data with the following:
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:
We disclose personal information for a business purpose to the following categories of third parties:
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:
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:
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:
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:
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