General Data Protection Regulation (GDPR) & UK GDPR

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Legacy PineBridge Investments “General Data Protection Regulation (GDPR) & UK GDPR”

Last Updated: March 2024

Privacy Notice

This Privacy Notice explains how PineBridge collects, uses, discloses and otherwise processes your personal data (i.e., information which directly or indirectly identifies you), and your rights in relation to such personal data.

In this Privacy Notice, “us”, “we” and “our” refers to the following PineBridge entities: PineBridge Investments Ireland Limited (and the Dutch and Swedish branch offices), PineBridge Benson Elliot LLP, PineBridge Investments Europe Limited, and PineBridge Investments Deutschland GmbH (together for purposes of this Privacy Notice, the “Company”).

The PineBridge group includes the Company as well as its affiliates (for purposes of this Privacy Notice, the “Group”).

Scope of Privacy Notice

This Privacy Notice applies to personal data we collect about individuals:

  • who visit our websites;
  • who visit our offices;
  • who are employed or otherwise engaged by our service providers / professional advisors;
  • with whom we have a contact for business-related purposes; and
  • with whom we deal with in connection with (potential) transactions.

This Privacy Notice does not apply to personal data we collect about job applicants or our employees and/or personal data collected by any third party, including through any application or content (including advertising) that may link to or be available from our websites.

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.

This Privacy Notice should be read together with any additional notice that we may provide to you when we collect or otherwise process your personal data.

Your Rights

You have the following rights in relation to the personal data we process about you, which may be subject to limitations or restrictions:

  • To obtain access to, and copies of, the personal data that we hold about you;
  • To object to the processing of your personal data;
  • To require us to erase your personal data;
  • To require us to restrict our data processing activities;
  • To request the transfer of your personal data you provided to us, in a structured, commonly used and machine readable format, to another controller; and
  • To require us to correct the personal data we hold about you if it is incorrect.

If you wish to exercise any of the rights set out above, please contact our privacy officer via email:privacyofficer@pinebridge.com.

You also have the right to lodge a complaint with the competent data protection authority in your jurisdiction.

The Categories of Personal Data We Collect and Why

Individuals who visit our websites:

  • Personal data processed: name, contact details, other personal data voluntarily disclosed to us in your communications with us. Please see also the Cookies Policy.
  • Legal Basis for processing: it is in our legitimate interest to process  such data in order to respond to your queries, complaints or other  communications.
  • Sources  of personal data: we will collect the above personal data  directly from you. We may also process your personal data for other purposes as detailed in the sub-section titled “Other Processing” below.
Individuals who visit our offices:
  • Personal data processed: name, contact details, company information, video images from CCTV, other personal data voluntarily disclosed to us in your communications with us.
  • Legal Basis for processing: it is in our legitimate interest to process such data in order to keep our offices secure.
  • Sources of personal data: we will collect the above personal data directly from you or from the company with which you are affiliated (e.g., your employer). We may also process your personal data for other purposes as detailed in the sub-section titled “Other Processing” below.

Individuals who are employed or engaged by our service providers or professional advisors:

  • Personal data processed: name, contact details, job title, company information, ID, other personal data voluntarily disclosed to us in your communications with us.
  • Legal Basis for processing: it is in our legitimate interest to process such data in order to: (i) arrange calls / meetings with you or others at your company; (ii) conduct our business; and (iii) manage our relationships with service providers and professional advisors (e.g., record-keeping). The processing may also be necessary to perform, or to enter into, contracts with you.
  • Sources of personal data: we will collect the above personal data directly from you or from the company with which you are affiliated (e.g., your employer). We may also process your personal data for other purposes as detailed in the sub-section titled “Other Processing” below.

Individuals with whom we have contact for business-related purposes:

  • Personal data processed: name, contact details, job title, company information, ID, photographs, other personal data voluntarily disclosed to us in your communications with us.
  • Legal Basis for processing: it is in our legitimate interest to process such data in order to: (i) arrange calls / meetings with you or others at your company; (ii) conduct our business; and (iii) maintain a directory of contacts. 
  • Sources of personal data: we will collect the above personal data directly from you or from the company with which you are affiliated (e.g., your employer). We may also process your personal data for other purposes as detailed in the sub-section titled “Other Processing” below.

Individuals we deal with in connection with (potential) transactions:

  • Personal data processed: name, contact details, job title, company information, ID, photographs, log-in information (e.g., for virtual data rooms), results of due diligence undertaken, professional opinions, information relating to financial status and dealings, results of anti-money laundering or KYC checks, other personal data voluntarily disclosed to us in your communications with us. We may also process data concerning your criminal convictions or offences if this is revealed to us when we perform anti-money laundering or KYC.
  • Legal Basis for processing: it is in our legitimate interest to process such data in order to: (i) arrange calls / meetings with you or others at your company; (ii) conduct our business; and (iii) evaluate, complete and administer transactions – including, seeking advice from professional advisors; (iv) undertake statistical analysis, transaction reporting and
    market research; and (v) maintain records of investments. Additional processing may be necessary to comply with our legal obligations, including anti-money laundering and KYC.
  • Sources of personal data: we will collect the above personal data directly from you or from the company with which you are affiliated (e.g., your employer). With respect to data concerning your criminal convictions or offences, we may obtain this data from third party sources (for example, disclosure and barring check databases). We may also process your personal data for other purposes as detailed in the sub-section titled “Other Processing” below.

Other Processing: For what other Purposes do we Process your Personal Data?

All of the abovementioned personal data may be processed in reliance on our legitimate interests or otherwise to comply with our legal and regulatory obligations for the following purposes:

  • identify and prevent fraud and other unlawful activity
  • keep our information and systems secure, and other IT support and development
  • train our personnel
  • seek and obtain advice from professional advisors
  • prepare for, respond to, and obtain advice in connection with, enquiries,
  • investigations, disputes or claims / proceedings
  • organising events and meetings
  • financial and statistical research
  • maintaining records and accounts
  • prepare for, and participate in, transactions
  • internal reporting
  • responding to data subject requests

Consequences of not Providing Personal Data and Right to Object

Where we require your personal data to comply our legal or contractual requirements, failure to provide this information means we may not be able to provide services to you and/or interact with you.

You have a right to object to the processing of your personal data where that processing is carried out for our legitimate interests. Please note however that we may not be able to fulfil this request in all instances.

With Whom Do We Share Personal Data? 

We only transfer your personal data or make it accessible to third parties insofar as these third parties need said personal data to carry out their tasks.

Your personal data may be shared with other companies within our Group.

In certain circumstances, we may also disclose and/or make your personal data(including, where applicable, certain sensitive data such as your biometric data) available tothe following categories of third parties:

  • service providers, for example IT companies that provide or have access to our IT systems, external storage space providers or outsourcing partners, as well as providers of security devices
  • business associates (for example, investors, lenders or financial intermediaries) who are involved in, or considering becoming involved in, transactions in which we are involved
  • professional advisors (e.g., accountants, auditors, lawyers or other consultants)
  •  regulators, courts and other governmental agencies
  • third parties that are considering acquiring or that acquire all or part of our assets or stock, or that succeed us in carrying on all or part of our business or services provided to or by us

International Transfers of Personal Data

In principle, the Company processes and stores personal data in countries located within the EEA, UK and Switzerland. However, in sharing your personal data for the reasons set out elsewhere in this Privacy Notice, we may need to transfer it to recipients located in countries outside of the EEA, UK and Switzerland, including the United States of America, Hong Kong, Japan and India, whose legal framework does not guarantee a level of protection equivalent to that of the jurisdictions in which the Company is incorporated.

Your personal data will only be transferred from the EEA, Switzerland or the UK to a recipient in a country that is not considered to provide an adequate level of data protection if the transfer is in compliance with applicable data protection and privacy laws. In such cases, we ensure adequate protection by using sufficient safeguards, for example by entering into standard contractual clauses (“SCCs”) with the recipient or by relying on the recipient’s Binding Corporate Rules. We may also rely on exceptional legal authorisations in certain cases, for example by obtaining your express consent to a specific communication, notably where the transfer is necessary for performance of a contract or the establishment or defence of legal claims. For intra-Group transfers, we rely on our Group-wide data sharing arrangements, which offer a common level of protection across the Group.

You can request further information in relation to international transfers and/or request a copy of SCCs entered into by us as well as of our Group's data sharing arrangements by contacting our privacy officer at any time via email: privacyofficer@pinebridge.com

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 is collected and afterwards in accordance with the Company’s legal and regulatory obligations, including but not limited to the Company’s record retention policy, which is available upon request from our privacy officer (privacyofficer@pinebridge.com). To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We also consider the applicable legal requirements and the extent to which it is necessary to process the personal data. In exceptional cases (e.g., in pending litigation matters or where the law requires us to) your personal data may need to be kept for longer periods of time.

Changes to the Privacy Notice

We will review and update this Privacy Notice as required to keep current with rules and regulations, new technologies and security standards. We will post those changes on our websites or update the “last updated” date of the Privacy Notice. If we make a material change to this Privacy Notice, you will be provided with appropriate notice in accordance with applicable legal requirements. Only the latest version currently published on our websites is binding.

Contact us

For any privacy issues, questions or complaints concerning the application of this Privacy Notice or to exercise your rights as described above, you may contact our privacy officer via email: privacyofficer@pinebridge.com.