This Privacy Notice explains how PineBridge entities or PineBridge related funds and/or collective investment schemes (each a “Data Controller”) ma collect, use and disclose your personal data, and your rights in relation to the personal data they hold. 

In this Privacy Notice, “us”, “we” and “our” refers to the relevant Data Controller.

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.

If you are a Data Subject for the purposes of the Dubai International Financial Centre (“DIFC”) Law No.5, Data Protection Law (“DIFC DPL”), please also refer to the Country Specific Addendum for the DIFC set out at the Exhibit to this Privacy Notice.

YOUR RIGHTS

Under local privacy regulations (as applicable), including but not limited to the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) the UK version of the GDPR (“UK GDPR”), 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. privacyofficer@pinebridge.com

HOW WE COLLECT YOUR DATA

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

• When you provide any information in order to subscribe for any interests in a PineBridge related product, fund or collective investment scheme;
• 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 THE DATA WE COLLECT

We collect personal information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or device (“Personal Data”). In particular, we may collect the following categories of Personal Data from you:

• Identifiers: 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, financial information and sensitive personal data (to the extent that you volunteered such information).
• 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.

Personal Data does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.

THE BASIS FOR PROCESSING YOUR DATA AND HOW WE USE THAT DATA

 1. We may process your Personal Data because it is necessary for our legitimate interests including but not limited to: 

• Mitigating business and operational risks.
• Ensuring network and information security.
• Investigating and preventing fraud and other crime.
• Providing our products and services to you.
• Carrying out marketing activities, which are in our or our affiliates’ legitimate business interest.

This may include sharing your Personal Data with the following:

• other companies in PineBridge; and 
• third party service providers as may be necessary.

When evaluating whether legitimate interests can be relied on as a legal basis for the processing activities described above, a balancing test is carried out to ensure that our use of your Personal Data will not be overridden by your interests or fundamental rights and freedoms.

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

3. We may process your Personal Data to perform our contractual obligations to you or to take steps at your request before entering into a contract.  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, including with regard to conducting due diligence.  

5. We may process your Personal Data where you have given consent. You may withdraw your consent at any time.

DISCLOSURE TO THIRD PARTIES

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 PineBridge. In certain circumstances, we may also disclose and/or make your Personal Data available to the 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 sharing your Personal Data for the reasons set out elsewhere in this Privacy Notice, we may need to transfer it to other PineBridge companies located in the European Economic Area, the UK, 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 relevant Data Controller is incorporated.

We may also share your Personal Data with PineBridge companies located in locations including the United States of America, Hong Kong, India, 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 relevant Data Controller is incorporated. However, these companies are subject to our PineBridge-wide data sharing arrangements which offer a common level of protection across PineBridge. To obtain a copy of these contractual safeguards, please contact us at the contact details above.

RETENTION OF YOUR DATA

Your Personal Data may be retained only for so long as is necessary for the purposes for which the Personal Data is collected and afterwards in accordance with the relevant Data Controller’s legal and regulatory obligations.

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 OUR PRIVACY NOTICE

From time to time, we may change our policy on how we handle personal information or the types of personal information that we hold. Any changes to our policy will be published on our website.

You may obtain a copy of our current policy from our website or by contacting us at the contact details above.