This Privacy Notice for California Residents supplements the information contained in any other Privacy Statement or Notice provided by Schroders Investment Management North America, Inc. and its affiliates (“Schroders”, the “company”, “we”, “our” or “us”) and applies solely to residents of the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended, and any terms defined in the CCPA have the same meaning when used in this notice.
Please note that certain exemptions apply to your rights and Schroders obligations pursuant to the CCPA. These rights and requirements may not apply in certain situations depending on your relationship with Schroders’ other legal obligations, and as otherwise provided for in the CCPA.
Schroders reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date.
I. Information that we collect
We may collect nonpublic personal information about you when you communicate or transact business with us or with our service providers in writing, electronically or by telephone. For example, we collect nonpublic personal information (such as name, address, online identifiers, Internet Protocol addresses, e-mail addresses, account and other similar identifying information) about you from the following sources:
- Applications or forms completed by you
- Information you provide during telephone conversations, email, website visits or contact forms that you send us; and
- Your transactions and account positions with us, our affiliates or others (including, for example, your own broker or custodian).
We have collected the following categories of personal information from consumers within the last twelve (12) months:
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
B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e) )
A 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, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories
C. Protected classification characteristics under federal law or California law as applicable
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)
D. Commercial information
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric Information
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data
F. Internet or other similar network activity
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement
G. Geolocation data
Physical location or movements
H. Sensory Data
Audio, electronic, visual, thermal, olfactory, or similar information
I. Professional or employment-related information
Current or past job history or performance evaluations
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99))
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records
K. Inferences drawn from other personal information
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
II. Information that we disclose and purpose for collection
Schroders does not sell or rent your nonpublic personal information to any third parties. We have not sold personal information in the preceding twelve (12) months. To the extent that Schroders ever changed its policy and chose to sell personal information, you would have the right to opt-out of the sale of your personal information.
We may disclose your nonpublic personal information to third parties in the following limited circumstances:
- We may disclose some or all of your nonpublic personal information to companies that help us maintain, process or service your transactions or account(s) or financial products or services effected by or through us, including companies that perform administrative, accounting, transfer agency, custodial, brokerage or proxy solicitation services for us.
- We may disclose some or all of your nonpublic personal information, such as account and transaction data, to companies that assist us in marketing or client servicing. These companies will use this information only for the services for which we hired them, are not permitted to use or share this information for any other purpose and are required to protect the confidentiality and security of this information.
- We may disclose or report some or all of your nonpublic personal information if you request or authorize us to do so, for institutional risk control, or in other circumstances where we believe in good faith that disclosure is required or permitted under law.
We collect information from you for the following purposes:
- To maintain, process, or service your transactions or account(s) or to provide financial products or services including administrative, accounting, transfer agency, custodial, brokerage or proxy solicitation.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing.
- To improve our website and present its contents to you.
- For marketing or client servicing.
- For testing, research, analysis and product development.
- For institutional risk control purposes as necessary or appropriate to product the rights, property or safety of us, our clients or others.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, assignment, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
- As described to you when collecting your personal information, or as otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.
III. Our security procedures
We maintain physical, electronic and procedural safeguards that comply with federal standards to protect your nonpublic personal information. Within Schroders, access to such information is limited to those employees who need it to perform their jobs, such as servicing your accounts, resolving problems or informing you of new products or services. Finally, our Code of Ethics, which applies to all employees, restricts the use of customer information and requires that it be held in strict confidence.
We observe these policies with respect to current and former Schroders customers and shareholders.
If you identify any inaccuracy in your personal information or you need to make a change to that information, please contact us in writing so that we may promptly update our records.
In certain jurisdictions, you may have additional rights, including:
I. The right to request that we delete personal information that we hold on you other than what we are required by law to retain. We will ensure that our service providers also delete any information covered by your request. At times it may not be possible for us to honor your request and we will notify you if this occurs.
II. The right to request details of the sale or commercial use of your personal information and the right to opt out of the sale of your personal information, if applicable. Please note that we do not sell your personal information.
III. The right to equal service and price, even if you exercise your privacy rights.
IV. The right to request details of the types of personal information we saved on you. Should you have such a request you may contact:
|Schroders Privacy Officer|
7 Bryant Park,
New York, NY 10018 USA
Email address: firstname.lastname@example.org
We will provide you with information about our use of your personal in response to your request. Once we’ve confirmed your identity, we will forward your information by mail or electronically.