CENTERSQUARE INVESTMENT MANAGEMENT LLC PRIVACY NOTICE
Last updated on: June 12, 2018
1. About this notice
This notice (the "Privacy Notice") provides information about how CenterSquare Investment Management LLC "we", "us", "our") gathers and uses personal information. We are committed to respecting the confidentiality of the personal information you supply to us and all data will be processed in accordance with applicable data privacy laws. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Privacy Notice. By using our website and voluntarily providing your personally identifiable information ("personal data") to us, you consent to the collection and use of such personal data as set forth in this Privacy Notice. If you do not agree with our use of your personal data as set out in this Privacy Notice, you should not submit your personal information to us. However, if you do not wish to submit your personal information, or if you wish to exercise your rights to prevent us using your data, you should be aware that we may not be able to do business with you. For more information on this, please see sections 4.1 and 7.
2. About us
We are a limited liability company organized in the State of Delaware (company number 6481319). For the purposes of EU data privacy legislation, we will be a ‘controller’.
3. Contacting us
Should you have any questions or concerns about this Privacy Notice or the processing of personal data we hold about you, please contact us:
CenterSquare Investment Management LLC, 630 W. Germantown Pike, Suite 300, Plymouth Meeting, PA 19462 Attention: Joseph Law, Chief Compliance Officer
4. Your rights
You have certain rights in relation to your personal data 4.1 Your rights in connection with personal information Under certain circumstances, for example where our processing of your personal is subject to the laws in your jurisdiction, and subject to section 10 below, you have the right to:
- Object to processing of your personal information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are processing it lawfully.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see above).
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party in a machine-readable, commonly used and structured format.
If you want to exercise any of these rights then please contact us using the details at section 3. The various rights are not absolute and each is subject to certain exceptions or qualifications. For example, if you wish to withdraw your consent or object to processing, we may need to discuss with you whether our use of your data needs to continue for other lawful purposes, such as fulfilment of a legal or contractual requirement. We will respond to your request within one month of receipt of your request. In some cases we may not be able to fulfil your request to exercise the right before this date and may need to request more time. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request. 4.2 Your duty to inform us of changes It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us. 4.3 Fees You will not have to pay a fee to access your personal information (or to exercise any of the other rights). In some cases, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, or if you request multiple copies of the information. Alternatively, we may refuse to comply with the request in such circumstances. 4.4 What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it. 4.5 Right to complain If you wish to request further information about any of the above rights, or if you are unhappy with how we have handled your information, please contact us on the contact details contained in section 3. If you are located in the EU and you are not satisfied with our response to your complaint or believe our processing of your information does not comply with EU data protection law, you can make a complaint to your supervisory authority which in the UK is the Information Commissioner’s Office: https://ico.org.uk/global/contact-us/ or 0303 123 1113.
5. Information we collect
We collect your personal information from a variety of sources, as set out in this Privacy Notice. Where necessary we collect information directly from you or indirectly from third parties, and through your use of our website. 5.1 Information you provide to us This section details the information we may collect about you in the course of us providing investment advisory services and otherwise in your interaction and correspondence with us and our representatives. We may collect:
- basic personal details including your name and address (and proof of name and address), email address, telephone number, any other contact details you supply, social security number and other tax details, nationality, citizenship, tax residency, date of birth and family connections;
- details of your company’s directors, shareholders, secretaries, authorised signatories and identification documents;
- banking details;
- information on your assets and/or income and/or financial dealings;
- details of business advisers you employ including wealth managers and independent financial advisers;
- records of all communications including recordings of phone calls and electronic communications with our staff and meeting notes (see below for more details);
- employment and education history (where you send us this information as part of a job application process).
5.2 Information we collect from other sources We may receive information about you from our affiliates and other third parties such as third-party service providers, our vendors and publicly available sources such as LinkedIn. We may collect the following information from third parties:
- basic personal details including your name, address, email address, telephone number and other contact details;
- data received from background checks related to the job application process. This may include criminal record checks and credit history or bankruptcy checks as required for regulatory purposes;
- data received from due diligence activities (such as anti-money laundering, politically exposed persons and sanctions checks);
- fraud inquiries (for example, information from police reports); and
- employment and education history (where we are sent this information by an employment agent).
5.3 Information from your use of our site We collect information about your use of our website and the devices you use. Our website permits you to contact us via email and subscribe to our news, commentaries and whitepapers. Whenever you send us an email via an email link on our website, you will be providing us with your name and email address and any information you choose to include in the text of your message. For example, you may choose to provide your mailing address, phone number or other information necessary or helpful for us to address your query or other concern. If you work for one of our institutional (business) clients, we may obtain from you or your firm your business contact information, such as your name, title, office address, business phone number and e-mail address. We may use this information for the purpose of conducting business with your firm, managing our relationship with your firm, and advising your firm of products and services that we believe might be of interest. We may collect other information including:
- when and how often you access our website;
- the way in which you navigate around it
- how long you spend on particular pages;
- the operating system, hardware, software versions, browser configuration, display size, browser configuration of the devices you use; and
- connection information such as IP addresses (and your general geographic location).
6. How we use the information we collect
6.1 General uses of information The information which we collect and what we use it for will depend on the nature of our business relationship with you. We use your information:
- to provide you with services which you have requested and to fulfil our contractual obligations towards you;
- to fulfil our contractual obligations to third parties to whom you have provided your information;
- for our internal business administration and record keeping purposes;
- to respond to your inquiries submitted through our website;
- for legal and regulatory compliance purposes, including as necessary to respond to governmental, regulatory or law enforcement agency requests;
- where required or considered appropriate, carrying out anti-money laundering (AML) and 'know-your-client' (KYC) checks and other procedures that we undertake prior to you becoming a client of ours and in the course of our ongoing business relationship; and
- for recruitment.
6.2 Information for marketing purposes We may use your information to identify products, services and events that we think may be of interest to you. We will only send you marketing messages where you have consented to such contact, or in the case of products and services, where these are similar to those that we have already provided to you. You have the right to ask us not to not send you marketing messages by post, telephone or e-mail or any combination of these at any time. You can also let us know at any time that you wish to change your mind and to start receiving such messages. You can do this:
- by replying directly to the marketing message;
- in case you wish to withdraw from all marketing communications, you can also unsubscribe from all marketing by clicking the appropriate link in any email you receive; or
- at any time by contacting us (see section 3).
Periodically, we will remind you (possibly along with other communications) that you may unsubscribe if you no longer wish to receive communications from us. If you choose to unsubscribe, we will cease to send you such communications as mentioned above.
7. Our bases for collecting and using the information
We are entitled to use your personal data in the ways set out in this Privacy Notice on the following bases:
- the use of personal data in this way is necessary for the performance of a contract with you for provision of our products and/or services or to take steps at your request prior to entering into such a contract;
- we have legal obligations that we have to discharge;
- the use of your personal data is necessary for our legitimate interests in:
- ensuring the quality of the products and services we provide to you;
- collecting information for marketing purposes;
- communicating with you; and
- statistical analysis;
- you have consented to such use; and/or
- to establish, exercise or defend our legal rights for the purposes of legal proceedings.
- Our website allows you to contact us via email and subscribe to company information including news, commentaries, and whitepapers; whenever you send us an email via an email link on our website, you will be providing us with your name and email address and other information provided by you to us.
- If you work for one of our institutional clients, we may obtain from you or your firm your business contact information and we may use this information of the purpose of conducting business with your firm, managing our relationship with your firm, and advising your firm of products and services that we believe might be of interest.
We may process your sensitive and special categories of information (this includes data concerning your health, personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or data concerning sexual orientation) where we have asked for your explicit consent or otherwise where this is necessary for the establishment, exercise or defence of legal claims If provision of your personal information is a legal or contractual requirement or a requirement necessary to enter into a contract with us, and you choose not to provide it, we may not be able to perform some of the tasks we need to in order to provide certain products or services to you. If you do choose to provide your consent you can withdraw it at any time by contacting us (see section 3).
8. Sharing your information
We will not disclose your personal information to third parties except as detailed in this Privacy Notice. Where necessary, we disclose your personal data to third parties that are specifically engaged by us to provide services to us, in which case we will require those parties to keep that information confidential and secure and to use it solely for the purpose of providing the specified services to us. The following is a list of the types of third parties who process your personal data on our behalf:
- we may share information with third party service providers, including our information technology providers, which we have appointed to process data on our behalf in order to allow us to provide products or services that you have requested;
- for existing employees and for employment applicants we may provide employment information to our third party human resource and payroll administrator who process data;
- we may provide your information to third parties engaged by us to provide services to us including:
- professional advisers, including accountants, auditors, compliance consultants, legal advisers and tax advisers;
- fraud prevention agencies;
- courier companies;
- other information technology providers, including providers of client relationship management systems,
and information security providers; and
- data storage suppliers;
- we may disclose to law enforcement agencies and regulators, government departments or competent authorities of the US, UK or of other countries any personal data (including tax status, identity or residency or other personal and payment information, documents or self-certifications) where we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation, or if we reasonably consider that this is necessary to help prevent or detect fraud or other crime or to protect our rights, property, or safety, or that of our customers or others. Such disclosure may be made directly to such regulators or competent authorities or made indirectly to our advisers or providers who will make such filings or disclosures on our behalf;
- if we are under a duty to disclose or share your information with tax authorities, who may transfer it to the government or the tax authorities in another country where you may be subject to tax. Such disclosure may be made directly to such regulators or competent authorities or made indirectly to our advisers or providers who will make such filings or disclosures on our behalf;
- if you have consented to any disclosure to a third party; and
- in addition, we may, in the future, sell or otherwise transfer some or all of our assets to a third party. Your personal data may be disclosed to any potential or actual third-party purchasers of such assets and/or may be among those assets transferred.
9. Where we store your information
We may store your information in the US, UK, and other jurisdictions where we, or our service providers, do business and this may include a transfer from your local jurisdiction to another country. If you are located in the European Economic Area (“EEA”), please note that we may transfer, use and/or store your personal information outside of the EEA and the laws of some of these destination countries may not offer the same standard of protection for personal information as countries within the EEA. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers (for example, those who supply support services to us). Transfers to our third-party service providers are to enable them to use and store your personal information on our behalf. We will, however, put in place appropriate security procedures in order to protect your personal information. Where your information is transferred to any country outside the EEA, we ensure that this is done using specific legally approved safeguards. You can request further details and a copy of these safeguards by contacting us (see section 3).
10. Keeping your information
We will keep your information only for as long as necessary depending on the purpose for which it was provided. Details of retention periods for different aspects of your personal information are available upon request. When determining the relevant retention periods, we will take into account factors including:
- our contractual and business relationships with you;
- legal obligations under applicable law to retain data for a certain period of time;
- statute of limitations under applicable law(s); and
- guidelines issued by relevant supervisory authorities.
We acknowledge that the information you provide may be confidential and will maintain the confidentiality of and protect your information in accordance with our normal procedures and all applicable laws. We employ appropriate technical and organizational security measures to help protect your personal data against loss and to guard against access by unauthorized persons. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. In addition, those employees, agents, contractors and other third parties who process your personal data will only do so on our instructions and they will be subject to a duty of confidentiality. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, for example by encrypting our outgoing email communications, we cannot guarantee the security of your data transmitted to our website. We are not responsible for the security of your internet access service provider; you should review the security and privacy policies of your internet access service provider carefully. Any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorized access. Information that you access via our website may be stored on your computer during your session for your convenience. If others have access to your computer they may be able to access this information. We are not responsible for the security or privacy of information while stored or processed on such a computer. You should keep any correspondence you receive relating to our services confidential and in a safe place.
12. Links to other websites
Links on our website may take you to third party sites over which we have no control. While such links are provided for your convenience, you should be aware that the information handling practices of the linked websites might not be the same as ours. You should review any privacy notices on those linked websites. We are not responsible for any linked websites.
13. Changes to our Privacy Notice
We reserve the right, at our discretion, to change, modify, add to, or remove portions from, our Privacy Notice, so please check from time to time for such modifications. We will of course notify you of any changes where we are required to do so.
14. Third Party Advertisers
15. Children's Information (Children's Online Privacy Protection Act)
We respect the privacy of your children and do not knowingly collect or retain personally identifiable information from children under the age of 13 through our website.
16. Notice to California Users Required by State Law
We collect, use, retain and share information we receive through our website in accordance with the above section 7 entitled “Our bases for collecting and using the information”. For information about whether third parties may collect personal information about your online activities over time and across other websites when you use our website, please see the above sections 7 and 14. Our website currently does not respond to "do not track" signals or similar mechanisms. If you have specific questions regarding this privacy notice, please contact us in accordance with section 3 above.
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