This Privacy Notice is for people who are located in the European Economic Area (“EEA”) and supplements our general Privacy Statement. Our processing of personal data of people who are in the EEA is governed by the General Data Protection Regulation (the “GDPR”), which applies from May 25, 2018. The GDPR requires us to provide certain information to you about your personal data, which we refer to in this notice as your personal information.

This Privacy Notice explains how Los Angeles Capital Management and Equity Research, Inc. (““Los Angeles Capital”, “LACM”, “we”, “us” and “our”), collect, use, share and otherwise process your Personal Data and other information.

We may provide supplemental privacy notices on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Personal Data. Those supplemental notices should be read together with this Privacy Policy.

About this Privacy Notice

For the purposes of data protection law, Los Angeles Capital is a data controller in respect of your Personal Data. We are responsible for ensuring that we use your Personal Data in compliance with data protection law.

The Privacy Notice sets out the basis on which any Personal Data about you will be processed by us. Please take the time to read and understand this Privacy Policy.

Personal Data

The term “Personal Data” as used in this Privacy Notice means any information relating to you such as your name, contact details, etc. Personal Data does not include data from which you can no longer be identified such as anonymised aggregate data.

We may combine the Personal Data and other information collected on www.lacapm.com with information collected from or about you in other contexts. This may include information collected online, such as through our email exchanges with you, from publicly available sources, such as your company website, or from offline sources, such as information that we collect when you call us. We will treat such combined information in accordance with this Privacy Policy.

Personal Data That We Collect About You

The kinds of Personal Data we may collect include:

Information that you provide to us. This includes information about you that you give to us by completing forms online or by communicating with us, whether face-to-face, by phone, e-mail or otherwise. This information may include:

  • your full name, company name, job title, email address, mailing address, telephone and fax numbers, mobile telephone number, and other information you provide to us directly online, such as information collected for identification purposes; and
  • other information that you provide to us in connection with the services we provide.

Information we collect or generate about you. We may collect information about you when you seek information about us or establish a business relationship with us on behalf of yourself or your organization. This information may include:

  • information collected from your organization, such as details about authorised signatories;
  • copies of any relevant trust deeds, partnership agreements, constitutions, articles of association or other corporate entity documents; and
  • information collected from your use of www.lacapm.com, including your voluntary disclosure of any personal information into www.lacapm.com (e.g., submission of an online form) and from the use of cookies, such as technical and navigational information, including what pages you visited, the number of times you visited the website, what site you came prior to visiting the website. See our Cookie Policy for more information.

Use of Your Personal Data

Your Personal Data may be stored and processed by us in the following ways and for the purposes for which it was provided to us, as required by law, and for our business purposes, including:

  • to perform our obligations and exercise our rights under a contract that Los Angeles Capital has entered with you or your organization, and to otherwise provide our products and services;
  • to communicate with you, notify you about important updates or changes to our products and services, and address relevant inquires or complaints;
  • to meet our legal obligations and protect our legal rights, including, without limitation, to comply with recordkeeping, reporting and tax obligations under applicable law (such as corporations, tax and anti-money laundering);
  • for marketing and promotional purposes, consistent with applicable law. For example, we may use your Personal Data, such as your email address, to send you news and newsletters, or to otherwise contact you about our services or information we think may be of interest to you; and
  • we will process Personal Data related to your use of our email system in order to enable the effective operation of the email system and ensure that it is used in accordance with our policies and procedures.
We are entitled to use your personal data in these ways because:
  • we need to in order to perform our obligations and exercise our rights in connection with any contract that Los Angeles Capital has entered with you or your employer, and to otherwise provide our products and services to you;
  • we have legal and regulatory obligations that we have to discharge;
  • we may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
  • the use of your Personal Data as described may be necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates), such as:
    • allowing us to effectively and efficiently administer and manage the operation of our business; or
    • maintaining compliance with internal policies and procedures;
  • you have consented to us doing so.

Disclosure of Your Information to Third Parties

We may disclose your Personal Data to affiliates for the purposes of:

  • the management and administration of our business and our affiliates’ business; and
  • assessing compliance with applicable laws, rules and regulations, and internal policies and procedures across our business and our affiliates’ businesses.
We will take steps to ensure that the Personal Data is accessed only by employees of our affiliates that have a need to do so for the purposes described in this policy.

We may also share your Personal Data with third parties outside of our corporate group for the following purposes:

  • to third party agents and contractors for the purposes of providing services to us, including administrators, transfer agents, broker-dealers, technology and communication service providers, law firms, accountants, consultants, auditors, and other professional advisers. These service providers may collect, process, and retain information about you, in accordance with applicable laws, directly on behalf of us. These third parties will be subject to confidentiality requirements and they will only use your Personal Data as described in this Privacy Policy;
  • if we sell any of our business or assets, in which case we may disclose your Personal Data to the prospective buyer for due diligence purposes;
  • if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer; and
  • to the extent required by law, for example, if we are under a duty to disclose your Personal Data in order to comply with any legal or compliance obligation, establish, exercise or defend our legal rights.

Transfers of Personal Data Outside the European Economic Area

Los Angeles Capital’s offices are in the United States and that is where we process the Personal Data that we collect from you. It may also be processed by individuals operating outside of the EEA who work for our affiliates or for one of our service providers. When you provide Personal Data to us, we request your consent to transfer that Personal Data to the United States. Although the data protection laws in the United States and other countries where your Personal Data may be transferred may be different from, and less stringent than, those in your country of residence, we safeguard your Personal Data by treating it in accordance with this GDPR Privacy Notice. We take appropriate steps to protect your privacy and implement reasonable security measures to protect your Personal Data in storage. We also enter into contracts with our data processors that require them to treat Personal Data in a manner that is consistent with this Notice. By using www.lacapm.com, or by providing Personal Data to us, you expressly consent to such transfer and processing.

You can obtain more details about the protection given to your Personal Data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Contacting us” section below.

Retention of Personal Data

How long we hold your Personal Data for will vary. The retention period will be determined by the following criteria:

  • the purpose for which we are using your Personal Data – we will need to keep the data for as long as is necessary for that purpose; and
  • legal obligations – laws, regulation, or internal policy may set a minimum period for which we have to keep your Personal Data.
We will use commercially reasonable physical, electronic, and procedural safeguards to protect your Personal Data from loss, misuse, and unauthorised access, disclosure, alteration, and destruction in accordance with applicable law. Note that despite our best efforts, no data security measures can fully guarantee security all of the time.

Your Rights

You have a number of legal rights in relation to the Personal Data that we hold about you. These rights include:

  • the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
  • where you have actively provided your consent for us to process your Personal Data, the right to withdraw your consent at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so;
  • in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided to us;
  • the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
  • the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
  • the right to request that we restrict our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you ask us to restrict our processing of your Personal Data but we are legally entitled to refuse that request; and
  • the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.
You can exercise your rights by contacting us using the details set out in the “Contacting us” section below.

Children's Privacy

We recognize the need to provide particular privacy protections with respect to personal information that may be collected from children. www.lacapm.com and the services are not aimed at or intended for children.

No Statutory of Contractual Requirement or Other Obligation to Provide Personal Data

Users of www.lacapm.com are under no statutory or contractual requirement or other obligation to provide Personal Data to us via www.lacapm.com.

Contacting Us

If you would like further information on the collection, use, disclosure, transfer or processing of your Personal Data or the exercise of any of the rights listed above, please contact us in any of the ways listed in the section “X. More Information” in our general privacy policy.

You have the right to file a complaint concerning our processing of your Personal Data with your national (or in some countries, regional) data protection authority. The EU Commission has a list available here.

Updated May 15, 2020

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