LACM Privacy Notices
Los Angeles Capital Management LLC (“LACM”, “we”, “us”, “our”) recognizes the importance of keeping information about you confidential and secure and is committed to protecting the nonpublic and personal and financial information of our clients and consumers who obtain or seek to obtain financial products or services. We fulfill this commitment by establishing and implementing policies and systems to protect the security and confidentiality of this information. Before you submit any information on, through, or in connection with the services to LACM or through this website, please carefully review these privacy policies and notices (“Policy”). By submitting any personal data directly to us, you understand the manner in which we collect, use, and disclose your information as described in this policy. We will continue to evaluate this Policy. Any changes will be posted here, and you should check this page periodically for updates. Your continued use of this website will signify your continued understanding of the terms of the updated Policy.
This Policy is split into sections. For your convenience, links to each of those sections are as follows:
I. What You Should Know
For California residents only, please refer to the Los Angeles Capital Privacy Notice for California Residents.
II. Safeguarding Your Information
Los Angeles Capital limits access to nonpublic personal and financial information about you to those personnel who need to know the information in order to provide products or services to you. Los Angeles Capital maintains physical, electronic, and procedural safeguards that we believe are reasonably designed to comply with federal standards to protect your nonpublic personal and financial information.
III. Categories of Personal Information We CollectDepending on the products and services you use, Los Angeles Capital may collect the following types of nonpublic personal and financial information about you:
- Your name, address, e‐mail address, name of current or former employer, tax identification number, and identifying numbers, and other similar personal and financial information, from you and from identification cards (e.g., passport and driver’s license) and papers you submit to us on applications, subscription agreements or other forms of communications.
- Information about your account balances and financial transactions with us, our affiliated entities or nonaffiliated third parties from our internal sources, from affiliated entities and from nonaffiliated third parties. This includes information about redemptions and additions to your accounts.
- Information about your balances and financial transactions and other personal and financial information, from consumer credit reporting agencies or other nonaffiliated third parties to verify information received from you or others as well as information from third parties such as consultants, referring brokers or advisers, managers, product sponsors and clearing firms, and their service providers.
- Information captured on our website.
IV. Categories of Information We Disclose to Non-Affiliated Third Parties
Los Angeles Capital occasionally discloses nonpublic personal and financial information about you to non‐affiliated third parties as permitted by law, including in the following instances:
- for our everyday business purposes as necessary to execute, process, service and confirm securities transactions that you request or authorize,
- to fulfill our contractual obligations to you or your employer,
- to service and administer your account and commingled investment vehicles in which you are invested,
- to communicate with you as our client, our client contact or employee,
- to market our products and services through joint marketing arrangements,
- to manage our business operations, including but not limited to: managing our products and services; collecting money that is owed to us; and making payments for products and/or services rendered,
- to process any job application submitted by you,
- to manage privacy and security,
- to aid in the detection and prevention of financial crimes,
- to comply with our regulatory requirements, or
- to respond to court orders and other legal proceedings, such as responding to a subpoena.
Los Angeles Capital may disclose nonpublic personal and financial information concerning you to law enforcement agencies, federal or state regulatory agencies, self‐regulatory organizations or other nonaffiliated third parties, if required or requested to do so by a court order, judicial subpoena or to comply with a legal or regulatory obligation.
When your nonpublic personal and financial information is disclosed to unaffiliated third parties, they are not permitted to use the information for any purpose other than to assist our servicing and administration of your account(s), including helping us improve the services we offer, or as permitted by law.
Nonpublic personal and financial information may be stored by Los Angeles Capital for an indefinite period of time. Access to such information is limited to those personnel who need to know the information in order to provide products or services to you and is password protected.
V. Categories of Information We Disclose to Our Affiliated Entities
Los Angeles Capital regularly discloses your name, address, and account and other identifying numbers, account balances and information about your pending or past transactions to our parent entities, LACM Holdings Inc. and LACM Equity LLC, and our subsidiary, LACM Global, Ltd. for any business purpose.
VI. Information About Our Former Customers
Los Angeles Capital does not disclose nonpublic personal and financial information about former customers to nonaffiliated third parties unless required for legal or regulatory purposes, including if requested to do so by a court order, judicial subpoena or regulatory inquiry, or otherwise where we believe in good faith that disclosure is required or permitted by law. Furthermore, Los Angeles Capital does not disclose nonpublic personal and financial information about former customers to nonaffiliated third party systems unless such system was used to service your account.
Los Angeles Capital may disclose your name, address, e‐mail address, phone number, taxpayer identification number, account and other identifying numbers, account balances, information about your past transactions and other personal financial information to our affiliated entities for any business purpose.
VII. Access To Your Information
You are entitled to access nonpublic personal and financial information that Los Angeles Capital may hold about you. Generally, you will be granted full access to your personal information unless there is a legal or administrative reason to deny access. In such an event, Los Angeles Capital will provide you with the reasons for the refusal. Individuals requesting access to any personal information maintained by Los Angeles Capital should contact the Chief Compliance Officer at firstname.lastname@example.org.
VIII. Changes to this Policy
Los Angeles Capital may modify, alter or otherwise update this Policy at any time. Los Angeles Capital will promptly post the new policy or summary on its public website including the date the Policy was revised.
IX. More Information
If you have any questions about this Policy, please contact us by email at email@example.com or regular mail as follows:
Los Angeles Capital Management LLC
Attn: Compliance Department
11150 Santa Monica Blvd. Suite 200
Los Angeles, California 90025
Revised September 14, 2023
Los Angeles Capital Privacy Notice and California Notice at Collection
This Privacy Notice and California Notice at Collection (“Privacy Notice”) describes how Los Angeles Capital Management LLC (“Los Angeles Capital”, “we”, “us” and “our”) collects, uses, and discloses certain information from and about you. This Privacy Notice applies to visitors to and users of www.lacapm.com (the “Site”), visitors to our offices, and employees and other personnel of entities that are our current or prospective customers (collectively, “you”, “your”, “yours”).
Please read this Privacy Notice carefully. By using the Site or otherwise interacting with us, you agree to our collection, use, and disclosure of your information as described in this Privacy Notice. If you do not agree to this Privacy Notice, please do not use the Site or otherwise interact with us. We may provide supplemental privacy notices and/or disclosures on specific occasions that supplement this Privacy Notice.
Residents of the European Economic Area, United Kingdom, and Switzerland: Please see our LACM GDPR Privacy Notice for EU and UK Residents.
Residents of California: Please see our Notice to California Residents.
1. Information we collect
The information we collect may vary depending on your interactions with us. We may collect information directly from you, such as when you sign up for emails and other communications, input your information into the Site, or correspond with us; automatically, such as through cookies and similar technologies; or from other sources, such as our affiliates. Companies that provide us with services may also collect information on our behalf.The information we collect from and about you may include the following:
- Identifiers, such as name, alias, work postal address, home and work email address, mobile and work telephone phone number, and Internet Protocol address.
- Professional or employment-related information, such as your title and the name of your employer.
- Internet or other electronic network activity information, such as browsing history, search history, and information on your interaction with the Site, including without limitation when you enter and leave the Site, the site or webpage you visited before visiting our Site, and the number of times you visit our Site.
- Audio and visual information, such as CCTV footage at our premises.
- Other information you provide us, such as any information you choose to provide via email.
We may combine this information with information collected from or about you in other contexts. This may include information collected from publicly available sources, such as your company website, and other sources. We will treat such combined information in accordance with this Privacy Notice.
2. How we use your information
We and the companies that provide services to us may use the information we collect for the following purposes:
- To maintain, administer, and provide the Site, including to fulfill your requests, and offer the features and functionalities of the Site, and for related operational purposes.
- To maintain, administer, and provide our services to our customers, and for related operational purposes.
- To fulfill our contractual obligations to you or your employer.
- To communicate with you, including to respond to your questions or other requests; provide support; provide you with information on services that you request; and notify you about changes to our Site, services, policies, terms, and notices.
- To verify your identity.
- To detect, protect against, and prosecute security incidents and fraudulent or illegal activity.
- For purposes of bug detection, error reporting, and activities to maintain the quality or safety of our service.
- To market ourselves and our services to you (subject to any preferences you have communicated to us, such as, e.g., unsubscribing from marketing emails).
- For examination or event registration, scheduling, administration, and related purposes.
- To comply with applicable laws (for example, to comply with recordkeeping, reporting, tax, and anti-money laundering obligations), respond to law enforcement requests (such as a search warrant, subpoena or court order), or to carry out professional ethics/conduct investigations.
- To protect and exercise our legal rights, such as to enforce our Terms and Conditions of Use posted on the Site.
- To analyze the use of the Site for our internal purposes.
- For any other lawful purpose (where required, with your consent).
3. How we disclose your information
We may disclose your information for any of the purposes in the “How we use your information” section above to the following types of entities and in the following circumstances.
Category of information disclosed
Categories of entities to which it is disclosed
Identifiers, such as name, alias, home and work postal address, home and work email address, mobile and work telephone phone number, Internet Protocol address.
Professional or employment-related information, such as your title and the name of your employer.
Same as first row.
Internet or other electronic network activity information, such as browsing history, search history, and information on your interaction with the Site, including without limitation when you enter and leave the Site, the site or webpage you visited before visiting our Site, and the number of times you visit our Site.
Same as first row.
Audio and visual information, such asCCTV footage of our premises.
Same as first row.
Other information you provide us, such as any information you choose to provide via email.
Same as first row.
4. How we retain your information
The length of time we retain your information may vary based on the type of information and the purposes it serves, and applicable laws and regulations. Applicable laws or regulations may set minimum or maximum periods for which we may or must retain your information, and other legal or regulatory circumstances may affect the retention period of information (e.g., if a litigation hold is placed on certain information, we may need to retain it for as long as the litigation hold is effective).
5. Notice for California Residents
This Notice for California Residents (“CA Notice”) applies solely to individuals residing in the State of California who are: (i) visitors to and users of www.lacapm.com (the “Site”); (ii) visitors to our offices; or (iii) employees and other personnel of entities that are our current or prospective customers (collectively, for purposes of this CA Notice, “you”, “your”, “yours”). California law requires us to provide you with some additional information regarding how we collect, use, and disclose your “personal information” as defined in the California Consumer Privacy Act (“CCPA”).
a. Categories of personal information we collect, use, disclose, and retain
In the 12 months leading up to the effective date of this CA Notice, we have collected the categories of personal information listed in Section 1 of our Privacy Notice, “Information we collect.” We have used these categories of personal information for any of the business and commercial purposes listed in Section 2 of our Privacy Notice, “How we use your information.” We have disclosed these categories of personal information as described in Section 3 of our Privacy Notice, “How we disclose your information.” We retain these categories of personal information as described in Section 4 of our Privacy Notice, “How we retain your information.”
b. Your CCPA rightsYou have certain rights under the CCPA with regard to your personal information. You may request that we
- Disclose to you the categories of personal information we collected about you in the past 12 months, the categories of sources from which we collected such personal information, our business or commercial purpose for collecting such personal information, and the categories of third parties to whom we disclosed that personal information. We have provided this information above in the Privacy Notice. You also have the right to request that we disclose the categories of third parties which we “sold” or “shared” personal information and our purposes for doing so, but we do not “sell” or “share” personal information as defined in the CCPA.
- Provide you with the specific pieces of personal information we collected about you in a commonly used, machine-readable format (where technically feasible).
- Correct inaccurate personal information that we hold about you.
- Delete or remove your personal information.
You also have the right not to be discriminated against (as provided for in California law) for exercising these CCPA rights. Although the CCPA also now confers certain rights to limit certain uses of what the CCPA calls “sensitive personal information,” we do not collect “sensitive personal information” about individuals covered by this Privacy Notice.
The CCPA places certain obligations on businesses that “sell” personal information to third parties or “share” personal information with third parties for “cross-context behavioral advertising,” as those terms are defined under the CCPA. We do not “sell” or “share” the personal information covered by this Privacy Notice and have not done so in the twelve months prior to the effective date of this Privacy Notice. In addition, we do not knowingly “sell” or “share” personal information of individuals under 16 years of age.
Exceptions to your rights: There are certain exceptions to these above rights. For instance, we may retain your personal information if it is reasonably necessary for us or our service providers to provide a service that you have requested or to comply with law or to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for that activity.
Exercising your rights: To exercise the rights described above, please submit a request to us by either sending an email to firstname.lastname@example.org or calling (888) 531-0306. Please note:
- Only you or your authorized agent (i.e., a person registered with the California Secretary of State which you authorize to act on your behalf) may make a request related to your personal information.
- Your request must: (1) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, or an authorized representative of such person, and (2) describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.
- We must be able to verify your identity to respond to your request or verify that you have authority to make the request on another person’s behalf. We will take reasonable steps to verify your identity before responding to a request. In doing so, we may ask you for verification information so that we can match at least two verification points with information we maintain in our files about you. If we are unable to verify you through this method, we shall have the right, but not the obligation, to request additional information from you.
Verification Process and Response: We verify requests by sending an email to you at the email address we have for you on file, by using other identifying information we have on file, or by using a third-party identity verification service. The email will ask you to respond to verify you are the person making the request. We will respond to your requests as required by the CCPA.
c. "Do Not Track" disclosure
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is still working toward defining what DNT means and how to comply with DNT, and there is not a common approach to responding to DNT. You can learn more about Do Not Track here.
d. "Shine the Light" disclosure
The California “Shine the Light” law gives you the right to opt out of the disclosure of certain categories of personal information (as defined in the Shine the Light law) to third parties for their own direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.
6. Children's privacy
The Site is not directed to minors under the age of 18 and we do not knowingly collect any information from minors under 18. If we discover we have received any “personal information” (as defined under the Children’s Online Privacy Protection Act) from a child under the age of 13, we will take reasonable steps to delete that information in a timely manner.
7. Changes to our privacy notice
Our current Privacy Notice will be posted on our Site and any updates will be effective upon posting. You are responsible for periodically checking this Site for updates. We reserve the right to amend this Privacy Notice at our discretion and at any time. If you use our Site or services after any changes to the Privacy Notice have been posted, that means you agree to the updated Privacy Notice.
8. Contacting us
If you would like further information on our Privacy Notice, please contact us at email@example.com, or write to us at 11150 Santa Monica Blvd, Suite 200, Los Angeles, CA 90025, Attn: Compliance-Privacy.
Updated: October 6, 2023
LACM GDPR Privacy Notice for EU and UK Residents