I. What You Should Know
Los Angeles Capital Management LLC (“Los Angeles Capital”) 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. This Policy applies to Los Angeles Capital. For California residents only, please refer to the Los Angeles Capital Privacy Notice for California Residents.
In our offices, 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 Information We Collect
Los Angeles Capital collects 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 and financial information about you to affiliates and non-affiliates as permitted by law. Some instances when we have shared information include:
- 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 regulatory obligation.
When your nonpublic personal and financial information is shared with 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 Entity
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 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 regulatory purposes, or 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 Angles Capital may disclose your name, address, e‐mail address, phone number, taxpayer identification number, and 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 personal 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 email@example.com.
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 it was revised.
IX. More Information
Los Angeles Capital Management LLC
Attn: Compliance Department
11150 Santa Monica Blvd. Suite 200
Los Angeles, California 90025
Revised January 4, 2021
Los Angeles Capital Privacy Notice for California Residents
About this privacy notice
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) this Privacy Notice describes the types of Personal Information Los Angeles Capital collects, uses, processes and shares and with whom we can share it. We may provide supplemental privacy notices on specific occasions when we are collecting or processing Personal Information about you so you are fully aware of how and why we are using your Personal Information. Those supplemental notices should be read together with this Privacy Notice.
Please take the time to read and understand this Privacy Notice.
Capitalized terms in this Privacy Notice are as defined in the CCPA. The following key terms are defined and summarized here: “Personal Information” as used in this Privacy Notice has the meaning set forth in the CCPA, and, in summary, means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. “Consumer” means a California resident. “Service Provider” has the meaning set forth in the CCPA and, in summary, means a company that processes Personal Information on our behalf and to which we disclose a Consumer’s Personal Information for a business purpose pursuant to a written agreement which prohibits that company from using or disclosing your Personal Information other than for the specific purpose of performing the services we have contracted to have that company perform, or as otherwise permitted under the CCPA.
We do not Sell, as that term is defined under the CCPA, your Personal Information.
We may combine the Personal Information and other information collected on www.lacapm.com (“Website”) 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 Notice.
Personal information that we collect about you
The categories of Personal Information we have collected from Consumers within the last twelve months, and which we may collect in the future, includes:
- Identifiers. Name, alias, home and work postal address, home and work email address, job title, Internet Protocol address, account name and digitized signature.
- Personal Information Categories Listed in the California Records Statute (Cal. Civ. Code §1798.80(e)). Name, signature, physical characteristics or description, address, telephone number, employment and employment history. Some Personal Information included in this category may overlap with other categories.
- Characteristics of protected classifications under California or federal law. This information may include: age (40 years or older) or gender.
- Sensory data. This information may include: audio voice recording, electronic, visual, or similar information.
How we collect Personal Information
We may collect your Personal Information via our Website, by emails you send to us, or via telephone, fax or mail.
Uses of your Personal Information
- To present our Website and its contents to you. We use Google Analytics and collect general anonymized information.
- To provide you with information on services that you request from us.
- To provide you with services that you have requested.
- To verify your identity in order to comply with federal or state laws
- To send you emails and newsletters with product, service, company and other information.
- To respond to your questions or other requests.
- To process other information or Personal Information that you submit through this Website.
- To notify you about changes to our Website, our policies, terms or any products or Services we offer or provide though it.
- For examination or event registration, scheduling, administration and related purposes.
- To provide verification of event attendance.
- For internal purposes, such as Website and system administration or internal audits and reviews.
- To comply with applicable laws (for example, to comply with a search warrant, subpoena or court order) or to carry out professional ethics/conduct investigations.
- To operate, maintain and provide to you the features and functionality of the Services.
- To provide statistics about the usage levels of the Website and other related information to reputable third parties, but these statistics will not include information which will allow you to be identified.
- To fulfill any other purpose for which you provide it.
- In any other way we may describe to you when you provide the information.
In addition to the above list, we may use your Personal Information we collect for one or more of the following business purposes:
- to perform our obligations and exercise our rights under a contract that Los Angeles Capital has entered with you or your organization.
- to fulfil or meet the reason for which the information is provided, and to otherwise provide our products and services.
- to provide you with information, products or services that you request from us.
- to communicate with you, notify you about important updates or changes to our products and services, and address relevant inquires or complaints.
- to provide you with email alerts, event registrations, newsletters and other notices concerning our products or services, or events or news, that we think may be of interest to you.
- we will process Personal Information 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.
- as described to you when collecting your Personal Information.
In addition to the above list, we may disclose your Personal Information we collect for one or more of the following business purposes:
- 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).
- to respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
- to evaluate or conduct a merger, divestiture, restructuring, reorganization, 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.
Disclosure of your information to third parties
- Fund administrators, transfer agents, brokers, advisors and similar professional service providers.
- Hosting providers for the secure storage and transmission of your data.
- Service providers who manage registration and attendance at Los Angeles Capital hosted events.
- Identity management providers for authentication purposes (e.g., multi-factor authentication software and service providers).
- Database software providers for the hosting, management and tracking of your data.
- Legal and compliance consultants, such as external counsel, external auditors or tax consultants.
- Third party service providers who send communications on our behalf regarding our products and Services.
- Technology providers who assist in the development and management of our Website.
We may share your Personal Information with Service Providers for the following business purposes:
- 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 your Personal Information on our behalf. These Service Providers will only use your Personal Information to provide services to us;
- if we sell any of our business or assets, we may disclose your Personal Information to the prospective buyer for due diligence purposes;
- if we are acquired by a third party, we may disclose Personal Information held by us about you to the third party buyer; and
- to the extent required by law, for example, if we are under a duty to disclose your Personal Information in order to comply with any legal or compliance obligation, or to establish, exercise or defend our legal rights.
We do not “sell”, as that term is defined under the CCPA, your Personal Information.
Retention of Personal Information
The length of time we retain your Personal Information for will vary. The retention period will be determined by the following criteria:
- the purpose for which we are using your Personal Information (e.g., your account information to be able to administer your account) – we will need to keep the data for as long as is necessary for that purpose; and
- laws, regulation or internal policy may set a minimum period for which we keep your Personal Information.
Your rights under the CCPA
Under the CCPA, Consumers have a number of specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection use, and disclosure of your Personal Information over the past 12 months. Once we receive and confirm your verifiable Consumer request, we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you (also called a data portability request).
- If we disclosed your Personal Information for a business purpose, a list disclosing disclosures for a business purpose and identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your Personal Information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete, and direct our service providers to delete, your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our Service Provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Enable solely internal uses that are reasonably aligned with Consumer expectations based on your relationship with us.
- Comply with a legal, regulatory or law enforcement obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability and deletion rights described above, please submit a verifiable Consumer request to us by either: sending an email to firstname.lastname@example.org or calling (888) 531-0306.
Only you, or a person registered with the California Secretary of State which you authorize to act on your behalf, may make a verifiable Consumer request related to your Personal Information. You may also make a verifiable Consumer request on behalf of your minor child.
You may only make a verifiable Consumer request for access or data portability twice within a 12-month period.
The verifiable Consumer 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, and (2) describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable Consumer request does not require you to create an account with us.
We will only use Personal Information provided in a verifiable Consumer request to verify the requestor's identity or authority to make the request.
We verify Consumer 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 Consumer making the request.
Response Timing and Format
We will confirm receipt of your request within ten (10) days of receiving it. We will respond to a verifiable Consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you in writing of the reason and extension period.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable Consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format in which to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable Consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you simply for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Notice
We strive to make our website accessible to everyone. You can print a copy of this Privacy Notice by clicking on the "Print" link here. Our Privacy Notice website page is compliant with the Americans With Disabilities Act (e.g., it can be read with a text-to-speech reader).
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.
You can find more information about your rights on the State of California Department of Justice’s website available here.
Updated: January 4, 2021
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Reminder About Los Angeles Capital's Financial Products
Financial products offered by Los Angeles Capital and its subsidiary, LACM Global, Ltd. ("LACM Global"), are not guaranteed by any bank, not insured by the Federal Deposit Insurance Corporation and are not obligations of Los Angeles Capital or LACM Global. Such products are subject to investment risks including possible loss of the principal amount committed or invested and earnings thereon.