GMO maintains physical, electronic, and procedural safeguards reasonably designed to guard its customers’ non-public personal data. GMO uses its customers’ non-public personal data primarily to complete financial transactions that its customers request or to make its customers aware of other financial products and services offered by a GMO affiliated company.
Information GMO Collects About Its Customers
GMO collects non-public personal data about its customers from the following sources:
How GMO Handles Its Customers’ Personal Data
GMO may disclose all of the non-public personal data it collects about current or former customers to its delegates, professional advisors, service providers, regulatory bodies, auditors, technology providers, and any duly authorized agents ore related, associated, or affiliated companies of the foregoing in certain situations. Examples include:
For information on the means of transfer of personal data or a copy of the relevant safeguards, please contact email@example.com.
Please note that personal data may be retained by GMO for the duration of a customer’s investment and afterwards in accordance with GMO’s legal and regulatory obligations, including but not limited to GMO’s record retention policy.
GDPR Customer Rights (not applicable to non-EU Data Subjects)
The General Data Protection Regulation (“GDPR”) (Regulation (EU) 2016/679) provides certain rights in favor of data subjects domiciled in the European Union (“EU”). The rights in question are as follows (the “Data Subject Rights”):
These Data Subject Rights will be exercisable by EU-domiciled data subjects (subject to limitations as provided for in relevant data protection law). In certain circumstances, it may not be feasible for GMO to discharge these rights (e.g., because of the nature of the relationship between GMO and the customer). Data subjects may make a request to GMO to exercise any of the Data Subject Rights by contacting firstname.lastname@example.org. Requests shall be dealt with in accordance with relevant data protection laws.
GMO is a data controller within the meaning of the GDPR and undertakes to hold any personal data provided by customers in confidence and in accordance with relevant data protection legislation. For queries, requests, or comments in respect of this notice or the way in which GMO uses customers’ personal data, please contact email@example.com. Customers may have the right to lodge a complaint with the local data protection regulator in their country of residence if they are dissatisfied with the manner in which their personal data is used by GMO.
CCPA Customer Rights (not applicable to non-California residents)
The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights in favor of natural persons that are California residents. The rights in question are as follows (the “CCPA Rights”):
These CCPA Rights will be exercisable by natural persons that are California residents (subject to limitations as provided for in relevant data protection law). In certain circumstances, it may not be feasible for GMO to discharge these rights (e.g., because of the nature of the relationship between GMO and the customer). California residents may make a request to GMO to exercise any of the CCPA Rights by contacting firstname.lastname@example.org, visiting www.gmo.com/contact, or by calling toll-free 1-888-890-3189, and can designate an authorized agent to make any such request. Requests shall be dealt with in accordance with relevant data protection laws. GMO may seek to verify any requests in one of several different ways, including but not limited to by referring to information that GMO has on file and/or by submitting one or more follow up queries to the customer.
GMO will not discriminate against customers (by denying services, charging different fees, or providing a different level of service) for exercising their CCPA Rights. For queries, requests, or comments in respect of this notice or the way in which GMO uses customers’ personal data, please contact email@example.com.
Keeping Its Customers Informed
GMO reviews this Privacy Notice at least once every 12 months and reserves the right to modify this notice at any time, but in the event that there is a material change, GMO will inform its customers of that change.
If you are in Singapore or have questions about how GMO Singapore Pte. Limited deals with your personal information or personal data, please contact our Singapore Data Protection Officer at DataProtectionOfficerSingapore@gmo.com.
*For purposes of this notice, the term “customer” or “customers” includes both individuals who have or had investments with a GMO affiliated company and individuals who have provided non-public personal data to a GMO affiliated company, but did not invest with a GMO affiliated company.
**For the avoidance of doubt, it is not GMO’s intent to sell its customers’ data. Any transfer of data to a third party (such as the examples described in this Notice) is only for the purpose of allowing GMO to discharge its obligations to its customers