GMO’S COMMITMENT TO ITS CUSTOMERS*
Last Updated: November 2, 2022
GMO maintains physical, electronic, and procedural safeguards reasonably designed to guard its customers’ non-public personal data. This notice informs you of GMO’s practices when handling your personal data (i.e., any information relating to an identified or identifiable individual), and GMO is the data controller under applicable privacy laws, such as GDPR (as defined herein). 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:
- Account Applications and Other Forms, which may include a customer’s name and address, social security number or tax identification number, total assets, income, and accounts at other institutions;
- Account History, which may include information about the transactions and balances in accounts with GMO;
- Correspondence, which may include written, telephonic, or electronic communications; and
- Other Interactions that you may have with us (including, but not limited to, accessing our website).
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, government authorities and regulatory bodies (including supervisory authorities and data protection regulators in the European Economic Area (“EEA”) and UK, as applicable), auditors, technology providers, and any duly authorized agents or related, associated, or affiliated companies of the foregoing in certain situations. Examples include:
- In order to complete certain transactions or account changes that a customer directs, or to otherwise administer a customer’s holding in a product managed by GMO in accordance with the contract between the customer and GMO, it may be necessary to provide certain non-public personal data about that customer to companies, individuals, or groups that are not affiliated with GMO. For example, if a customer asks GMO to transfer assets from another financial institution, GMO will need to provide certain non-public personal data about that customer to the company to complete the transaction.**
- In order to alert a customer to other financial products and services that a GMO affiliated company offers, or in order to perform intra-company accounting. GMO may share non-public personal data it has about that customer with a GMO affiliated company. This would include, for example, Grantham, Mayo, Van Otterloo & Co. LLC sharing a customer’s non-public personal data with GMO Australia Limited.
- In certain instances, GMO may contract with non-affiliated companies to perform services for or on behalf of GMO. Where necessary, GMO will disclose non-public personal data it has about its customers to these third parties. For example, GMO may provide non-public personal data about a customer’s separate account to a qualified brokerage firm in order to enter into futures transactions. In all such cases, GMO will provide the third party with only the information necessary to carry out its assigned responsibilities and only for that purpose. In addition, GMO requires these third parties to treat GMO customers’ non-public information with the same high degree of confidentiality that GMO does.
- In order to carry out statistical analysis and market research as GMO’s legitimate business interest.
- In order to comply with legal and regulatory obligations applicable to the customer and GMO from time to time, including applicable anti-money laundering and counter terrorist financing legislation. In connection with this, GMO may use third party services like Refinitiv World-Check One, and refers customers to the World-Check One privacy statement located here.
- In connection with corporate transactions, for instance if we divest one or more of our funds or lines of business.
- Finally, GMO will release non-public information about customers if that customer and/or individuals associated with the customer’s account have given specific consent, or if GMO is authorized by law to do so.
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-EEA and non-UK Data Subjects)
The General Data Protection Regulation (“GDPR”) (Regulation (EU) 2016/679) (including, for the purposes of this notice, the GDPR as adopted and implemented in the United Kingdom in the form of the UK GDPR) provides certain rights in favor of data subjects based in the EEA or UK. The rights in question are as follows (the “Data Subject Rights”):
- the right of access to personal data;
- the right to amend and rectify any inaccuracies in personal data;
- the right to erase personal data (right to be forgotten);
- the right of data portability;
- the right to restrict Processing;
- the right to object to Processing; and
- the right to object to automated decision making, including profiling.
These Data Subject Rights will generally be exercisable by EEA-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; in the UK, this is the Information Commissioner’s Office.
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”):
- the right of access to personal data;
- the right to erase personal data (right to be forgotten); and
- the right of data portability.
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.
What are cookies?
A cookie is a small text file of letters and numbers that is sent to the hard drive of your computer, phone or tablet when you use our website. Each time you return to the same website, your browser retrieves and sends the relevant cookie(s) to the website’s server. This enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.
What cookies does GMO use?
GMO’s website uses the following types of cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of GMO’s website.
- Analytical/performance cookies. These cookies allow GMO to recognize and count the number of visitors and to see how visitors move around GMO’s website when they are using it. This helps GMO to determine the effectiveness of GMO’s website and to guide future improvements to the way GMO’s website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These cookies are used to recognize you when you return to GMO’s website. This enables us to personalize our content for you and remember your preferences (for example, your choice of region).
- Targeting cookies. These cookies record your visit to GMO’s website, the pages you have visited and the links you have followed. GMO will use this information to make our website more relevant to your interests. We may also share this information with third parties for this purpose.
How long do cookies last?
Except for strictly necessary cookies, all cookies will expire after 13 months.
What about third-party cookies?
When you first use GMO’s website, you will see a “pop up” cookies notice. By using GMO’s website after accepting the cookies notice, or by browsing GMO’s website after you have been presented with this notice, you agree to us placing cookies on your computer in accordance with the terms described on this page.
Please note that if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of GMO’s website.
Who should I contact with a question?
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