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:
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, regulatory bodies, auditors, technology providers, and any duly authorized agents ore 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 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-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.
Keeping Its Customers Informed
GMO 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.