Effective Date: December 20, 2019
Western Asset is a global asset management firm comprised of six legal entities operating as one firm. The entities include: Western Asset Management Company, LLC (the Pasadena and New York offices); Western Asset Management Company Distribuidora de Títulos e Valores Mobiliários Limitada (the São Paulo office); Western Asset Management Company Limited (the London and Zurich offices); Western Asset Management Company Pte. Ltd. (the Singapore office); Western Asset Management Company Ltd (the Tokyo office); and Western Asset Management Company Pty Ltd (the Melbourne office) (collectively, “Western Asset” , “us” , “we” , or “our” ).
Table of Contents
- I. Personal Information We Collect
- II. How We Use The Personal Information We Collect
- III. How Your Personal Information Is Stored
- IV. Cookies
- V. Disclosure and Sharing Personal Information
- VI. Transferring Your Personal Information
- VII. Protection of Your Personal Information
- VIII. Retention of Your Personal Information
- IX. Your Data Rights
- X. California Residents
- XI. Children’s Privacy
- XII. Links to Other Websites
- XIII. Additional Region-Specific Disclosures
- XV. How To Contact Us
I. Personal Information We Collect
We may collect a variety of personal information about you, including:
- Job title, occupation, employer details;
- Address and phone number;
- Email address;
- Date of birth;
- Corporate contact details; and
- Financial information.
II. How We Use the Personal Information We Collect
The legal basis on which Western Asset processes personal information is to comply with applicable laws and regulations, to fulfil our contractual obligations with you and/or to pursue Western Asset’s legitimate interests where these are not outweighed by your interests. In some circumstances, we may rely on your consent to send electronic marketing communications.
We may use your personal information to:
- Conduct administrative or operational processes within our business;
- Process and respond to requests, enquiries or complaints received by you;
- Provide new products and services requested by you;
- Communicate with you about information that might be of interest;
- Identify services and products we can offer you;
- Comply with applicable laws or regulations or at the request of a competent regulatory authority (such as the recording of telephone calls and monitoring of emails);
- Identify organizations who have visited the website to compile statistical data on the use of our website to track how users navigate through our website in order to enable us to evaluate and improve our website;
- Monitor and analyze our business;
- Conduct market research surveys where you choose to participate in these;
- Process and consider your application for job openings;
- Prevent, investigate and provide notice of fraud, unlawful or criminal activity, or unauthorized access to or use of personal data, our website or data systems, or to meet legal obligations.
III. How Your Personal Information Is Stored
Our website utilizes a variety of technologies, including some provided by third parties, including but not limited to cookies, web beacons, pixels/tags, and other storage technologies, (collectively, “cookies”), ) to collect, store, measure and aggregate data about usage and browsing patterns. These technologies help us to secure, analyze and tailor the site for all users and better understand how our website is used.
Refusing Cookies on this Website
Most web browsers allow some control of most cookies through the browsers settings. You can choose not to accept or delete certain cookies by turning this feature ‘off’ within the browser settings; however, doing this may detract from ‘user experience’ of or even prevent access to some of our website. You can set your browser to let you know each time a website tries to set a cookie. To find out more information on cookies and how to turn them off you can visit www.aboutcookies.org or www.allaboutcookies.org.
“Do Not Track” Signals
“Do not track” is a preference you can set in your web browser to inform websites that you do not wish to be tracked. You can enable or disable “do not track” by visiting the Preferences or Settings page of your web browser. At this time, we do not respond to “do not track” signals. We do not allow third parties to collect personal information about your online activities over time and across different websites when you use our online services.
V. Disclosure and Sharing Personal Information
We may from time to time be required to disclose your personal information to comply with law enforcement bodies, regulators, agencies or third parties under a legal requirement or court order. We act responsibly and take account of your interests when responding to any such requests.
Western Asset does not sell your personal information. We will only share your personal information with Western Asset affiliates or third party companies when:
- You agree for us to share this information with third party companies to receive marketing material from them; or
- Sharing your information with Western Asset affiliates or third party companies (such as our suppliers) is necessary to perform the services you have requested from us; or
- In the event of a change of control transaction, external investment, merger, acquisition, reorganization, or liquidation or similar event.
We and our service providers may collect other Information in a variety of ways, including:
- Through your browser or device:
- Certain information is collected by most browsers or automatically through your device, such as your address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the services (such as the App) you are using. We use this information to ensure that the services function properly.
- Through your use of the Mobile App
- When you download and use the Mobile App, we and our service providers may track and collect Mobile App usage data, such as the date and time the Mobile App on your device accesses our servers and what information and files have been downloaded to the Mobile App based on your device number.
- Using cookies
- Using pixel tags and other similar technologies
- Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, to track the actions of users of our services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
- We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering our services.
VI. Transferring Your Personal Information
We may transmit, transfer or process your personal information to an affiliate or third party service provider outside your country of residence or the country where the information was collected. We will take measures to ensure personal information is handled, in our view, with the same or similar levels of protection as required in the EU or the United Kingdom, for instance by entering into contracts incorporating approved Model Contractual Clauses (as published by the European Commission). By providing us with your personal information you expressly consent to our transferring your personal data to countries or jurisdictions, which may not provide the same level of data protection as your home country, including without limitation countries or jurisdictions outside the EEA.
VII. Protection of Your Personal Information
We employ up to date data storage, back up and security measures that seek to protect your information from access by unauthorized persons and against unlawful processing, accidental loss, destruction, and damage. We apply robust information security management processes, which we believe are in line with the standards required and prevailing in our industry. With respect to our internal security procedures, we maintain physical, electronic, and procedural safeguards to protect your non-public information, and we restrict access to this information. For details, please view our Online Security Policy.
VIII. Retention of Your Personal Information
We will keep your personal information as required by applicable laws and regulations and in accordance with our data retention policy. We will retain your personal information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
IX. Your Data Rights
Individuals in Andorra, Argentina, Australia, California, Canada, Cayman, European Union, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, United Kingdom, Uruguay, and certain other jurisdictions may have certain data subject rights. These rights vary, but may include the right to: (i) request access to and rectification or deletion of their personal information; (ii) restrict or object to the processing of their personal information; and (iii) obtain a copy of their personal information in a portable format, subject to certain exceptions. We do not discriminate against individuals who have opted out of receiving marketing offers or who otherwise exercise their privacy rights to access, restrict or obtain a copy of personal information.
You may make a request to Western Asset to exercise these rights by contacting us as described in the section “How to Contact Us” and providing pertinent details for the request. If you make a request related to personal information about you, you may be required to supply a valid means of identification as a security precaution. We will process your request within the time provided by applicable law.
X. For California Residents
You may designate an Authorized Agent to exercise a request on your behalf, subject to the identification process. This process may include providing a password/passcode, a copy of government issued identification, affidavit or other applicable documentation, i.e. written permission, if you have appointed an authorized agents to make a request on your behalf, or you are an Authorized Agent making such a request (such as a power of attorney or other written permission). We may require you to verify your identity directly even when using an Authorized Agent, unless a power of attorney has been provided. We reserve the right to deny a request submitted by you or an agent if suitable and appropriate proof is not provided. Please see “Additional Region Specific Disclosures” below for further details.
Your Opt-Out Choices
We may use your information to offer you a wide range of financial services and products that may be of value to you. However, if you do not wish us to communicate marketing offers to you, or you want to unsubscribe from our emails, including blog posts, you can notify us at any time as described under the section “How To Contact Us” and we will remove your information from our marketing/email database. We do not discriminate against individuals who have opted out of receiving marketing offers or who otherwise exercise their privacy rights.
XI. Children’s Privacy
We do not offer our services to anyone under the age of 18.
XII. Links to Other Websites
XIII. Additional Region-Specific Disclosures
For the purposes of the European General Data Protection Regulation (GDPR), the Data Controller of your personal information is Western Asset Management Company Limited located at 10 Exchange Square, Primrose Street, London, EC2A 2EN. Telephone: +44 (0)20 7422 3000, Fax: +44 (0)20 7422 3100, Email: email@example.com.
You may have the right to lodge a complaint with a supervisory authority, in particular, in the EU Member State of your habitual residence, place of work or place of the alleged infringement. The lead Supervisory Authority is the Information Commissioner’s Office (ICO) which can be contacted via its hotline +44 (0)303 123 1113 or through the Concerns section of its website, https://ico.org.uk/concerns/.
“Shine the Light” Disclosure
In response, we will provide a list of the categories of “Personal Information”, as that term is defined by California Civil Code Section 1798.83, disclosed to third parties for direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email or mailing addresses specified in this section.
The contact for complaints and inquiries about personal information handling is as follows:
Western Asset Management Company Ltd
Attention: Legal & Compliance Department
Shin Marunouchi Building 36th Fl., 1-5-1 Marunouchi, Chiyoda-ku Tokyo 100-6536
The names of Registered Personal Information Protection Group and Contact Information for Complaint Resolution is as follows:
Japan Investment Advisors Association
Business Complaint Support Center (Staff in Charge of Personal Information)
Shouken Kaikan 7th Fl., 5-8 NihonbashiKayaba-cho 1-Chome, Chuo-ku, Tokyo
Postal Code 103-0025
Office hours: Monday – Friday (excluding holidays) 9 AM – 5 PM
Investment Trust Association, Japan
Office of Investors Inquire
Tokyo Stock Exchange Building 6th Fl., 2-1 NihonbashiKabuto-cho, Chuo-ku, Tokyo
Postal Code 103-0026
Office hours: Monday – Friday (excluding holidays) 9 AM – 11:30 AM 0:30 PM – 5 PM
XV. How to Contact Us
Western Asset Management Company, LLC
Attn: Legal and Compliance
385 East Colorado Blvd.
Pasadena, CA 91101
Western Asset Management Company Limited
Attn: GDPR Team
10 Exchange Square, Primrose Street
London, EC2A 2EN
Western Asset Management Company Pty Ltd
Attn: Privacy Officer
Level 48, 120 Collins Street
Melbourne VIC 3000
Western Asset Management Company Distribuidora de Títulos e Valores Mobiliários Limitada
Attn: Legal & Compliance Department
Av. Presidente Juscelino Kubitschek
1455 - 15º andar
04543-011 – São Paulo
SP - Brazil
Western Asset Management Company Ltd
Attn: Legal & Compliance Department
Shin Marunouchi Building 36th Fl., 1-5-1 Marunouchi, Chiyoda-ku, Tokyo 100-6536
Western Asset Management Company Pte. Ltd.
Attn: Data Protection Officer
1 George Street, #23-01