California Consumer Privacy Notice

Last Updated: January 1, 2024

This notice is applicable to California residents only. For Western Asset’s main privacy policy, please click here.

Respecting your privacy is very important to us. This California Consumer Privacy Notice (“California Notice”) explains how Western Asset Management Company (“Western Asset”) collects, uses, retains, and discloses personal information relating to California residents who are subject to the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”). Unless otherwise stated, any terms defined in the CCPA have the same meaning when used in this California Notice.

This California Notice governs certain information that we collect about you both offline and online. The CCPA contains certain exceptions, including an exception for personal information that is collected, processed, sold, or disclosed subject to the federal Gramm Leach Bliley Act (“GLBA”) and implementing regulations, and so the privacy rights set out herein may not apply to you or to all of your personal information. For example, information that we collect when providing financial products or services to you is not covered by the CCPA or this California Notice. The disclosures in this California Notice govern our current practices and over the last twelve months.

Categories of Personal Information We Collect
We may collect (and may have collected during the 12-month period prior to the date of this California Notice) the following categories of personal information about you:

Contact information, such as your name, email address, phone number, or address.
Employment information related to your role as an employee, such as your employer or company’s name, location, job title, etc.
Financial and transaction-related information, such as account numbers, bank information, transaction history, assets under management, etc.
Location-related information, such as your physical or device location.
Images, recordings, or biometric information, such as audio recordings, CCTV/video recordings, or photographs.
Inferences or profile information.
Internet activity, such as website cookie information, device ID, IP address, browsing activity, etc.
User account information, such as your account login ID, password, account age, etc.

Purposes for Collection of Your Personal Information
Western Asset has collected the categories of personal information for the business purposes listed below.

To provide the information, product or service requested by the individual or as reasonably expected given the context in which the personal information was collected.
Completing a transaction for which the personal information was collected, providing a product or service requested by you, taking actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise performing our contract(s) with you.
Data analytics to improve the services and products we offer, to learn about the interests of visitors to our websites for marketing purposes like identifying prospective clients.
Complying with a legal obligation, including our records retention obligations, to answer subpoenas or requests from our regulators.
To de-identify the data or create aggregated datasets for analytical purposes.
For business continuity and disaster recovery purposes.
Statistical monitoring, including estimating our audience size and usage patterns, store information about your preferences and recognize you when you visit our website.
Communications notifying you about changes to our services or products.
In any other way we may describe when you provide the information, or otherwise at your direction or with your consent.
As permitted by law or as we may notify you.

Sources From Which We Collect Your Personal Information
We collect the categories of personal information set out above from the following sources:

Automatically or, where applicable, with your consent, when you visit our website or interact with emails you receive from us. We may receive such information directly from you or indirectly, such as from vendors we have engaged to assist us with website analytics, online tracking and advertising and other services.
Via our websites.
From communications with you.

Managing Your Digital Tracking Preferences
We use digital tracking technology on our website and in our marketing campaigns. This includes pixels, beacons, and cookies to collect from your computer or other connected device information about you, your internet and website activity, and your preferences. We collect this type of information from:

You and from your connected devices when you interact with our websites, online content, and mobile applications. For example, when you visit our website, our server logs record your IP address and other information.
Through digital tracking technologies such as cookies, pixels, and beacons.

We impose specific contractual obligations on service providers, third parties, and contractors before sharing or disclosing your personal and sensitive information in order to provide us the services we have hired them to perform, to protect it appropriate to its sensitivity, not to use it for their own purposes, collect further personal and sensitive information with respect to it, and to tell us if they cannot comply with such requirements and to allow us to make sure that they are complying with their obligations.

Your California Rights under the CCPA
As a California resident and consumer, you have certain rights in relation to your personal information under the CCPA as described below:

Right to Know: Requires that we inform you about the personal information and sensitive personal information we collect.
Right to Access: You have the right to request, twice in a 12-month period, that we disclose the categories of personal information we have collected, the categories of sources from which the personal information is collected, the purpose for collecting personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
Right to Correct: You have the right to request that we correct the personal information we maintain about you if that information is inaccurate.
Right to Delete: You may have the right to request that we delete your personal information that we have collected or received. Subject to certain exceptions, we must delete your personal information and direct our service providers and contractors to do the same.
Right to Object/Opt-Out of Sale or Sharing: If we were to “share” your personal information for purposes of “cross-context behavioral advertising” as such terms are defined in the CCPA, you would have the right to opt-out of the sharing of your personal information. Regardless, we recognize that the use of third-party providers for certain marketing activities may be considered a “sale” or “sharing” under the CCPA. Western Asset does not sell your personal information or share your personal information for cross-context behavioral advertising purposes as defined under the CCPA.
Right to Limit Use and Disclosure of Sensitive Personal Information: Subject to certain exceptions, you may have the right to limit our use and disclosure of your sensitive personal information. We do not collect sensitive personal information from you pursuant to this California Notice.
Right to Not Discriminate: We will not discriminate against those who exercise any rights.

How to Exercise Your California Privacy Rights
To exercise the rights described above, please submit a request by:
Phone: (626) 844-9400 or Toll-Free (844) 905-0999
Email: dataprotection@westernasset.com
Mail: 385 East Colorado Blvd., Pasadena, CA 91101 Attn: Privacy Team

Responding and Verifying Your Request
When you make a request, we will first take steps to verify that it is really you who is making the request. To verify your request, we may request that you provide us with additional documentation to verify your identity and may decline your request if we are unable to verify your identity. Once we have verified your request, we will provide information from our records for the preceding 12 months. We aim to promptly verify your requests and respond to your requests within 45 days of receipt but may require up to 90 days to respond.

Appointing an Authorized Agent
The CCPA allows you to authorize a person (“Authorized Agent”) registered with the California Secretary of State to exercise your California privacy rights on your behalf. An Authorized Agent can also include a person who has power of attorney or is acting as a conservator. To submit a request on behalf of another person as an Authorized Agent, please submit a request to us by mail, phone or email provided above.

Retention Periods
Western Asset will retain your personal information for the duration of your relationship with us unless a different retention period is required by applicable law. We will retain your personal information for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

Personal Information About Minors
Our website is neither intended for, nor targeted at children under 18, and we do not collect personal information directly from children under 18. We receive limited personal information about children from parents/guardians and other responsible adults only as required to establish and maintain accounts for the child’s benefit. Additionally, Western Asset does not sell the personal information of minors, nor do we direct targeted advertising to minors.

Limitations
As described above, the CCPA is not fully applicable to much of the personal information we collect from California residents. Therefore, even if you are a California resident and submit a verifiable request, we may not be required to comply with your request. For example, we are not required to comply with your “requests to know” more than twice in any 12-month period.

Updates to the California Notice
We may update this privacy notice periodically and any new version will be posted on our website. We recommend you review this notice regularly to ensure that you are aware of our current privacy practices.

Contact Us
If you would like further information regarding the collection or use of your personal information, please email is at dataprotection@westernaasset.com or call us at 626-844-9400 or Toll-Free at 844- 905-0999.