Last Updated: December 31, 2019
The California Consumer Privacy Act of 2018 (“CCPA”) gives California consumers certain privacy rights related to their personal information. This document describes the rights that California consumers may have under the CCPA.
- Publicly available information from government records.
- De-identified or aggregated information.
- Other regulated information that is excluded from the CCPA’s scope, such as personal information covered by certain sector-specific privacy laws, including the GLBA (which includes rules implementing the GLBA, such as Regulation S-P, which governs the privacy requirements of investment advisers under the GLBA).
- HOW WE COLLECT, USE, AND SHARE PERSONAL INFORMATION
|Category of Personal Information Collected||Categories of Source(s) from which Personal Information Was Collected||Business or Commercial Purpose(s) for which Personal Information Was Collected or Used||Categories of Third Parties with whom Personal Information Was Shared|
Personal Identifiers (such as name, postal address, phone number, email address) related to prospective investors and visitors to our website.
We obtain this information directly from prospective investors or their representatives when they seek information about our advisory services.
Contacting you or your designated representative (including by phone, email, fax, or mail).
Sharing information about our services with you, including investment research.
Providing you or your representative with marketing communications.
Fulfilling our legal and regulatory obligations.
Our affiliates for the purpose of operating our business and servicing your prospective account.
|Financial information (such as investment objectives and amount available to invest).||
Same as above.
Same as above.
Same as above.
Information from website browsing (such as Internet protocol (“IP”) addresses, browser type, Internet service provider (“ISP”), referring/exit pages, the files viewed on our site).
We may obtain this information automatically when you visit our website. This information could be captured using cookies or beacons. We may also use third-party web analytics services, such as Google Analytics.
Providing and improving our products and services, such as by personalizing content, offering and measuring campaigns and understanding user behavior. We also use this data to support information security and fraud prevention and detection.
We use Google Analytics to help us analyze how visitors use our website.
|Information captured by a third-party through automated means, such as Google Analytics, is collected directly.|
- NO SALE OF PERSONAL INFORMATION
- CCPA RIGHTS FOR CALIFORNIA CONSUMERS
The CCPA provides California consumers with certain rights with regard to their personal information. This Section explains those rights. If you are a California consumer and would like to exercise any of those rights, please see Section 4.E below for more information on how to submit a request.
A. RIGHT TO KNOW ABOUT AND ACCESS YOUR PERSONAL INFORMATION
If you are a California consumer, you may have the right to request that Fiera Capital provide you with information regarding what personal information about you we have collected, used, disclosed, or sold in the preceding twelve (12) months. Once we receive your request and verify your identity, we will disclose to you one or more of the following as requested:
- The categories of personal information we have collected about you in the preceding twelve (12) months.
- The categories of sources from which we collected your personal information in the preceding twelve (12) months.
- The business or commercial purposes for collecting your personal information in the preceding twelve (12) months.
- The categories of third parties with whom we shared your personal information in the preceding twelve (12) months.
- The specific pieces of personal information we collected about you in the preceding twelve (12) months.
You may only make a consumer request to know about or access your personal information twice within a twelve (12)-month period.
B. RIGHT TO DELETE YOUR PERSONAL INFORMATION
If you are a California consumer, you may have the right to request that Fiera Capital delete certain of your personal information that we have collected from you. However, this right to deletion does not apply to any of your personal information that is subject to an exception under the CCPA (as described below). Once we receive your request and verify your identity, we will delete (and direct our service providers to delete) your personal information in our records that is not subject to any of the CCPA exceptions.
We may deny your deletion request where your personal information is required for any of the following reasons, which we will identify in our response to you if we deny your request:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
C. RIGHT TO OPT-OUT OF THE SALE OF YOUR PERSONAL INFORMATION
D. PERSONAL INFORMATION FROM MINORS
We may collect personal information from minors for UGMA and UTMA custodial accounts. We follow all local legal requirements with respect to the collection and processing of a minor’s personal information.
E. RIGHT TO NON-DISCRIMINATION
Fiera Capital will not discriminate against any California consumer who exercises any of the rights described above. Specifically, except as permitted by the CCPA, we will not deny you goods or services; charge you different prices or rates, including through granting discounts or other benefits, or imposing penalties; provide you with a different level of service or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
F. HOW TO SUBMIT A REQUEST
If you are a California consumer and would like to exercise any of the CCPA rights identified above, you may submit a request by writing to PrivacyUS@fieracapital.com or by calling us at 866 227-9925.
G. SUBMITTING A REQUEST THROUGH YOUR AUTHORIZED AGENT
If you are a California consumer, you may have the option to designate an authorized agent to submit a request on your behalf, so long as the authorized agent has your written permission to do so and you have taken steps to verify your identity directly with us. If you would like to designate an agent, your agent must register as such with the California Secretary of State and submit a copy of this registration along with your consumer request to us. We may need to contact you directly to verify the request.
H. HOW WE VERIFY YOUR REQUEST
We cannot fulfill your request to provide you with or delete your personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us.
If you send us a request by calling the toll-free number or the dedicated privacy email address, we will contact you using the phone number or the email address that we have on file.
Depending on your type of request or the information requested by you, we may require additional information in order to verify your identity and fulfill your request. If we cannot successfully verify your identity, we will inform you of that fact.
In accordance with the CCPA, we will respond to your request within forty-five (45) days. However, in certain circumstances, we may require additional time to process your request, as permitted by the CCPA or other applicable law. We will advise you within forty-five (45) days after receiving your request if such an extension is necessary and why it is needed. Any disclosures we provide will only cover the twelve (12)-month period preceding our receipt of your request. If we cannot fulfill your request, our response to you will also explain the reason why we cannot fulfill your request.
We do not charge a fee to process or respond to your consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
I. CONTACT FOR MORE INFORMATION