Privacy & Cookie Policy

Safeguarding your private information is very important to us at BrightSphere Investment Group (“BSIG”). This Privacy & Cookie Policy (“Privacy Policy”) describes the types of information that we collect about you as a user of our websites, the purposes for which we use the information and the circumstances in which we share such information.

BSIG has in place a comprehensive information security and privacy program design to ensure sensitive data is protected. The program includes proper oversight and resources dedicated to risk identification, protection, detection and incident response. Information security is managed as a critical priority with active monitoring and management of current and emerging risks.

This Privacy Policy applies to bsig.com and ir.bsig.com (collectively, the “Site”). Please note that other, more specific policies may be available to you on websites through which you transact with one of our affiliated companies (“Affiliates”). BrightSphere Inc., a subsidiary of BSIG, reserves the right to change this Privacy Policy at any time.

Our Web Site

This Site does not directly collect any personal information or data. Unless you voluntarily provide personal data, as defined by the European Union’s General Data Protection Regulation (“GDPR Personal Data”), your Site visit will be anonymous. GDPR Personal Data includes your name, address, precise location, phone number or any other information relating to an identified or identifiable natural person. If submitted, only our employees and service providers who need your GDPR Personal Data to provide services to you have access to the data.

In addition, BSIG automatically collects and aggregates information about visitors to the Site for purposes of improving its design and content. This information includes, but is not limited to, how many people visit the site, which page(s) they visit, their IP addresses and which browser and operating system they use.

Use of Cookies

We use cookies for website viewing session management or to analyze Site usage. Cookies are small text files that are placed on your computer or device by websites you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Our Site automatically collects information from a user's computer using cookies which provides us with limited user information. We use this data primarily for the following purposes:

  • enhance and personalize aspects of our service;
  • show that a user has read any relevant legal information;
  • analyze how our site is used.

The table below explains all the cookies we use and why:

Cookie Name Purpose Website Using These
Tracking and Analytics _ga
_gat
_gat_Client
_gid
These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. www.bsig.com
ir.bsig.com

By using this website, you consent to the use of cookies.

Most web browsers allow control of most cookies through the browser settings. If at any time you wish to withdraw your consent for cookie usage, please delete the cookies generated by our Site from your browser. Please note that deleting any of these cookies may result in you not being able to enter or use all of the features of our Site.

In Our Marketing, Distribution and Servicing Role

If you choose to provide us with any GDPR Personal Data, the data will be used for the purpose for which you provided it to us. Occasionally, BSIG gathers GDPR Personal Data of active or potential clients with respect to marketing initiatives, employees of Affiliates and/or to comply with regulatory, legal or contractual obligations. In most cases the types of GDPR Personal Data we collect directly is limited to professional contact information. However, other types of background check information may be required in certain cases such as in the case of Anti-Money Laundering reviews.

We collect, store and use GDPR Personal Data to conduct our business. From time to time, we share GDPR Personal Data among legal entities within BSIG and our Affiliates on a limited as needed basis to support our business and in accordance with this Privacy Policy. In all cases we keep it for as long as necessary to fulfil our business purposes and then delete it unless a longer retention period is required by applicable law.

GDPR Personal Data is shared with third parties as necessary who provide professional services to us such as external auditors, legal advisors and other service providers who are utilized to support our core business operations.

Sharing GDPR Personal Data requires the transfer of the data outside the European Economic Area to BSIG Companies in the United States and other locations. All transfers are subject to appropriate industry standard safeguards which in most cases include standard data protection clauses adopted by the European Commission.

If you have any questions regarding this notice or our Privacy Policy or about the personal information we track related to you, please contact us via email at info@bsig.com.

If you would like to be removed from future communications and/or have your GDPR personal data removed from our systems, please email us at unsubscribe@bsig.com.

California Residents

California residents should be aware that this section does not apply to: Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act and its implementing regulations, the California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994; or other information subject to a California Consumer Privacy Act (“CCPA”) exception.

Notice of Collection and Use of Personal Information:

"Personal Information" is data that identifies, relates to, describes, is capable of being associated with, or may reasonably be linked, directly or indirectly, with a particular Consumer or household. We may collect the following categories of personal information about you online or offline:

  • name, address including physical address, email address and Internet Protocol address;
  • telephone number and personal information provided in connection with account access;
  • Commercial information, such as account data;
  • Professional or employment-related information;
  • Education information;
  • Internet or other electronic network activity information, such as Site usage (e.g., cookies, browsing history and/or search history).

We use the categories of Personal Information listed above for the business purposes described within this Privacy Policy.

Disclosure of Personal Information

We may have collected and disclosed your Personal Information during the 12-month period prior to the effective date of this California Consumer Privacy Statement for business purposes as describe the Privacy Policy.

We have not sold Personal Information in the twelve months preceding the date of the current Privacy Notice.

California Consumer Privacy Rights

If you are a resident of California, you have certain rights in relation to your Personal Information pursuant to the CCPA. These include your right to:

  • Request information about the Personal Information that we collect about you and the manner in which we process and disclose that information;
  • Obtain the specific pieces of Personal Information that we have collected about you in the 12 months preceding your request;
  • Delete certain Personal Information that we have collected about you;
  • Opt-out of disclosures of your Personal Information to third parties under certain circumstances; and
  • Not be discriminated against as a result of exercising any of the aforementioned rights.

If you would like to discuss or exercise such rights, please contact us at info@bsig.com or at (617) 369-7300.

California law requires us to verify the requests we receive from you when you exercise certain of the rights listed above. To verify your request, we will require specific information from you to help us verify your identity and process your request. If we do not have information that permits us to verify your identity, your requests to know or delete may be denied.

You may also designate an authorized agent to exercise certain of the rights listed above on your behalf by providing the authorized agent with power of attorney pursuant to the California Probate Code. If an authorized agent submits a request on your behalf, we will contact you to verify that they represent you.

California law requires that we describe certain disclosures of personal information where we receive valuable consideration. California law treats such disclosures as “sales” even if no money is exchanged. We do not sell information to third parties as defined under California law. We do not sell the personal information of minors under 16 years of age.


BrightSphere International Ltd information:


Job Applicants

Any personal data that you submit to BrightSphere International Ltd “BSI” for the purpose of applying for employment will be used for the purpose of matching you to current or future job vacancies at BSI. We will store your personal data securely and only share it within the organisation with those individuals involved in the recruitment process and for the purposes of assessing your suitability for a position with BSI. We will only disclose your personal data outside of the organisation if we reasonably believe we are obliged to do so for legal reasons e.g. to HMRC for the purpose of tax collection or in connection with a criminal investigation.

By submitting your personal data you are consenting to your data being processed within third party software, including cloud based packages, on BSIG servers and by our staff. We are entitled to hold your personal data for the legitimate purpose of human resource management so if your application is successful and you become an employee your data will be transferred into our personnel system and files. In the event that your application is unsuccessful we will keep your personal data for 12 months after which time it will be destroyed.

How can I access the information you hold about me?

You have the right to request a copy of the information that we hold about you. If you would like to request a copy of some or all of your personal information (otherwise known as a Subject Access Request in the UK) please email us using the contact details noted below.

bsigcompliance@bsig.com

In the UK, we will have one month to provide you with the information (this can be extended by a further two months in case of complex or numerous requests that have you have made). We are obliged to verify your identity for this request and notify you within one month of any reason why our deadline to respond to your request may be triggered.

We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove/amend any information that you think is incorrect.

How long do we keep hold of your information?

We will retain your personal data for as long as permitted and required by the lawful basis upon which your personal information has been obtained. However, we are subject to regulatory requirements to retain data for specified minimum periods. You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests, as noted above.

What can you do if you are unhappy with how your personal data is processed?

You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is the Information Commissioner’s Office.

January 2020