Causeway Capital Management LLC (“Causeway”) recognizes and respects the privacy concerns of its clients. Causeway collects nonpublic personal information about you in the course of doing business with you.
Causeway collects this information from the following sources:
- Information we receive from you or your representative on applications or other forms or from our website, and
- Information about your transactions with us and our service providers, or others, such as financial advisers, custodians or consultants.
The information Causeway may disclose.
Causeway only discloses nonpublic personal information we collect about our clients as permitted by law. For example, we may disclose nonpublic personal information about you to third parties such as:
- To government entities, in response to subpoenas or to comply with laws or regulations.
- When you direct us to do so or consent to the disclosure.
- To companies that perform necessary services for us, such as data processing companies, including Causeway’s third party service providers.
- To protect against fraud, or to collect unpaid debts.
Information about former clients.
If you decide to close your account(s), we will adhere to the privacy policies and practices described in this notice.
How Causeway safeguards information.
Causeway restricts access to nonpublic personal information about you to those persons who need to know that information to provide products and services to you or help Causeway meet its regulatory obligations. Causeway or its service providers maintain physical, electronic and procedural safeguards that comply with federal standards to guard your nonpublic personal information.
Should you have any questions regarding Causeway Capital Management LLC’s privacy policies and practices, please contact 310.231.6100.
Other information Causeway collects from you online.
Websites maintained by Causeway or its service providers may use a variety of technologies to collect information that help Causeway and its service providers understand how the website is used. Information collected from a client’s web browser (including small files stored on a client’s device that are commonly referred to as “cookies”) allow the websites to recognize a client’s web browser and help to personalize and improve a client’s user experience and enhance navigation of the website. In addition, Causeway or certain of its service providers may use third parties to place advertisements for Causeway products on other websites, including banner advertisements. Such third parties may collect anonymous information through the use of cookies or action tags (such as web beacons). The information these third parties collect is generally limited to technical and web navigation information, such as a client’s IP address, web pages visited and browser type, and does not include personally identifiable information such as name, address, phone number or email address. If a client is a registered user of Causeway’s website, Causeway or its service providers or third party firms engaged by Causeway or its service providers may collect or share the information you submit to us, which may include nonpublic personal information. This information can be useful to Causeway when assessing and offering services and website features for you. You may be able to change your cookie preferences by changing the setting on your web browser to delete or reject cookies. If you delete or reject cookies, some website pages may not function properly. Causeway does not look for or respond to web browser “do not track” requests.
CALIFORNIA RESIDENT RISK LENS PRIVACY NOTICE
Last revised: November 15, 2023
This California Resident Risk Lens Privacy Notice (“California Privacy Notice”) is only applicable to California residents. It is delivered by Causeway Capital Management LLC (“Causeway”, “we”, “us”, and “our”), being the entity which operates the Causeway Risk Lens financial analysis tool, and it governs certain personal information we collect from you.
We have adopted this California Privacy Notice to comply with the California Consumer Privacy Act, Cal. Civ. Code §§ 1798.100 et seq. (“CCPA”). Please take the time to read and understand this California Privacy Notice before submitting your information to us.
Scope
This California Privacy Notice covers personal information we collect from and about California residents in their capacity as users of Causeway Risk Lens. There is other personal information that this California Privacy Notice does not cover. In some cases, that personal information may not be subject to the CCPA. In other cases, a different privacy notice may apply. Accordingly, this California Privacy Notice and/or the California privacy rights set out herein may not apply to you or to all of your personal information.
By personal information we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, which includes “personal information” and “sensitive personal information” as those terms are defined in the CCPA. The following is not personal information for purposes of the CCPA: (i) “publicly available information”; (ii) lawfully obtained, truthful information that is a matter of public concern; (iii) “deidentified” consumer information about California residents; and (iv) “aggregate” consumer information about California residents (in each case, as those terms are used in the CCPA). This California Privacy Notice does not apply to such information.
Notice at Collection
The following table sets forth the categories of personal information we may collect from you as a business; the purposes for which we use it; and whether we “sell” or “share” it for purposes of the CCPA (as those terms are used in the CCPA). Our collection, use and disclosure of personal information depends on your relationship with us and your interaction with us. For information on our receipt of personal information as a third party, please see Third Party Processing below.
|
Category of Personal Information |
Purpose for Collecting the Personal Information |
Whether We “Share” the Category of Personal Information for Cross-Context Behavioral Advertising |
Whether we “Sell” the Category of Personal Information |
|---|---|---|---|
|
Identifiers and Categories in Cal. Civ. Code 1798.80(e), such as name, unique personal identifier, password, online identifier, account name, phone number or signature, email address |
|
No |
No |
|
Geolocation data, such as the state or country associated with your IP address, or home address |
|
No |
No |
|
Other personal information we receive from you or your representative on applications or other forms or from our website |
|
Data Retention: We will retain your personal information for as long as necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. To determine the appropriate retention period for your personal information and sensitive personal information, we will consider the amount, nature and sensitivity of the personal information, the potential risk from unauthorized use or disclosure, the purposes for which we process it and whether we can achieve those purposes through other means, and applicable legal requirements.
Prior Collection, Use and Disclosure of Personal Information
The CCPA requires us to give you specific information about the categories of personal information and sensitive personal information we collect about you, the sources from which we have obtained that information, the purposes for which we collect it and the categories of entities to whom we disclose it. Our relevant practices over the last twelve months are described below.
|
Category of Personal Information |
Categories of Sources From Which Collected |
Business or Commercial Purpose for Collecting PI |
Categories of Third Parties and Other Entities To Whom We May Disclose |
|---|---|---|---|
|
Identifiers and Categories in Cal. Civ. Code 1798.80(e), such as name, unique personal identifier, password, online identifier, account name, phone number or signature, email address |
|
|
|
|
Geolocation data, such as the state or country associated with your IP address, or home address |
|
|
|
|
Other personal information we receive from you or your representative on applications or other forms or from our website |
|
|
|
How We Disclose Personal Information
In the past twelve months, we have disclosed the following categories of personal information for business purposes as set out above:
- Identifiers
- Geolocation data
We Do Not Sell or “Share” Your Personal Information for Purposes of the CCPA
We do not “sell” your personal information for purposes of the CCPA or “share” it for purposes of cross-context behavioral advertising (as those terms are defined in the CCPA) and have not done so in the past twelve months.
Minors Under the Age of 16
We do not have actual knowledge that we sell or share the personal information of minors under the age of 16.
Your Rights as a California Resident
As a California resident, you may have certain rights in relation to your personal information.
Right to Know
You may have the right to know how we have collected, used and disclosed your personal information. Specifically, you may have the right to know:
- The categories of personal information we have collected about you.
- The categories of sources from which we have collected your personal information.
- The business or commercial purpose for which we collect, sell or share your personal information.
- The categories of third parties to whom we have disclosed your personal information.
- The categories of personal information that we have sold or shared about you and the categories of third parties to whom it was sold or shared.
- The categories of personal information we have disclosed about you for a business purpose and the categories of persons to whom we have disclosed it.
In addition, you may have the right to know the specific pieces of personal information we have collected about you.
Right to Make a Deletion Request
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 delete your personal information.
Right to Correct Inaccurate Personal Information
You may have the right to request that we correct inaccurate personal information about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
Right to Opt-Out of Sales of Personal Information
If we were to sell your personal information for purposes of the CCPA, you may have the right to opt-out of the sale of your personal information.
Right to Opt-Out of Sharing of Personal Information
If we were to share your personal information for cross-context behavioral advertising purposes for purposes of the CCPA, you may have the right to opt-out of that sharing.
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 use or disclose your sensitive personal information in a manner that gives rise to this right.
Right to Non-Discrimination
You have the right not to be discriminated against by us for choosing to exercise your rights under the CCPA.
How to Exercise Your California Privacy Rights
If you wish to exercise your right to know, delete or correct inaccuracies in your personal information, or your right to limit our use and disclosure of your sensitive personal information, please contact us at [email protected]. If you maintain an account with us, we may require you to submit a request through that account.
You can 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 to Causeway on behalf of another person as an Authorized Agent, please contact us at [email protected].
Verifying Your Requests
We only respond to your requests to know how we have collected, used and disclosed your personal information, access the specific pieces of personal information we have about you, delete your personal information or correct inaccurate personal information when we can verify that you are a California resident exercising your rights regarding your personal information.
We may need to ask you for personal information to verify your request so we can match it to the personal information we already have about you. We may also need to obtain additional information about you that we do not already have. If you provide us with new personal information that we do not already have about you, we will use it solely for the purpose of verifying your request. We will let you know via email if we need more information from you to verify your request. Please reply to our requests promptly.
We will communicate with you about your requests via email. We will use the email address you provided when submitting your request.
If we cannot verify your identity, we will let you know.
Responding To Your Requests
We aim to promptly verify and respond to your requests within 45 days of receipt but may require a total of up to 90 days to respond to your requests. If we require additional time beyond the initial 45 days after we receive your request, we will let you know within the first 45 days.
We do not ordinarily charge a fee for our response to your requests. However, we may do so to the extent your request(s) are excessive, repetitive, or manifestly unfounded. If we determine that charging a fee is warranted, we will let you know and will provide you with an estimate of the associated costs of responding to your request(s).
If we determine that we cannot or will not take the action that you requested, we will let you know. We will inform you of our reasons for not taking action and any rights you may have to appeal the decision.
Unless you tell us that you would like to receive a response via postal mail, we will respond to you via email regarding your requests to know and to access the specific pieces of personal information we have about you. We will contact you at the email address you provided when submitting your request(s). If you would like to receive responses to a request to know or access personal information via postal mail rather than email, please let us know when submitting your request(s).
Limitations
The CCPA does not apply in full to all 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.
We are only required to respond to certain requests twice in any twelve-month period. We are not required to provide you access to specific pieces of personal information more than twice in any twelve-month period. Similarly, we are not required to comply with your “requests to know” more than twice in any twelve-month period.
Changes to Our California Privacy Notice
From time to time, Causeway may update or revise this California Privacy Notice. If there are changes to the terms of this California Privacy Notice, documents containing the revised policy on the relevant website(s) will be updated.
Contacting us
If you would like further information on the collection or use of your personal information, please submit questions, comments and requests by contacting us at [email protected].
Updates to this privacy policy.
From time to time, Causeway may update or revise this privacy policy.
Last updated: November 15, 2023.
