Clarion Partners, LLC and its affiliates (“Clarion," “we", “us" or “our") are committed to safeguarding your privacy. The purpose of this notice (“Privacy Policy") is to inform individuals who invest or are interested in investing in any accounts managed or advised by Clarion, or other individuals who access the website (“you" or “your"), www.clarionpartners.com (the “Site"), of the types of information we collect on the Site, how we use such information and to whom and under what circumstances we may disclose it. This Privacy Policy intends to comply with all applicable law, including, not by way of limitation, General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA) and similar U.S. state consumer data privacy laws, and notice and disclosure regulations promulgated by the U.S. Securities and Exchange Commission under Regulation S-P. This Privacy policy applies only to this Site, and any other personal information obtained when you call, email, or otherwise communicate with Clarion. By accessing the Site on any computer, mobile phone, tablet, or other device or otherwise interacting with Clarion, you agree to the terms of this Privacy Policy. If you do not agree to the policy, please do not use the Site.
We may modify this Privacy Policy at any time and will post the current version on the Site. We encourage you to periodically review our Privacy Policy to stay informed about how we are using the information we collect.
Personal Information That We Collect
We collect personal information from you when you submit it to us during your interactions with us, including when you contact us online, by phone, or in other communications. This information may include your contact information (e.g., your full name, company name, telephone number, business and/or personal email address). We may collect the same type of information about you from third parties such as our business partners and service providers.
When you visit the Site, we may collect certain information from you, including your Internet Protocol (IP) address, approximate geolocation, MAC address, browser type, operating system, device-identifying information, the specific web pages visited during your connection, and the domain name from which you accessed the Site.
In addition, we may collect information about your browsing behavior, such as the date and time you visit the Site, the areas or pages of the Site that you visit, the amount of time you spend viewing the Site, the number of times you return to the Site and other clickstream data. We may also use non-personal or aggregated information for statistical analysis, research, and other purposes. Like many commercial websites, we analyze how visitors use our Site through cookies, pixels, or other similar online tracking technologies. A cookie is a small text file that is placed on your computer when you access the Site and allows us to recognize you each time you visit the Site and improve your experience with the Site. We and our third-party providers may use these technologies on our Site to track your online activity over time and across third-party websites, including the website that you came from before visiting our Site and the website you go to after leaving our Site. Our Site does not currently respond to Do Not Track “DNT" signals, however it may recognize and process other opt-out preference signals, such as the Global Privacy Control (“GPC") signal. Additionally, your browser may provide additional tools to reject cookies. You can manually delete individual cookies or all of the cookies on your computer by following your browser's help file directions or privacy settings. Please note that, by rejecting cookies, some of the pages and features on our Site may not function properly.
You can find more information about the types of cookies we use on our website in this
cookie register.
Use of Personal Information
We may use the personal information we collect from and about you for any of the following purposes: (1) to provide, analyze, and improve our Site and services and develop future offerings; (2) to respond to your inquiries; (3) to enhance or personalize your experience with the Site or services; (4) monitor, manage, and protect the Site; (5) to retain records of our business transactions and communications; (6) for compliance with legal and regulatory requirement; (7) in connection with actual or potential litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving us or our clients; (8) to operate our Site efficiently and improve our service to you; and (9) any other legitimate business interests.
Disclosure of Personal Information
We may disclose personal information about you to third parties as permitted by law and in accordance with any applicable governing agreement, if applicable, including: (1) service providers to our investment funds, such as accounting, legal or tax preparation services; (2) partners and potential investors in our investment funds; and (3) transfer agents, portfolio companies, brokerage firms and others, in connection with distributions to our limited partners (4) third-party vendors that support our operations, including data analytics firms and advertising networks or platforms, and (5) among our corporate family.
We may also disclose personal information about you as necessary (1) if we believe that there has been a violation of this Privacy Policy or of our rights or the rights of any third party; (2) to respond to legal process (such as a search warrant, subpoena or court order) and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law; and (3) in the event that Clarion or substantially all of its assets are acquired, personal information about you may be one of the transferred assets.
We may also disclose personal information about you with your express consent. We may share aggregate, non-personally identifiable information about Site users with third parties.
Retention of Personal Information
Personal information that we collect, access, or process will be retained only as long as reasonably necessary for the fulfilment of the purposes for which it was collected, unless otherwise provided in agreements between you and Clarion or as required or authorized by law. Personal information that is no longer required to fulfill the identified purposes will be destroyed, erased, or de-identified.
Security
We maintain reasonable and appropriate measures designed to maintain information we collect in a secure manner. We have taken reasonable physical, electronic, and administrative steps to safeguard and secure the information we collect from visitors to the Site. Even though we follow reasonable procedures to try to protect the information in our possession, no security system is perfect and we cannot promise, and you should not expect, that your information will be secure in all circumstances.
Children
We do not knowingly request personal information from anyone under the age of 18. Our Site is not targeted to or intended for use by children. However, if we learn that we have received personal information from a child under the age of 18 without appropriate parental consent, we will delete that information from our database.
Data Subject Rights
You may have the rights (“Data Subject Rights”) with respect to the personal information that we collect or process about you, however, these rights differ depending on your country or state of residence, including, not by way of limitation, the European Union, the United Kingdom, California, Virginia, Colorado, Connecticut, Utah, and Nevada. Please note that we reserve the right to honor your Data Subject Rights to the extent required by applicable law.
- Right to Confirm Processing, Access, and/or Obtain a Copy (referred to in some countries as a Data Subject Access Request): If you ask us, we will confirm whether we are processing personal information about you. Additionally, upon request, we will provide you with a copy of all personal information you are lawfully entitled to receive, potentially including specific pieces of information, along with certain other details.
Right to Amend: If you believe personal information about you is inaccurate or incomplete, you may request that we correct it.
Right to Delete: You may request that we delete personal information about you, subject to certain exceptions as prescribed by applicable law.
Right of Portability: You may request that we move, copy, or transfer the personal information that we hold about you to another organization.
Right to Opt Out of Certain Processing Activities: You may ask us to restrict or stop the processing of personal information about you. This includes general requests and requests in specific contexts, such as if we process personal information that is considered “sensitive” under applicable U.S. state laws or engage in certain automated decision-making activities.
Right to Opt Out of Targeted Advertising: Targeted advertising is the practice of serving you tailored advertisements based personal information about you gathered over time and across other businesses, websites, applications, or services. We do not currently engage in this practice.
Right to Opt Out of Sales: Some states may consider targeted advertising a “sale” of personal information. You may request that we not “sell” personal information about you. We do not currently engage in this practice.
Right to Non-Discrimination: We will not discriminate against you for exercising Data Subject Rights, but we may charge a reasonable fee as permitted by law in fulfilling these rights, such as if you request multiple copies of personal information about you.
Right to Appeal: If we deny your request to exercise a Data Subject Right, you may have the right to appeal the decision with us. If you would like to appeal a prior decision, please be sure to include information about your prior request so that we may locate our earlier determination.
Right to Lodge a Complaint: You may submit a complaint to the competent supervisory authority in the country in which you live if you have any concerns about our processing of personal information about you.
If you or your authorized agents would like to exercise a Data Subject Right, you may do so by following the instructions in “How do I contact you?” below.
When you exercise these Data Subject Rights and submit a request to us, we may ask for your email address, telephone number, or other information in order to verify your identity. We also may use a third-party verification provider to verify your identity.
Additional Disclosures for California Residents
If you reside in California, please read this section for additional disclosures about how we collect, use, and disclose information about you under the California Consumer Privacy Act (“CCPA”).
Categories of Personal Information Collected: In the previous 12 months, we have collected the personal information listed in the section
Personal Information That We Collect, above. This information falls into the following categories under the CCPA: identifiers; categories of personal information described in Cal. Civ. Code 1798.80(e); commercial information; geolocation information; audio, electronic, or visual information; internet or electronic network activity information; employment or professional information; inferences drawn from the above categories. Additionally, we collect the following “sensitive" personal information: account credentials and contents of messages that you send to our customer service providers.
Sensitive Personal Information Uses or Disclosures: We do not use or disclose “sensitive" personal information for purposes other than those specified by the CCPA.
Business or Commercial Purpose for Collecting Information: We collect personal information for the business and commercial purposes described in
Use of Personal Information, above.
Categories of Sources of Personal Information: We collect personal information from and about you as described in
Personal Information That We Collect, above. These sources are: directly from you, automatically from you, corporate affiliates, service providers, data analytics providers, and other third parties.
Categories of Third Parties with Whom We Disclose Information: We may disclose personal information about you with third parties as described in
Disclosure of Personal Information, above.
Categories of Personal Information Disclosed: In the preceding 12 months, we have disclosed the categories of personal information listed in
Personal Information That We Collect for the reasons described in
Use of Personal Information and
Disclosure of Personal Information, above.
We do not currently “sell" or “share" personal information about you as defined by the CCPA. Accordingly, we do not have actual knowledge that we sell or share the personal information of consumers under the age of 16 years old.
Your Nevada Rights
2019 Nev. L. 211 permits customers of Company who are Nevada residents to request that we not sell their personal information. We do not sell personal information as defined by Nevada law. If you are a resident of Nevada and would like to request that we not sell information about you in the future, please contact us following the instructions below.
Additional Information for Residents of the European Economic Area and the United Kingdom
For personal information subject to the General Data Protection Regulation (“GDPR"), we will not collect or process that information unless we have a lawful basis to do so under the GDPR. The principal lawful bases that we rely on include:
Legitimate interests: We process personal information about you in connection with meeting our legitimate business objectives (such as those listed above) or those of a third party. We balance those interests against any risks to your rights from our data processing activities and do not pursue any data processing where the potential harm to your rights outweighs our legitimate interests.
Performance of a contract: We process personal information to the extent necessary to perform our obligations under a contract with you or your organization, or if requested by you or your organization to enter into a contract with us.
Legal obligation: We may need to process personal information to comply with a law or legal process to which we are subject.
Consent: If we rely on consent as a lawful basis for processing personal information about you, we will obtain your consent before processing personal information about you for one or more specific purposes. You are free to withdraw your consent at any time.
Changes to This Privacy Policy
We may change this Privacy Policy from time to time, including as required to keep current with rules and regulations, new technologies and security standards. When we do, we will post the change(s) on our Site and indicate an effective date. If we change this Privacy Policy in a material and retroactive manner, we will provide appropriate notice to you.
Visitors from Outside the United States—Cross-Border Transfer
The Site is hosted in the United States. If you are visiting the Site from outside the United States, information about you may be transferred to, stored, and processed in the United States or other countries in accordance with this Privacy Policy. The data protection and other applicable laws of the United States or other countries may not be as comprehensive as those laws or regulations in your country or may otherwise differ from the data protection or consumer protection laws in your country. Information about you may be available to government authorities under lawful orders and law applicable in such jurisdictions. By using the Site and/or providing personal information to us, you consent to transfer of information about you to our facilities as described in this Privacy Policy.
Right to Lodge Complaints
We are transparent about the ways in which we collect and use personal information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle personal information about you, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or the United States. You may contact the U.S. Federal Trade Commission regarding your concerns. For more information, please see
https://www.ftc.gov/faq/consumer-protection/submit-consumer-complaint-ftc.
Contact Us
If you have questions or concerns about this Privacy Policy, or would like to submit a Data Subject Rights request, you can contact us by using
this form, emailing us at
[email protected], or by telephone at +1-212-883-2500.
Additional Information for Job Applicants
This section supplements the information provided above and describes the additional personal information we collect when you apply for a job with us. We may collect the personal information in the below list in the following ways: directly from you; from publicly available sources, such as government entities, public records systems, and social media networks; data analytics providers and data brokers; or as you may otherwise authorize, such as a former employers or references.
Please note if you use our Site in the job application process, additional information is collected, as described above. We may collect the personal information categories listed in Cal. Civ. Code § 1798.80(e) (the California Customer Records Statute) in addition to the categories of personal information listed below. Items with an asterisk (*) may be considered “sensitive" personal information according to the CCPA.
Identifiers*: Government-issued identification numbers, including your Social Security, driver's license, passport, state identification card, or military identification card numbers.
Demographics and Protected Classifications*: citizenship, gender, data of birth, age, and other traditionally protected classifications that you chose to disclose, such as race and ethnicity, marital status, sexual orientation, veteran or military status, disability, and medical status.
Professional or Employment Related Information: professional associations and employment history, including name of employer, position, employer contact information, and associated employment records.
Educational Information: educational institutions attended, degrees and certifications attained, and other educational or student records, which may include details about attendance, grades, and academic and disciplinary history.
We generally collect this personal information in order to evaluate your application for employment. For more details about how we use and disclose the personal information listed here, please refer to
Use of Personal Information and
Disclosure of Personal Information above.