This privacy notice (“Privacy Notice”) applies to individuals (“Data Subject”, “you”, and “yours”) whose personal data may be processed by Arrowstreet because of your business relationship to or with one or more of Arrowstreet’s clients or prospective clients. 

Arrowstreet is responsible for ensuring that your personal data described below is being treated in accordance with applicable data protection laws, including but not limited to the General Data Protection Regulation 2016/679 (“GDPR”) and the UK Data Protection Act 2018 (collectively referred to as the “Data Protection Laws”). In this context, Arrowstreet Capital, Limited Partnership is data controller with respect to such personal data.

This Privacy Notice describes the types of personal data Arrowstreet may collect and process, and/or instruct other parties to process on our behalf, as well as the basis and purpose for which Arrowstreet may process such personal data from time to time. This Privacy Notice also describes your rights under applicable Data Protection Laws, and how to contact us if you would like more information or to request a copy of your personal data.

For the reasons described in the next section of this Privacy Notice, from time to time Arrowstreet may collect, generate, and/or otherwise process the following types of personal data:

1.  Information that you directly provide to us.
   
   • Any information about you that you provide us by communicating with us, whether face-to-face, by phone, e-mail or otherwise. This information may include, for example, your full name, title, business address, company affiliation, country of domicile, email address, and telephone number. 

1. • In connection with inviting you to attend an Arrowstreet client event, we may request health information such as whether you have any food allergies or require any other specific physical accommodations.
2.  Information that we collect or generate about you.
   •  This information may include, for example, your full name, title, business address, company affiliation, country of domicile, email address, telephone number, notes describing our communications with you, and any of your personal data you may choose to disclose to us in writing (which may be via email) or verbally.
3. Information about you that we obtain from other sources.
   •  Arrowstreet engages a third party service provider to conduct legally required due diligence checks on certain individuals in accordance with applicable law. The data we obtain includes information that helps identify you (e.g., your name; alias (if any) age; date of birth; gender; country of residence; passport details; citizenship). Depending upon the specific facts and circumstances of your particular business relationship to or with one or more of Arrowstreet’s clients or prospective clients, we may also obtain the following types of personal data:
     •  Personal identification numbers (e.g., social security numbers; national insurance numbers) that are Public Domain Data.
     • Family circumstances information (e.g., your marital status and dependents) if you are a PEP or a close associate of a PEP.
     • Employment/role and education details (e.g., the organization(s) you work/have worked for, public roles (including political, diplomatic, religious, judicial, military and trade union roles), your job title and your education history).
     • Professional and personal affiliations (e.g., organizations (including sanctioned vessels and aircraft) and individuals that you may be associated with in your professional or personal capacity).
     • Financial information relevant to understanding your income or wealth (e.g., bankruptcy or insolvency filings).
     • Your inclusion (if any) on sanctions lists or on public lists of disqualified directors or other positions of responsibility.
     • Public Domain Data about actual or alleged money laundering or terrorist financing crime, or crimes that are a pre-cursor to money laundering or terrorist financing which are also known as predicate offences (e.g., financial crime, illegal trafficking, environmental offences, smuggling, membership of an organized crime group).
     • Your postings on website, blogs or social media applications.
     • In some cases, the personal data available from our service provider may include so-called “sensitive” or “special categories” of personal information, or such information can be reasonably inferred from other information. This could include, e.g., information relating to your political opinions, sexual orientation, religious beliefs, racial or ethnic origin, or trade union membership. Please review the Refinitiv (LSEG) WorldCheck Privacy Notice for more detail.

Arrowstreet collects and processes your personal data for the following purposes:

• To provide the services described in the relevant investment management agreement, subscription agreement, and/or any other product-specific offering documents, or in connection with entering into such agreement(s);
• To provide information about Arrowstreet’s other products and services, unless you have indicated otherwise;
• To perform AML/KYC and other due diligence checks as required by applicable laws and regulations as a result of your professional relationship with one or more of Arrowstreet’s clients or prospective clients, and to comply with other applicable laws and regulations, including, to the extent necessary, in connection with any official legal proceedings;
• To perform and/or deliver client reporting with respect to the services described in the relevant investment management agreement, subscription agreement, and/or any other product-specific offering documents; and/or
• To service our clients’ account(s) as may be appropriate from time in connection with fulfilling our contractual obligations to provide the services described in such agreement.

We may need to disclose your personal data to the following categories of recipients:

• To third party service providers Arrowstreet has engaged to provide us with various services including, for example, assistance with fulfilling our various legal and regulatory obligations (such as the screening tool we use to conduct AML/KYC checks)
  •  Your personal data is disclosed to this type of recipient only as necessary for Arrowstreet to obtain the services from its third party provider.
  • These third parties are subject to legally binding confidentiality requirements with respect to any such personal data or other information we provide to them for this purpose, and they are only permitted to process your personal data as described in this privacy notice.
•  To applicable regulatory authorities or judicial courts, to the extent required by applicable law or court order.
  •  Your personal data is disclosed to this type of recipient only if we are under a duty to disclose your personal data in order to comply with any legal obligation, or as necessary in order to establish, exercise or defend our legal rights.
  • To the extent permitted under applicable laws and regulations, and/or to the extent it is legally possible to do so under the specific facts and circumstances, Arrowstreet will seek to obtain confidential treatment of any such data. 

The personal data that we collect from or about you may be transferred to, stored within, or processed in a country outside of the European Economic Area (“EEA”) and/or the United Kingdom (“UK”). In particular, your personal data may be processed by Arrowstreet staff in the United States, and/or your personal data may be transferred to and processed by certain of our third party service providers in the United States.

We are required to ensure that any transfers of your personal data to recipients outside the EEA/UK are compliant with applicable Data Protection Law, such that that your personal data remains protected in a manner that is consistent with how Arrowstreet protects your personal data in the EEA/UK. This may be done in a number of ways. For example, we may transfer your personal data to a country or recipient on the basis of an adequacy decision issued by the European Commission in accordance with Article 45.3 of GDPR, or pursuant to a “model contractual clause” or “form of international data transfer agreement” approved by the European Commission or the UK Government (as applicable). These are legally binding agreements executed between Arrowstreet and the recipient of your personal data, which require the recipient to protect your personal data in a manner consistent with applicable Data Protection Law. 

In certain circumstances, applicable law may otherwise permit us to transfer your personal data outside the EEA/UK. In all cases, however, we will ensure that any such transfer of your personal data complies with applicable Data Protection Law.

You can obtain more detail regarding the protection given to your personal data when it is transferred outside the EEA/UK (including, as applicable, a copy of the legally binding agreement(s) described above) by contacting us at the details below.

The length of time for which we may continue to store and process your personal data will vary. The retention period will be determined by various criteria:

•  The purpose(s), for which we are using your personal data, as detailed above.
  • We will need to keep the data for as long as is necessary for that purpose.
• Our legal and regulatory obligations.
  •  Laws or regulations may set a minimum period for which we are required to retain your personal data.

You have a number of legal rights in relation to the personal data that we hold about you. These rights include:

• the right to obtain additional information regarding our processing of your personal data, and access to your personal data that we process;
• the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so;
• in certain circumstances, the right to receive a copy of certain personal data that we process, in a structured, commonly used and machine readable format, and/or the right to request that we transmit your personal data to a third party where this is technically feasible. Please note, however, that this right only applies to personal data which you have provided to us directly;
• the right to request that we rectify and correct your personal data if it is inaccurate or incomplete;
• in certain circumstances, the right to request that we erase your personal data. Please note, however, that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
• in certain circumstances, the right to object to, and the right to request that we restrict, our processing of your personal data. Please note, however, that there may be circumstances where you object to, or ask us to restrict, our processing of your personal data, but we are legally entitled (or otherwise required by applicable law) to continue processing your personal data, and / or to refuse such a request; and
• the right to lodge a complaint with the relevant national data protection regulator (details of which are provided below) if you think that we have infringed upon any of the rights you are entitled to, under applicable Data Protection Law.

You can exercise your rights by contacting us using the details set out in the “Contacting us” section below.
You can find out more information about your rights by contacting the Information Commissioner’s Office, or by searching their website at https://ico.org.uk/.

If you would like further information about Arrowstreet’s collection, use, disclosure, transfer or processing of your personal data, or to exercise of any of your legal rights described above, please address any questions, comments and requests to [email protected].