Brandywine Global is required by applicable laws and regulation to provide this Privacy Notice to you. Brandywine Global operates in a number of jurisdictions around the world and as such is required to provide specific information to residents in those jurisdicitions. Our Global Policy below applies to all individuals that interact with Brandywine Global whether in person or through electronic communications, including our website. You should also click on the relevant link at the end of this Privacy Notice if you are resident in any of the jurisdictions listed for additional information.
It is the policy of Brandywine Global to institute appropriate procedures, processes, and systems to safeguard the integrity, confidentiality, and security of client (or potential client) non-publication information ("Non-Public Information"), and protect such information from unauthorized use or disclosure.
For the purpose of this policy, Non-Public Information at the highest level is information relating to clients and potential clients that is not publicly available. As a US based asset manager, this also includes any "non-public personal information" as defined in Regulation S-P. As a global asset manager, Brandywine Global may also be required to comply with data protection rules in other jurisdictions in which it operates or where clients, potential clients or other individuals interacting with Brandywine Global are based. These include Canada, the European Union, Singapore and the United Kingdom ("International Data Protection Rules").
Safeguarding Non-Public Information
In order to establish administrative, technical, and physical safeguards for the protection of Non-Public Information, Brandywine Global has adopted policies specific to information security and access control incorporated by reference herein; policy summaries are available upon request.
Disclosure of Non-Public Information to Non-Affiliated Third Parties
At a minimum, and subject to International Data Protection Rules, Non-Public information will not be disclosed to non-affiliated third parties, subject to the following exceptions:
- Non-Public Information may be disclosed to non-affiliated third parties to perform services on behalf of Brandywine Global if such non-affiliated third party has appropriate confidentiality provisions in place and has been subjected to scrutiny by Brandywine Global to understand the technical and physical safeguards in place to protect such information.
- Non-Public Information may be disclosed to non-affiliated third parties as necessary to effect, administer, or enforce a transaction that a client requests and authorises.
- Non-Public Information may be disclosed to non-affiliated third parties with the consent or at the direction of the data owner;
- Non-Public Information may be disclosed to non-affiliated third parties as may otherwise be required by law, authorised by Sections 248.13, 248.14 and 248.15 of Regulation S-P and/or International Data Protection Rules.
Receipt of Non-Public Information from Non-Affiliated Third Parties
If Brandywine Global receives Non-Public Information relating to its clients or prospective clients from a non-affiliated third party, Brandywine Global will treat such information in the same manner as it would any other Non-Public Information in its possession in accordance with this Policy.
Disposal of Non-Public Information
Brandywine Global will properly dispose of any Non-Public Information and as required by International Data Protection laws as follows:
Hard Copy Media: In accordance with all applicable rules and regulations, Brandywine Global will shred or arrange for the secure destruction of all hard copy media containing Non-Public Information.
Electronic Media: In accordance with all applicable rules and regulations, Brandywine Global's Information Technology Group will destroy or arrange for the secure destruction of all company electronic media.
Brandywine Global Investment Management, LLC
1735 Market Street, Suite 1800
Philadelphia, PA 19103
By email: email@example.com