GQG PARTNERS PRIVACY POLICY
Last Updated: December 21, 2023
This Privacy Policy explains how GQG Partners LLC and its subsidiaries and affiliated companies (“GQG,” “we,” or “us”) collect, use, and disclose information about you. This Privacy Policy applies when you use our investment management services, websites, mobile applications, and other products and services (collectively, our “Services”), contact our customer service team, engage with us on social media, participate in one of our contests, sweepstakes, promotions, or surveys, attend one of our events, or otherwise interact with us.
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.
For residents of the European Economic Area, Switzerland, and the United Kingdom, please review this Privacy Policy and also refer to GQG’s Privacy Notice for Residents of the European Economic Area, Switzerland, and the United Kingdom GDPR Privacy Notice for additional information relevant to you.
If you are a resident of the United States and have an individual account or begin the process of creating an individual account with us, you can also review our U.S. Financial Privacy Notice for a summary of our practices with respect to nonpublic personal information we collect about you. The U.S. Financial Privacy Notice is provided as an alternative way to read about our practices with respect to that information and does not supplement or supersede this Privacy Policy in any way.
On certain occasions, we may provide supplemental privacy notices that provide additional information about the personal information we collect and process, e.g. for job applicants. Those supplemental notices should be read together with this Privacy Policy and any geographic-specific privacy notices.
Collection of Information
Use of Information
Disclosure of Information
Advertising and Analytics
Transfer of Information to the United States and Other Countries
Storage and Security of Information
Your Choices
Your California Privacy Rights
Contact Us
COLLECTION OF INFORMATION
Information You Provide to Us
We collect information you provide directly to us. For example, you share information directly with us when you solicit our investment advice and investment management services, create an account, fill out a form or survey, use our online tools, sign up to receive our emails or other correspondence, communicate with us via third-party platforms, participate in a sweepstake, contest, or promotion, request customer support, register for an event, or otherwise communicate with us. The types of personal information we may collect include your name, email address, physical address, phone number, unique identifiers, citizenship, social security number, login credentials, banking information, income and source of wealth, company name, investor type, location and preferences, user preferences, personal comments or feedback, age, sex, and any other information you choose to provide.
Information We Collect Automatically When You Interact with Us
When you access or use our Services, we automatically collect certain information, including:
- Device and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Services, such as access times, visit duration, pages viewed, links clicked, country of access, and the page you visited before navigating to our Services.
- Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see our Cookie Policy and the Your Choices section below.
Information We Collect from Other Sources
We obtain information from third-party and public sources. For example, we may collect information about you from data analytics providers, data aggregators, social networks, including name, email, address, phone number, professional licenses, professional designations, location and investor type; brokerage firms, including trade confirmations; identity verification providers that provide “know your customer” services; and the third parties described under Disclosure of Information below.
Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer your preferences based on past engagements and information you submit to us.
Information We Collect under Law
Some of the personal information we collect as described above is collected by us in connection with legal requirements such as the Foreign Account Tax Compliance Act (FATCA), Common Reporting Standard (CRS), anti-money laundering and counter-terrorism financing acts, corporations acts and income tax acts and other tax laws.
USE OF INFORMATION
We use the information we collect to provide, maintain, and improve our investment management services, as well as the rest of our Services. We also use the information we collect to:
- Personalize and improve your experience with our Services;
- Determine what type of investor you are;
- Communicate with you about products, services, and events offered by GQG and others and provide news, opinions and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
- Monitor and analyze trends, usage, and activities in connection with our Services;
- Respond to your comments and questions and provide customer service;
- Personalize the advertisements you see on third-party platforms and websites (for more information, see the Advertising and Analytics section below);
- Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
- Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of GQG and others;
- Send you technical notices, security alerts, and support and administrative messages;
- Debug to identify and repair errors in our Services;
- Comply with our legal and financial obligations, and exercise and defend our legal rights; and
- Carry out any other purpose described to you at the time the information was collected.
We may not be able to do the things described in this section if we are unable to collect certain personal information. For example, we may not be able to communicate with you, provide services to you or grant you access to certain parts of our website.
We disclose personal information in the following circumstances or as otherwise described in this policy:
- We may disclose your personal information to investment and financial services providers as part of providing our Services.
- We may also disclose personal information to other vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies that assist us with web hosting, website analytics, data storage, customer retention, administering surveys, processing transactions, creating and maintaining customer accounts, fraud prevention, customer service, and marketing and advertising.
- We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
- We may disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of GQG, our customers, the public, or others.
- We disclose personal information to our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
- We may disclose personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
- Personal information is disclosed between and among GQG and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
- We may disclose personal information with your joint investors, representatives, agents and advisors.
- We disclose personal information with your consent or at your direction.
- We also disclose aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you.
We also share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you.
ADVERTISING AND ANALYTICS
We allow others to provide analytics services on our behalf across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by GQG and others to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.
We also work with third parties to serve ads to you as part of customized campaigns on third-party platforms (such as LinkedIn). As part of these ad campaigns, we or the third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.
TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES
GQG is headquartered in the United States, and we have operations and service providers in the United States, United Kingdom, Australia and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps as appropriate in the circumstances to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.
STORAGE AND SECURITY OF INFORMATION
We implement measures designed to protect personal information, including – depending on the circumstances – electronic access controls, premises security and network firewalls. We hold personal information electronically and in hard copy form, both at our own premises and with the assistance of our service providers.
YOUR CHOICES
Account Information
You may update and correct personal information we hold about you at any time by logging into your account (for certain account information) or emailing your request to us at privacy@gqgpartners.com. Where Australia’s Privacy Act applies (e.g. where personal information is held by our Australian subsidiary, which processes personal information of Australian residents), you may also access personal information we hold about you by emailing your request to us at privacy@gqgpartners.com. We will provide our reasons if we deny any request for updating of (or access to, under Australia’s Privacy Act) personal information. Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to note your requested correction with the information.
If you wish to delete your account, please email us at privacy@gqgpartners.com from the email address connected to your account and with the subject line “Delete My Account.” Note that we may retain certain information as required by law or for our legitimate business purposes.
Cookies
Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services. For more information about cookies and how to disable them, see our Cookie Policy.
Communications Preferences
You may opt out of receiving promotional emails from GQG by following the instructions in those communications. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
With your consent, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
YOUR CALIFORNIA PRIVACY RIGHTS
The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) requires us to explain some information using certain definitions and categories set out in that law. If you are a California resident, this section applies to you and describes our data practices today and in the preceding 12 months.
Additional Disclosures
We collect the following categories of personal information: identifiers, information (other than identifiers) subject to Cal. Civ. Code § 1798.80(e) (e.g., banking information), commercial information (including business partner personnel information and contact information), internet or other electronic network activity information, professional or employment-related information, and inferences. For details about the precise data points we collect and the categories of sources of such collection, please see the Collection of Information section above.
We collect personal information for the business and commercial purposes described in the Use of Information section above.
We have disclosed personal information for the business and commercial purposes described in the Disclosure of Information section above. Specifically, we have disclosed the following categories of personal information to the following categories of recipients:
Some of our advertising and marketing activities related to business contact information may constitute “sharing” or “selling” under California law. We do not “share” or “sell” our customers’ personal information. We only “share” or “sell” business contact information about certain business partners for the commercial purpose of building a database across investment managers and brokers. In the preceding 12 months, we have “shared” or “sold” the following categories of personal information from certain business partners to the following categories of third parties:
| Category of Personal Information | Category of Third Parties |
| Identifiers | Asset management solution providers |
| Professional or employment-related information | Asset management solution providers |
We do not knowingly sell personal information about individuals under the age of 16.
We store personal information for as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Privacy Policy.
Your Privacy Rights
The business partners whose information we may have “shared” or “sold” have the right to opt out of the “sharing” or “sale” of their information at any time by submitting a “Do Not Sell or Share My Personal Information” request by completing this form GQG CCPA Request Form and emailing it to privacy@gqgpartners.com or by calling 1-833-904-9090. You can also opt out by visiting our Services with a legally-recognized universal choice signal enabled (such as the Global Privacy Control). Please note that, depending on which legally-recognized opt-out preference signal you use and whether you are logged into your account with us, our processing of the signal may be limited to the specific browser or device that you are using. You may need to renew your opt-out choice if you use a different browser or device to access our Services, or if you clear your cookies.
Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose, including in a portable format, (2) request deletion of your personal information, (3) request correction of inaccurate personal information, and (4) opt out of any “sharing” or “sales” of your personal information that may be occurring.. You may make these requests by calling 1-833-904-9090 or completing this form GQG CCPA Request Form and emailing it to privacy@gqgpartners.com. We will verify your request by asking you to provide certain identifying information, such as your name, email address, phone number, or company. We will not discriminate against you if you exercise your rights under the CCPA.
If you are submitting a rights request as an authorized agent, you are required to submit proof of your authorization to make the request, such as a valid power of attorney or proof that you have signed permission from the individual who is the subject of the request. Please do not provide any sensitive personal information in connection with this request, such as a driver’s license or other government-issued ID. In some cases, we may contact the individual who is the subject of the request to verify his or her own identity or confirm you have permission to submit this request. If you are an authorized agent seeking to make a request, please contact us.
CONTACT US
If you have any questions about this Privacy Policy, please contact us at privacy@gqgpartners.com.