GQG PARTNERS PRIVACY POLICY

Last Updated: August 29, 2021

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.

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.

CONTENTS

Collection of Information
Use of Information
Sharing 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, login credentials, banking information, 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 “Sharing 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.

SHARING OF INFORMATION

We share personal information in the following circumstances or as otherwise described in this policy:

  • We may share your personal information with investment and financial services providers as part of providing our Services.
  • We may also share personal information with 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 share 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 share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
  • We may share 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 shared between and among GQG and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
  • We may share personal information with your joint investors, representatives, agents and advisors.
  • We share personal information with your consent or at your direction.

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 websupport@gqgpartners.com. We will provide our reasons if we deny any request for updating of 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 websupport@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.

Mobile Push Notifications

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.) affords individuals residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.

In the preceding 12 months, we have collected 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, 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. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

Category of Personal Information

Categories of Recipients

Identifiers

Data storage providers
Customer relationship management providers
Analytics providers
Advertising and marketing providers
Survey providers
Investment and financial services provider
Customer service providers
Digital event providers

Information (other than identifiers) subject to Cal. Civ. Code § 1798.80(e) (e.g., banking information)

Data storage providers
Customer relationship management providers
Analytics providers
Advertising and marketing providers
Investment and financial services provider

Commercial information

Data storage providers
Customer relationship management providers
Analytics providers
Advertising and marketing providers
Investment and financial services provider

Internet or other electronic network activity information

Data storage providers
Analytics providers
Advertising and marketing providers
Customer service providers

Professional or employment-related information

Data storage providers
Customer relationship management providers
Analytics providers
Advertising and marketing providers
Survey providers
Investment and financial services provider
Digital event providers

Inferences

Data storage providers
Customer relationship management providers
Analytics providers
Advertising and marketing providers
Survey providers
Investment and financial services provider

California law requires that we provide transparency about personal information we “sell,” which, for the purposes of the CCPA, broadly means scenarios in which GQG has shared personal information with third parties in exchange for valuable consideration. We do not sell our customers’ personal information. We only “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 “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

These business partners have the right to opt out of these sales at any time by submitting a “Do Not Sell My Personal Information” request by completing this form GQG CCPA Request Form and emailing it websupport@gqgpartners.com or by calling (754) 218-5500. We do not knowingly sell personal information about individuals under the age of 16.

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, (2) request deletion of your personal information, (3) opt out of any “sales” of your personal information that may be occurring, and (4) not be discriminated against for exercising these rights. You may make these requests by calling (754) 218-5500 or completing this form GQG CCPA Request Form and emailing it to websupport@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 we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. 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 websupport@gqgpartners.com.