Privacy Notice
- What personal information does PIMCO collect?
- Can you remain anonymous?
- How does PIMCO store personal information?
- How and why does PIMCO collect, hold, use and disclose personal information?
- How does PIMCO collect personal information through PIMCO events?
- How does PIMCO disclose personal information to others?
- How can you manage cookies, online tracking and interest-based advertising?
- How can you access and correct your personal information, request further information or make a complaint?
PIMCO Australia Pty Ltd ABN 54 084 280 508 and PIMCO Australia Management Limited ABN 37 611 709 507 (collectively referred to as “PIMCO”) are bound by the Privacy Act 1988 (Cth) ("Privacy Act"). and the Australian Privacy Principles (“APPs”).
PIMCO considers privacy to be a fundamental aspect of our relationship with our clients and partners. We are committed to maintaining the confidentiality, integrity, and security of all personal information we hold, and have developed policies that are designed to protect this confidentiality, while allowing client needs to be served. This Privacy Notice sets out how we collect and handle personal information (being information or an opinion which is about, and reasonably capable of identifying, an individual).
All references to “us”, “we”, and “our” in this Privacy Notice are references to PIMCO. All references to “you” and “your” in this Privacy Notice are references to our clients, contractors, potential employees, users of our Digital Services (as defined below), and any other individuals that we deal with in the course of providing our services and running our business.
We may change our Privacy Notice from time to time and without notice - we will publish any changes on our website and/or Digital Services which you should review periodically.
1. What personal information does PIMCO collect?
In the course of providing you with products and services, or in our other dealings with you, we and certain of our service providers may obtain personal information about you, including sensitive information.
"Personal information" is information or an opinion about an identified individual or reasonably identifiable individual, whether true or not and whether recorded in material form or not.
About clients and prospective clients
If you are a client or a prospective client, this information may come from you directly, such as when you correspond with us by phone, chat, e-mail or otherwise; including through sources such as account applications and other forms, your transactions, when you fill in product / account applications and other forms, interact with us via calendar invites or meetings, register as a pimco.com/au user, sign up for and attend our events or conferences, log in to a PIMCO website, download and use mobile applications we make available (“Apps”, and together with PIMCO websites, “Digital Services”), or other written, electronic or verbal correspondence with you or when we provide products and services to you, whether online (e.g. including by email or telephone) or offline. We may also collect information from your brokerage or financial advisory firm, financial adviser or consultant, and from information captured about your use of our Digital Services and other online activity. The types of personal information we collect about you might include (but are not limited to):
- your full name, date of birth and gender;
- your contact information (including address, phone number and email address);
- any other information that may be obtained from your product / account applications and other forms;
- your transactional information;
- records of any communications or interactions you have with us;
- information to verify your identity and comply with our anti-money laundering obligations;
- your employment information;
- information about your use of our Digital Services;
- pictures, audio, or videos of you;
- information about your professional and employment capacity; and
- any other information you or your brokerage or financial advisory firm or consultant provide to us about you.
It is up to you to choose the information that you give to us. If you choose not to provide us with particular information that has been requested, we may not be able to provide the service that you have requested.
In addition, we sometimes record telephone conversations and monitor electronic communications to resolve complaints, improve our service and in order to comply with our legal and regulatory requirements. The information we capture in this way may include your name, address, e-mail address and phone number, financial information, and identification records. We will obtain your consent to collect this information if required by law to do so.
We may also take photographs of you as well as other recordings of your voice, likeness and / or image, when you participate in one of our events/meetings or attend our premises. If you do not wish for an image or recording of you to be taken, do let us know prior to attending the relevant event or meeting or our premises.
About Digital Services users
Digital Services maintained by us or our service providers may use a variety of technologies to collect information that help us and our service providers understand how the Digital Services is used, such as your IP address and your online activity. When you register to attend a PIMCO event, our service providers may also collect information regarding your travel plans, including your flight preferences, travel itinerary and details about your accommodations. Information collected from your web browser (including small files stored on your device that are commonly referred to as “cookies”) allow the websites to recognize your web browser and help to personalize and improve your user experience and enhance navigation of the website.
In addition, we or certain of our service providers may use third parties to develop marketing campaigns and manage advertisements of our products on our and other third party websites, including targeted banner advertisements. Such third parties may collect, and share with us, anonymous information through the use of cookies or action or container tags (such as web beacons). The information these third parties collect and share with us is generally limited to technical and web navigation information, such as your IP address, web pages visited and browser type, and does not include other personally identifiable information. You can change your cookie preferences by changing the setting on your web browser to delete or reject cookies. If you delete or reject cookies, some website pages may not have optimal functionalities.
For more information regarding how we and third parties we engage may collect information from you automatically via cookies and other tracking technologies and how you can manage them, please see How can you manage cookies, online tracking and interest-based advertising? below.
About employees, contractors, potential staff
If you are our employee, contractor or potential staff please refer to our "Employee / Contractor Privacy Notice" which is applicable to our engagement with you on the PIMCO Intranet or our “Applicant and Prospective Applicant Privacy Notice” available here as applicable for details about how your personal information will be processed by us.
About other individuals that we deal with
If you are another individual that we deal with in the course of providing our services and running our business, most personal information we collect will be received from you directly, however may also be collected from third parties such as or our business partners. The types of personal information we might collect about you will ultimately depend on our relationship with you or the way in which you engage with us, but examples might include:
- if you are a financial advisor or broker: your name and contact details, information about any interactions you have with us or our clients, and any other information you or your employing/contracting entity provide us with; or
- if you have subscribed to receive communications from us, or to participate at any conferences or events we organise, your name and contact details and any other information you provide us with.
2. Can you remain anonymous?
You can always choose to deal with us anonymously or by using a pseudonym.
However, please note that if you choose to remain anonymous or use a pseudonym, this may affect your ability to access or use certain functions of our websites or our ability to provide you with certain products and services.
If you wish to remain anonymous or use a pseudonym when dealing with us via a telephone call, please advise the call operator assisting you. Providing your personal details enables us to provide you with a contact record reference number which allows you, and other authorised persons, to retrieve information about that call at a later date.
3. How does PIMCO store personal information?
We aim to keep all personal information secure from any misuse, loss or unauthorised access, modification or disclosure. If we find that we have no further need for your personal information, we may remove it from our systems and destroy all records of it (in accordance with our records management policy and subject to applicable law).
We take seriously the obligation to safeguard your personal information. In addition to this Privacy Notice, we have implemented procedures that are designed to restrict access to your personal information to those members of our personnel who need to know that information to perform their jobs.
Physical, electronic, and procedural safeguards are in place to help guard your personal information. We employ firewalls, encryption technology, and user authentication systems where appropriate to help assure the security of data.
If we become aware of any loss of, unauthorised access to, or unauthorised disclosure of, personal information, we will comply with any mandatory data breach notification obligations under the Privacy Act which might arise.
4. How and why does PIMCO collect, hold, use and disclose personal information?
We may use your personal information to provide you with our services or to enable the functions and activities of our business. Again, how we use your personal information will generally depend on the nature of our relationship with you and the purpose for which we collected it, but may include the following:
- to present our Digital Services and its contents to you and to operate our Digital Services;
- to register your account and deliver access to your accounts to you;
- to provide you with information, or products or services you have requested;
- to comply with applicable law, including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and other applicable know-your-client, anti-money laundering and sanctions requirements;
- to conduct pre-investment diligence;
- to conduct research for the purposes of improving our existing products or services or creating new products or services;
- to communicate with you, including to arrange and log interactions and notify you about changes to our Digital Services, products or services;
- to facilitate your participation in events we host, including in connection with travel arrangements;
- to provide you with access to our Apps and populate a profile for you in the App associated with the PIMCO event for which you are registered;
- to create event attendee lists;
- to assist you by providing you with information and support;
- to carry out our obligations and enforce our rights, including as arising from any contracts entered into with you. This includes managing and administering any account or product you hold with us, including for processing transactions, billing and collection, and as we believe is necessary or appropriate to protect, enforce or defend the legal rights, privacy, safety or property of the Digital Services, our employees or agents, or other users;
- to help us improve our Digital Services and communications and services, and personalise and customise your online experience (including by tailoring any online promotional or marketing materials you see on our website or other third party websites, and by enabling us to estimate and analyse our audience size and usage patterns, store information about your preferences, speed up your searches and recognize you when you return to our website);
- to perform our organisational functions and activities and to operate our business efficiently (including through the appropriate use of automation and artificial intelligence tools);
- to promote (internally or externally) our business or your contributions / participation in our initiatives (including events hosted by us);
- to promote and market our products and services, and products and services of our business partners, to you or provide you with information that we believe may be of interest to you. We will only use your personal information for this purpose if you have consented to receiving marketing communications from us and/or our business partners and have not subsequently opted-out;
- to the extent permitted by law, to post information in relation to our business and promotional activities (such as events or conferences) on our websites, social media or other digital communication, marketing, advertising, publicity or sales channels;
- to create deidentified, statistical or aggregate data which is no longer personal information;
- to develop leads related to individuals or representatives of companies with whom we believe we may be interested in doing business, and to engage and manage our relationship with individual contractors or suppliers, and any other individuals we deal with in the course of operating our business;
- for quality assurance purposes or training purposes or to otherwise improve our products and services; and
- any other purposes disclosed to you at the time of collection, or otherwise at your direction or with your consent, or which are otherwise permitted or required by Australian laws.
5. How does PIMCO collect personal information through PIMCO events?
PIMCO hosts various events and conferences which you may sign up for or be invited to attend. You, or your designee such as an assistant acting on your behalf, may provide certain information to us or to providers working on our behalf when you apply for or register to attend an event. Such information may include your name and contact details, company, job title, professional and employment history, social media handle or LinkedIn profile, professional interests and other information you choose to share with us.
In some cases, we may also coordinate with you or your designee to book travel in connection with the event, which may include obtaining information from you regarding requested flight times and preferences, and information about your dates of travel, lodging and accommodations.
In some cases, we may collect, use, and/or share audio, visual or similar information from events that we host, including photos, videos and other types of recordings of your voice, image or likeness.
Events we host may have an event-specific App, which you can download to your device. We may, at our discretion, upload or otherwise transmit information provided to us in connection with your event registration into the App. You can view and manage your privacy settings within the App and make choices regarding whether to share information about yourself with other participants via the relevant App.
We may use and share personal information collected in connection with your registration for and attendance at PIMCO events as set forth in this Privacy Notice.
6. How does PIMCO disclose personal information to others?
As is common in the industry, PIMCO engages non-affiliated companies to provide certain services on its behalf, such as preparing and mailing investor correspondence including reports, account statements and other information, undertaking marketing activities, and conducting research on client satisfaction.
We may disclose your personal information provided by you or gathered by us to our related PIMCO entities and also non-affiliated third parties, as required or permitted by law or for one or more of the purposes described above. This might include our disclosing your personal information to:
- your nominated financial advisory firm, financial adviser or broker, or their service providers;
- our business partners and affiliates, such as investment funds or brokers and dealers that we work with when providing and marketing our and their products and services;
- PIMCO's agents, professional advisers, contractors or service providers (including its fraud prevention and tokenization service providers);
- Government bodies, regulators or law enforcement authorities, as required or authorised by law;
- event sponsors and attendees, and other users of our Apps when you attend a PIMCO event;
- other non-affiliated third parties for one of the purposes described above, as required or authorised by law, or otherwise by your request or with your consent; and
- our affiliates and related entities (including those located outside Australia).
When we disclose personal information to third parties, we make all reasonable efforts to ensure that we disclose only relevant information and that it is accurate, complete and up to date and that the third party will comply with the Privacy Act in relation to the use, disclosure and storage of your information.
We may collect, use and disclose your personal information for other purposes not listed in this Privacy Notice. If we do so, we will make it know to you at the time we collect or use your personal information.
Other permitted disclosures
We may disclose personal information in other circumstances, where the person concerned has consented to the disclosure, or where we are expressly permitted to do so by the Privacy Act or another applicable law.
Disclosure of personal information outside of Australia
Your personal information may be disclosed to entities located outside Australia (including entities located in Argentina, Brazil, Canada, France, Germany, Hong Kong, Ireland, Italy, Japan, Luxembourg, Singapore, Spain, Switzerland, Taiwan, United Kingdom and United States of America).
Where we disclose information (including when we disclose it outside of Australia), we take reasonable steps to ensure that any third parties we disclose your personal information to (including those entities located outside Australia) will deal with that information in a way that is consistent with the APPs.
7. How can you manage cookies, online tracking and interest-based advertising?
Cookies and Other Tracking Technologies
We and third-party partners we engage may use cookies (i.e., small text files that are stored on your browser, computer, or mobile device), web beacons, pixel tags, browser analysis tools, server logs and other tracking technologies to automatically collect information, including personal data such as your IP address, from your browser.
We use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use our website or other Digital Services.
We use cookies and other tracking technologies for a variety of purposes, including functional, analytics and advertising purposes. For example, we, our service providers and other partners we engage use cookies and other tracking technologies:
- For functional purposes, such as to provide the Digital Services and their content to you.
- For analytics purposes, such as to provide us with information about which portions of our Digital Services and offerings are the most popular, enabling us to see what web pages a user visits and how much time a user spends on each page, and what communications are of interest to a user.
- To personalize your experience on our Digital Services (e.g., to recognize you by name when you return to our website, to save your password in password-protected areas, or to tailor content, or product and service offerings to you).
- For advertising purposes, such as to provide advertisements to you (known as interest-based advertisements) that we or third parties believe may be relevant to your interests.
Google Analytics
Our website may use Google Analytics, a web analytics service offered by Google. You may learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy at http://www.google.com/policies/privacy/partners.
Interest-Based Advertising and Third Party Rights to Your Information
We may partner with third-party companies in an effort to serve targeted, interest-based advertisements to you. We permit our third-party partners to obtain information about you when you use our Digital Services. This information includes your IP address, mobile device ID and advertising ID. Such information is obtained through cookies and other tracking technologies. Our third-party partners and others may collect similar information from you across other websites and over time. We, our third-party partners and others may use this information to engage in interest-based advertising and display ads or other targeted content to you that is believed to be relevant to you based on your use of our Digital Services, other sites and other information we may collect about you. Such ads and targeted content may appear on our website and/or across other domains.
We take steps to contractually limit the rights our third-party partners have to the information they collect from you via cookies and other tracking technologies.
Your Choices
With respect to our website, you can generally manage your cookie preferences through your web browser. Most web browsers will tell you how to stop accepting new cookies and how to disable existing cookies. For more information regarding how to manage your preferences, please consult the information made available by your particular browser or visit www.allaboutcookies.org.
With respect to Google Analytics, you can also view Google’s currently available opt-out options at https://tools.google.com/dlpage/gaoptout in an effort to opt-out of being tracked by Google Analytics.
Please note that if you choose not to accept cookies, you may be unable to use certain features of our website. In addition, you may still receive advertisements on our website; however, they may not be as relevant to you.
8. How can you access and correct your personal information, request further information or make a complaint?
If you would like to access or correct the personal information we hold about you, obtain more information, or make a complaint about the way we manage this information, you can do so by contacting our Privacy Officer on the below details:
post: Level 19, 5 Martin Place, Sydney, NSW 2000
ph: 02 9279 1771
fax: 02 9279 2580
email: privacy@au.pimco.com
If we receive such a request or complaint, we will endeavour to provide you with our written response within 30 days, where possible. Please note that in certain circumstances, we may also need to consult another party in order to respond to you (particularly if you have raised a complaint which also involves a third party).
There are some circumstances in which we are not required to give you access to your personal information.
There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).
We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate and up to date.
If we refuse to provide you with access to your record or to update your record in the way you request, we will provide you with written reasons.
If we refuse to correct or update your information, you may request that we make a note on your record that you are of the opinion that the information is inaccurate, incomplete, out of date, irrelevant or misleading, as the case may be.
If you are not satisfied with our response to your access or correction request or complaint, you may approach an independent advisor or contact the Office of the Australian Information Commissioner for further review or assistance. See the OAIC website for more information about how to make a complaint.