Privacy Notice
This PIMCO Privacy Notice (“Privacy Notice”) describes the personal data PIMCO Asia Limited (“PIMCO” or “we”) collect or receive from or about you as well as the ways in which we use and share such personal data. We will collect and/or process personal data about you when you visit https://www.pimco.com/hk/en/ (“Website”), use mobile applications we make available (“Apps”, and together with the Website, “Digital Services”), via social media platforms, and when we interact with you or provide products and services to you, whether online (e.g. by email or telephone) or offline.
At PIMCO, we consider privacy to be a fundamental aspect of our relationship with our current, former and prospective clients, shareholders and other individuals whose personal data we collect and process, and we are committed to maintaining the confidentiality, integrity and security of your personal data. Our collection, sharing and use of personal data is governed by the Personal Data (Privacy) Ordinance (“PDPO”).
Information We Collect About You
We collect information about you in various ways. Some of this information may be considered “personal data” under PDPO. The personal data that you provide and that we collect or receive from you depends on the context of your interaction with us and our Digital Services, the choices you make when you interact with us or use our Digital Services, and the products, services and/or features that you use.
We require information from you for various purposes explained in the section below entitled “How We Use Your Information”. Accordingly, if you do not provide any information that is requested, we may not be able to carry out the necessary activities in relation to such purposes (for example, we may not be able to respond to your queries or requests, and/or we may not be able to provide you with our products and/or services).
You may provide information to us directly. We collect and receive information from you directly, such as when you correspond with us by phone, chat, e-mail or otherwise; fill in product / account applications and other forms; interact with us via calendar invites or meetings; register as a PIMCO.com/hk user; sign up for and attend our events or conferences; download and use one of our Apps and/or log in to a PIMCO Website. This information may include your name, contact details, financial information, identification records, the contents of our communications with you, pictures, audio, or videos of you, related details, login ID and password, information about your professional and employment capacity.
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, identification records and other information collected during our communication with you.
You may provide information to third parties who act on our behalf. We collect and receive information when you provide your information to our third party service providers and other partners who we engage to assist us in providing services to you. Such third parties may include website providers and entities that assist us in holding meetings and events. The information collected by such entities may include your name, contact details, IP address and other online identifiers, login ID and password or information regarding the events you attend. When you register to attend a PIMCO event, such providers may also collect information regarding your travel plans, including your flight preferences, travel itinerary and details about your accommodations.
We collect information from you automatically through tracking technologies. When you visit our Digital Services or interact with us electronically we collect certain information from you automatically. We may collect this information through cookies, web beacons, tags and scripts and other tracking technologies. We may combine this information with other information we collect about you on our Digital Services or via other sources.
The information we collect automatically may include the following:
- Your IP address.
- Your device identifier.
- Advertising identifiers.
- Your location.
- The type of browser and/or operating system you are using.
- The domain name of your Internet service provider.
- Information regarding when you access or how you use our Digital Services.
- The URLs of the pages that you visit and information regarding how long you use various pages or aspects of our Website.
For more information regarding how we and third parties we engage may collect information from you automatically via cookies and other tracking technologies, please see Cookies, Online Tracking and Interest-Based Advertising below.
We receive information about you from other sources. We may act as a third-party recipient of personal information, such as:
- When verifying your identity and when carrying out diligence to comply with know-your-client and anti-money laundering and sanctions laws. Such information may include some details about identification, any criminal convictions, and any allegations regarding criminal activity that relate to you (to the extent that this is permissible under local laws).
- When conducting pre-investment diligence, including personal identifiers, contact details, professional or employment information, and geolocation data.
- When developing leads related to individuals or representatives of companies with whom we believe we may be interested in doing business. We use such personal information, including personal identifiers, professional or employment information, geolocation data, and information regarding interactions with our Digital Services, to contact such individuals about products and services we believe may be of interest to them subject to your consent where required by law, or as otherwise permitted or required by law.
We collect information that you provide to us via social media platforms and other third-party services. We collect and receive information from you when you interact with our social media pages, accounts or via posts you make on social media and other third-party platforms (“Social Media Platforms”). This may include demographic information about users who “follow” our pages or information regarding how you engage with us, such as when you “like” our content. For more information, please see Social Media and Other Platforms below.
How We Use Your Information
We may use the information we collect from you in a variety of ways, including:
- To present our Digital Services and its contents to you and to operate our Digital Services.
- To deliver the information, products or services you have requested from us.
- To register your account and deliver access to your accounts to you.
- To reach out to you about and market or promote new information, products or services to you that we believe you may be interested in, subject to obtaining your consent if required by law.
- To verify your identity and comply with applicable law, including know-your-client and anti-money laundering and sanctions requirements.
- To conduct pre-investment diligence.
- To communicate with you, including to arrange and log interactions and notify you about changes to our Digital Services or 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 help us improve our Digital Services and communications and services and deliver a more personalized experience. This includes by enabling us to estimate and analyze 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 deliver interest-based advertising to you. Please see Cookies, Online Tracking and Interest-Based Advertising below for further information about our and third parties’ use of cookies and other tracking technologies to provide you with relevant ads on our Digital Services and other sites, and information about how to disable cookies and make other choices related to targeted advertising.
- To carry out our obligations and enforce our rights arising from any contracts entered into with you. This includes for billing and collection, and as we believe is necessary or appropriate to protect, enforce or defend the legal rights, privacy, safety or property of PIMCO , its affiliates, employees or agents, or other users of Digital Services or clients of PIMCO or to comply with law.
- To create deidentified, statistical or aggregate data which is no longer personal information.
- To improve or enhance our services or business, for research purposes.
- 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.
- In any other way we may describe when you provide the information, or otherwise at your direction or with your consent.
- As permitted by law or as we may notify you.
Please note that we may use artificial intelligence (“AI”) when processing personal data for these purposes if permitted by applicable law. AI can help to improve the efficiency of our processes and enhance the quality of services that we offer. However, it is important to note that any decision that is material to you will ultimately be taken by appropriate member of our staff. Our use of AI-powered tools will supplement and enhance but not replace human judgement and expertise. We will not use the AI-powered tools to make solely automated decisions, nor rely solely on outputs generated by AI-powered tools without human review for accuracy and appropriateness. We will not, and will not allow third parties to, use your personal data to train AI models.
How We Share Information
To the extent permitted by law, we may share the information that we collect pursuant to this Privacy Notice both within and outside of Hong Kong, as follows:
- With our affiliates.
- With our service providers, business partners and vendors. These parties may include companies that host our Digital Services, provide web analytics, perform data processing, provide AI tools on which we rely, distribute emails to you, serve interest-based ads or measure ad performance, assist our other marketing and publicity activities or help us communicate and interact with you.
- When you request any of our products or services. We will share your information to the extent necessary or appropriate to fulfill your request.
- When required to do so by law or regulation. For example, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency’s or regulator’s or governmental body’s request.
- With any third party in connection with a dispute, litigation, investigation, proceedings or enquiry involving us or any of our affiliates.
- With event sponsors and attendees, and other users of our Apps when you attend a PIMCO event.
- Otherwise at your direction or with your consent.
In addition, please note that if PIMCO or any of its affiliates, subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of or dissolved, including through merger, consolidation, sale or divestiture of assets, the relevant customer database, including personal data we may possess about you, and information collected pursuant to this Privacy Notice, may, in whole or in part, be sold, disposed of, transferred, divested, or otherwise disclosed as part of that transaction or proceeding.
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.
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 information in connection with your registration for and attendance at events as set forth in this Privacy Notice.
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 https://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.
Social Media and Other Platforms
You may choose to engage with us on Social Media Platforms. We collect and receive information from you when you interact with our social media pages, accounts or via posts you make on Social Media Platforms. If you choose to make any of your activities or other content available through a Social Media Platform, including on our pages, or you engage in other activities in connection with a Social Media Platform, your friends and followers on those Social Media Platforms that you have enabled, and potentially the general public, will be able to view those contributions and activities. Please remember that the manner in which Social Media Platforms use, store, and disclose your information is governed by the policies of such third-parties. PIMCO is not responsible for the privacy practices or other actions of any Social Media Platform through which we may engage with you.
Links to Third-Party Websites
Our Digital Services and digital communications may contain links to third-party sites and services whose privacy practices may be different than ours. We may also allow you to connect with other third-party sites and services. We are not responsible for the privacy practices of third-party sites and services and you should consult the other third-party sites’ and services’ privacy notices in order to better understand their privacy practices.
“Do Not Track” Signals
We do not recognize the “do not track” signals that some browsers may employ as no uniform standard for responding to such signals has been developed at this time.
Security
PIMCO takes seriously the obligation to safeguard personal data. PIMCO has implemented procedures that are designed to restrict access to personal data to its personnel who need to know that information to perform their jobs. Physical, electronic, and procedural safeguards are in place to guard your personal data.
Children’s Privacy
Our Digital Services, products and services are not intended for users under the age of 16, and PIMCO does not knowingly collect information from anyone under the age of 16. No one under the age of 16 is permitted to access or use our Digital Services, products or services or provide us with personal data.
Your Rights
We take reasonable steps to accurately record the personal data that you provide to us pursuant to this Privacy Notice and any subsequent updates to such information. Under the PDPO, you have the right to check whether we hold your personal data and request access to such data, and to require us to correct any data that is inaccurate.
Where you have consented to receiving marketing information from us, you also have the right to change your mind on which communications you would like to receive, or how you would like to receive them, or decide that you do not wish to receive marketing communications.
To exercise the above rights, please address your request to:
Data Protection Officer c/o Senior Counsel
PIMCO Asia Limited
Suite 2201, 22nd Floor
Two International Finance Centre
8 Finance Street
Central, Hong Kong
Retention Period of Your Personal data
We shall retain personal data for no longer than is necessary for the fulfillment of the purpose for which such information is used.
Changes to the Privacy Notice
From time to time, PIMCO may update or revise this Privacy Notice. If there are changes to the terms of this Privacy Notice, documents containing the revised notice on the relevant website(s) and/or Digital Services will be updated. Please check back frequently to see any updates or changes.
How to Contact Us
If you have any questions or concerns about this Privacy Notice, please contact us at apac_privacy@pimco.com.