In this Privacy Notice:
- "we", "our" "us", or “PIMCO” means the European and UK PIMCO entities listed here; and
- “PIMCO Group” means any PIMCO entity, including those entities which are based outside of Europe and the UK.
For the purposes of data protection law, we are a data controller in respect of your personal data. We collect and use your personal data and where applicable this may include information related to your spouse/partner, directors, partners and owners (your “representatives”). PIMCO is responsible for ensuring that it uses your personal data in compliance with data protection law.
PIMCO considers customer privacy to be a fundamental aspect of its relationship with clients. PIMCO is committed to maintaining the confidentiality, integrity, and security of its current, prospective and former clients' personal data. PIMCO has developed policies that are designed to protect this confidentiality, while allowing client needs to be served.
This notice applies to any personal data we receive from you, create or obtain from other sources and explains how it will be used by us. It applies to personal data collected in connection with your use of this website or any PIMCO social media channels (we refer to both when we refer to “website” below). It also applies to other, offline data collection and interaction that you may have with us.
Please note that our website may link to third-party websites and third parties (including, for example, providers of external services like web traffic analysis services), over which we have no control and which will be subject to the provisions set out in those third parties’ privacy notices.
It is important that you take the time to read and understand this notice so that you understand how we will use your personal data and your rights in relation to your personal data.
Personal data that we collect from you
We will collect and use the following personal data about you and your representatives:
Information you give us:
- This is personal data about you and any other individuals (such as representatives or advisors) that you give us by filling in forms or by corresponding with us by phone, e-mail or otherwise. The information you give us may include your and your representatives’ name, address, e-mail address and phone number, financial information, and identification records (including your nationality).
- You should ensure that in respect of any information you provide us with which does not relate to you (for example, information about your representatives), you have obtained the necessary consent in order to disclose such information.
Information we collect or generate about you and your representatives:
- We sometimes record telephone conversations and monitor email 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 (including your nationality).
- We generate data to improve our service and to manage, administer and take decisions about the accounts and holdings we provide. The information we capture in this way may include your name, address, e-mail address and phone number, financial information, and identification records (including your nationality).
- In the course of operating our websites, we may collect and process the following information about you:
- Information that you provide by filling in forms on our websites. The personal data you provide in this way may include your full name, title, telephone number and email address.
- Information about when you use our services. We use various technologies to collect and store information when you visit our website. We may, for example, collect information about the type of device you use to access the websites, your IP address and your geographic location, the operating system and version, your browser type, the content you view and features you access on our websites, the web pages and the search terms you enter on our websites.
- Information when you report a problem with our website.
Information we receive from other sources:
- Verifying your identity – We will use information provided by third parties (e.g. fraud prevention agencies) when verifying your identity and when carrying out anti money laundering checks. Such information may include some details about any criminal convictions and any allegations regarding criminal activity that relate to you (to the extent that this is permissible under local laws), as well as details of your status as a politically exposed person. It may also include identification records (including your nationality).
- Intermediaries – We may receive information from dealers, brokers and introducers for the purposes of entering in to and administering your agreement. This may include your name, address, e-mail address and phone number, financial information, and identification records.
- Publicly available information - We may obtain information about you from publicly available databases, such as social media sites. The information we capture in this way may include your name, employer, email address and phone number.
How we use your personal data
Your personal data may be used by us in the following ways:
- to verify your identity as part of our client onboarding process;
- in order to detect and prevent fraud and money laundering; and / or
- in order to identify politically exposed persons.
Products & Services:
- to ensure content from our website is presented in the most effective way for you and your computer;
- in order to manage and administer accounts and holdings we provide to our clients;
- in order to provide you with information, products or services you may request from us;
- to record and monitor your use of our website or our other online services for our business purposes which may include analysis of usage and measurement of site performance; and / or
- where you have provided your consent to do so, to send promotional information about our products and services via the methods you specify (for example by email or post).
Legal bases pursuant to which we process your personal data
We process your personal data pursuant to the following legal bases:
- in order to perform our obligations under our contract with you;
- to comply with our legal and regulatory obligations;
- to establish, exercise or defend our legal rights and / or for the purpose of (or in connection with) legal proceedings;
- for the prevention of fraud; and
- the use of your personal data as described is necessary for our legitimate business interests such as:
- to enable us to improve the website and deliver a better and more personalised service to you;
- enforcing the terms and conditions of any agreement we have with our clients;
- the recovery of outstanding debts existing under an agreement with our clients; and
- to send promotional information about our products and services where permissible.
- to send promotional information about our products and services via the methods you specify, where you have provided consent to do so.
Sharing your personal data
As a matter of policy, PIMCO does not disclose any personal data provided by its clients or gathered by PIMCO to non-affiliated third parties, except as required or permitted by law or for PIMCO's everyday business purposes, such as to process transactions or service a client account. We may disclose your personal data within the PIMCO Group and to third party service providers in the circumstances described below:
- to ensure the delivery of products or services to our clients;
- to ensure the safety and security of our data;
- to assess compliance with applicable laws, rules and regulations, and internal policies and procedures across our business; and
- for internal research and statistical analysis purposes.
We will take steps to ensure that the personal data is accessed only by personnel that have a need to do so for the purposes described in this notice.
We may also share your personal data outside of the PIMCO Group:
- to any distributor, broker or introducer of an agreement with us;
- if we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes;
- if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer; and
- to third party agents.
These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice.
We may also share your personal data outside of the PIMCO Group to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation (including disclosures made to regulators and Companies House), and to establish, exercise or defend our legal rights.
Transfer of personal data outside the UK, European Economic Area or Switzerland
The information you provide to us will be transferred to and stored on our secure servers in the UK, European Economic Area (“EEA”) or Switzerland. However, from time to time, your personal data may be transferred to, stored in, or accessed from a destination outside the UK, EEA or Switzerland. It may also be processed by staff operating outside of the UK, EEA or Switzerland who work for a company in the PIMCO Group or for one of our suppliers.
Where we transfer your personal data outside the UK, EEA or Switzerland, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the UK, EEA or Switzerland. This can be done in a number of ways, for instance:
- the recipient of the data might be a signatory to PIMCO Group binding corporate rules;
- the country that we send the data to might be approved by the European Commission or a relevant data protection authority; or
- the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data.
In other circumstances the law may permit us to otherwise transfer your personal data outside the UK, EEA or Switzerland. In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.
You can obtain more details of the protection given to your personal data when it is transferred outside the UK, EEA or Switzerland (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data or binding corporate rules) by contacting us in accordance with the “Contact us” section below.
How long we keep your personal data
How long we hold your personal data for will vary. The retention period will be determined by various criteria including:
- our internal policies that dictate the period for which we hold personal data; and
- legal obligations – laws or regulation may set a minimum period for which we have to store your personal data.
We will not retain your personal data for longer than is necessary and we will hold it only for the purposes for which it was obtained. As soon as we no longer need your personal data for the purposes mentioned, we will delete the data from our systems, unless we are legally obliged to store it.
You have a number of rights in relation to the personal data that we hold about you. These rights include:
- the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
- the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so;
- in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
- the right to request that we rectify your personal data if it is inaccurate or incomplete;
- the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
- the right to request that we restrict our processing of your personal data in certain circumstances. Please note that there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request;
- the right to object to our processing of your personal data where we process your personal data pursuant to our legitimate business interests. Please note that there may be circumstances where you object to our processing of your personal data but we are legally entitled to refuse that request;
- the right to object to any automated decision making (including profiling) which we conduct based on your personal data, which significantly affects you. Please note that there may be circumstances where you object to us conducting automated decision making but we are legally entitled to refuse that request;
- the right to object to the processing of your personal data for direct marketing purposes; and
- the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.
You can exercise your rights by contacting us using the details set out in the “Contact us” section below.
You can find out more information about your rights by contacting the following:
- for PIMCO Europe GmbH, the Bavarian Data Protection Officer or by searching their website at https://www.datenschutz-bayern.de/;
- for PIMCO Europe Limited and PIMCO Europe GmbH UK Branch, the Information Commissioner or by searching their website at https://ico.org.uk/;
- for PIMCO (Schweiz) GmbH, the Federal Data Protection and Information Commissioner's Office or by searching their website at https://www.edoeb.admin.ch/edoeb/en/home.html;
- for PIMCO Europe GmbH, Sucursal en España, the Spanish Agency for Data Protection or by searching their website at https://www.aepd.es/es;
- for PIMCO Global Advisors (Luxembourg) S.A., the Commission nationale pour la protection des données or by searching their website at www.cnpd.lu;
- for PIMCO Europe GmbH Italian Branch, the Garante per la protezione dei dati personali or by searching their website at www.garanteprivacy.it; and
- for PIMCO Global Advisors (Ireland) Limited, PGA Global Services LLC (Ireland Branch), and PIMCO Europe GmbH Irish Branch, the Data Protection Commission or by searching their website at https://www.dataprotection.ie/.
- for the French Branch of PIMCO Europe GmbH, the Commission National Informatique et Libertés or by searching their website at https://www.cnil.fr
Changes to our privacy notice
We keep our privacy notice under regular review. Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Please contact us if you have any questions about our privacy notice or personal data we hold about you:
- write to us at our addresses listed here; or
- contact us by email at: email@example.com or alternatively by completing the ‘contact us’ form on our website.
PIMCO Europe GmbH has appointed a Data Protection Officer who, for queries relating to PIMCO Europe GmbH, can be contacted using the ‘contact us’ details above. Please mark your enquiry ‘for the attention of the Data Protection Officer’.
Allianz Binding Corporate Rules
The PIMCO Group entities are all members of the Allianz Group and the PIMCO Group entities set out in this document have signed up to comply with the Allianz Binding Corporate Rules. The Allianz Binding Corporate Rules provide information on the rules governing the international transfer of personal data between PIMCO Group companies (as well as other Allianz Group companies) operating in the European Economic Area (EEA) and PIMCO Group companies (as well as other Allianz Group companies) outside that area. The Allianz Binding Corporate Rules also describe the rights of data subjects in respect of such transfers, what to do if data subjects want to exercise their rights or complain about such transfers, and how data subjects can contact PIMCO.