PRIVACY STATEMENT FOR RESIDENTS OF CALIFORNIA

This Privacy Notice for California Residents supplements the information contained in any other Privacy Statement or Notice provided by Newton Investment Management (“NIM” or “we”) and applies solely to residents of the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended, and any terms defined in the CCPA have the same meaning when used in this notice.

Please note that certain exemptions apply to your rights and Newton Investment Management’s obligations pursuant to the CCPA. These rights and requirements may not apply in certain situations depending on your relationship with NIM, NIM’s other legal obligations, and as otherwise provided for in the CCPA.

NIM reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our services, products, websites and/or mobile apps following the posting of changes constitutes your acceptance of such changes.

Information we collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we may have collected the following categories of personal information from our consumers within the last twelve (12) months:

Category

Examples

Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, signature or other similar identifiers.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))


A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.

Protected classification characteristics under California or federal law


Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Biometric information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Internet or other similar network activity

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Geolocation data

Physical location or movements.

Sensory data

Audio, electronic, visual, thermal, olfactory, or similar information.

Professional or employment-related information

Current or past job history or performance evaluations.

Inferences drawn from other personal information

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Household Information

Information pertaining to household age, estimated income identifier, number of persons in household, number of cars owned, household college education, dwelling type, among other information capable of being linked to a household.

Where we collect your personal information from

 

We will collect the personal information described above from one or more of the below sources:

 

  • directly from you throughout our relationship, including when you sign up for, and/or use, our products, services and websites, or when you visit our offices or attend a NIM event;
  • indirectly from you, for example, from observing your actions on our websites or mobile apps;
  • from our parent entities, affiliates, subsidiaries and partners;
  • from third parties that are authorized to share your information with us, such as intermediaries, broker dealers, our institutional clients and service providers; and
  • from publicly available sources of information‌.

Use of personal information

 

We may use or disclose the personal information we collect for one or more of the following business purposes:

 

  • To fulfill or meet the reason you provided the information;
  • To provide, support, personalize, and develop our websites, mobile apps products, and services;
  • To create, maintain, customize, and secure your account with us;
  • To process your requests, transactions, payments and prevent transactional fraud;
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
  • To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, third-party sites, and via email or text message (with your consent, where required by law);
  • To help maintain the safety, security, and integrity of our websites, software, systems, networks, products, services, databases other technology assets, and business;
  • For testing, research, analysis, and product development, including to develop and improve our websites, mobile apps, products, and services;
  • To manage our relationship with you or your business;
  • To develop new ways to meet our clients’ needs and to grow our business, for example by seeking client feedback or sharing our market research;
  • To develop and carry out marketing activities in order to keep our clients informed about our products and services;
  • To develop and manage our brand;
  • To respond to requests by law enforcement and our regulators and as may otherwise be required by applicable law, court order, or governmental regulations;
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of NIM’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by NIM is among the assets transferred; and
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

 

NIM will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Disclosures of personal information for a business purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Identifiers.
California Customer Records personal information categories.
Protected classification characteristics under California or federal law.
Commercial information.
Biometric information.
Internet or other similar network activity.
Geolocation data.
Sensory data.
Professional or employment-related information.
Inferences drawn from other personal information.
Household Information.

 

We disclose your personal information for a business purpose to the following categories of third parties:
– Parent entities, affiliates and subsidiaries;
– Business partners;
– Service providers who help manage, develop, and analyze our business and/or deliver services to us and our clients. These service providers have agreed to confidentiality restrictions and use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us;
– Agencies and organizations working to prevent fraud in financial services;
– Law enforcement, regulatory and other governmental agencies;
– Advertisers and Social Media Companies;
– Internet cookie information recipients including Google, Oracle, Facebook, LinkedIn, and Twitter (click on each respective link to see that party’s privacy policy); and
 – Any potential or actual third party purchasers of NIM assets where consumer information may be among those assets transferred.

No sale of personal information

 

NIM has not sold personal information in the preceding twelve (12) months. To the extent that NIM ever changed its policy and chose to sell personal information, you would have the right to opt-out of the sale of your personal information.

Access to specific information rights

 

You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that NIM disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • The categories of personal information that each recipient received.
  • The specific pieces of personal information we collected about you.

Deletion request rights

 

You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that NIM delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request we will delete (and direct our service providers to delete) your personal information from our records.

Exercising access, and deletion rights

 

To exercise the access, and deletion rights described above, please submit a verifiable consumer request to us by either:

        •     Visiting the Individual Request Page or
        •     Calling us at 1- 844-545-1259; or
        •     Emailing us at trmglobalprivacy@bnymellon.com

 

You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must:
 – Provide sufficient information that allows us to verify, to a reasonably high degree of certainty, that you are the person about whom we collected personal information. This may include requesting that you provide us with at least two or more pieces of personal information to match against personal information about you that we may or may not maintain and which we have determined to be reliable for the purpose of verification.
 – Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Authorized agent

Only you, or a person you have designated in writing as your authorized agent, or whom is registered with the California Secretary of State to act on your behalf, or whom you have provided power of attorney pursuant to California Probate Code sections 4000 to 4465, (“Authorized Agent”), may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

If you wish to have an Authorized Agent make a verifiable consumer requests on your behalf, they will need to provide us with sufficient written proof that you have designated them as your Authorized Agent and we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information.

Non-discrimination

 

You have the right not to receive discriminatory treatment for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California privacy rights

Websites operated by NIM currently do not respond to “do not track” signals or similar mechanisms. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to trmglobalprivacy@bnymellon.com or write us to the address listed below.

Contact information

Please do not hesitate to contact us if you have any questions or comments about this notice, the ways in which NIM collects and uses your personal information, your choices and rights regarding such use, wish to exercise your rights under California law (click here), or wish to receive a written copy of this notice.

Email: trmglobalprivacy@bnymellon.com
Phone: 844-545-1259
Website: Individual Request Page

PRIVACY STATEMENT FOR RESIDENTS OF ALL OTHER US STATES


At Newton, we take the issue of privacy very seriously. We would like to assure visitors to our Website of the security, privacy and confidentiality that they would expect from a leading financial services institution.

Information collected

General

We do not collect any personal information from anyone who is merely visiting or browsing our Website. However, personal information may be requested from visitors who choose to respond to online surveys or to send Newton an email message.

Email and product inquiry

Visitors to our Website are invited to send email messages to Newton in order that we may respond to enquiries regarding Newton or our products or services. These contact details are available from the ‘Contact us’ page on this Website.

Use of cookies

A cookie is a small piece of information about an internet session that may be created when a visitor accesses a website. Our Website uses cookies to facilitate easier navigation within the site and provide a higher level of convenience for the visitor. Your internet browser is likely to accept cookies by default, however you can set your browser to reject cookies and delete them from your system at any time. The cookies used by Newton do not retrieve any information from the visitor’s personal computer. For more information, please read our Cookie policy.

Use of information collected

Improved customer service

Newton uses the information collected from visitors to our Website to address the specific needs of those visitors and to provide better customer service, including the supply of the latest information regarding Newton products.

Record of communications

The information collected is also used to maintain a record of communications between Newton and our Website visitors, and to comply with any applicable legal or regulatory requirements.

Data Protection and transfer of personal information

The uses of your personal information are covered by the registrations of the Newton Group under the Data Protection Act 1998. The personal information you supply may be used to provide the service applied for, confirm/update customer records and establish your identity. The information will be held on a database and may be shared with and used by any company within The Bank of New York Mellon Corporation in the UK and internationally who are obliged by law or agreement to comply with the principles set out in the European Directive 95/46/EC. Under the Act you have the right to obtain a copy of the information held about you by contacting Newton Investment Management Limited in writing at any time, for which you may be charged a fee. You hereby agree that we may use, disclose and transfer this personal data as described herein. If you do not wish for your details to be used in the above manner and/or if you do not wish to receive marketing approaches relating to products and services offered by The Bank of New York Mellon Corporation which we believe may be of interest to you, then please write to Newton Investment Management Limited at BNY Mellon Centre, 160 Queen Victoria Street, London EC4V 4LA.

Access to information collected

Employees

Selected Newton employees have access to the information collected in order to respond to each visitor’s needs and provide that visitor with information regarding specific products in which they may have an interest. Newton employees are instructed to use strict standards of care when handling the personal/confidential information of Newton customers, and the handling of such information is dealt with in The Bank of New York Mellon’s Code of Conduct, which applies to its subsidiaries. Newton employees who do not conform to The Bank of New York Mellon’s confidentiality rules are subject to disciplinary sanctions.

Third parties

Newton does not transmit any personal information collected through its Website to any third-party marketers. However, Newton does offer the opportunity to its Website visitors to link to the web pages of third parties who provide products and services not supplied by Newton. Once the visitor leaves the Newton site, Newton does not receive any further information from the visitor.

Visitors

Visitors having specific questions regarding any information they have sent to Newton through our Website should send an email to  contact@newtonim.com

Information for Residents of the United States

Protection of Social Security Numbers

In this section, “We” refers to the family of companies owned by The Bank of New York Mellon Corporation.

Like all financial services companies, we collect a variety of information about individuals, including but not limited to our customers and employees. In many cases that information includes individuals’ Social Security numbers. We use records of Social Security numbers for many purposes, especially to comply with federal and state laws such as tax laws and anti-money-laundering laws.

Our policy is (i) to comply with all laws restricting the use and disclosure of Social Security numbers, (ii) to protect the confidentiality of Social Security numbers, (iii) to prohibit the unlawful disclosure of Social Security numbers, and (iv) to limit access to Social Security numbers to our employees, and in certain cases to non-affiliated parties that provide services to us, based on their responsibilities. To safeguard Social Security numbers, we maintain physical, electronic, and procedural safeguards that are designed to comply with applicable legal standards. Our employees are prohibited from disclosing Social Security numbers for unauthorised purposes.

We may share Social Security numbers among our affiliated companies or with non-affiliated parties for administrative purposes, such as to process transactions, verify identities and service accounts. We disclose Social Security numbers as required or permitted by law, such as to the Internal Revenue Service or to credit bureaus. When necessary, we disclose Social Security numbers to regulatory agencies, law enforcement agencies, courts and parties to lawsuits.

We may share Social Security numbers among our affiliated companies or with non-affiliated parties for administrative purposes, such as to process transactions, verify identities and service accounts. We disclose Social Security numbers as required or permitted by law, such as to the Internal Revenue Service or to credit bureaus. When necessary, we disclose Social Security numbers to regulatory agencies, law enforcement agencies, courts and parties to lawsuits.

We may share Social Security numbers among our affiliated companies for marketing purposes, but only in compliance with legal restrictions, including required opportunities to opt out of such sharing. We do not, without consent of the individual involved, share Social Security numbers with parties not affiliated with us to enable them to market their own products or services.