Regulatory Notices

For the reasons described in the next section of this Privacy Notice, from time to time Arrowstreet may process the following types of personal data:

1. Information that you directly provide to us.
   • Any information about you that you provide us by communicating with us, whether face-to-face, by phone, e-mail or otherwise. This information may include, for example, your full name, title, business address, company affiliation, country of domicile, email address, and telephone number. 
2. Information that we collect or generate about you.
   • The information we collect may include, for example, your full name, title, business address, company affiliation, country of domicile, email address, and telephone number. The information we generate may include notes describing our communications with you.
3. Information about you that we obtain from other sources.
   • Arrowstreet engages a third party service provider to conduct legally required due diligence checks on certain individuals in accordance with applicable law. The data we obtain includes information that helps identify you (e.g., your name; alias (if any) age; date of birth; gender; country of residence; passport details; citizenship). Depending upon the specific facts and circumstances of your particular business relationship to or with one or more of Arrowstreet’s clients or prospective clients, we may also obtain the following types of personal data:
     • Personal identification numbers (e.g., social security numbers; national insurance numbers) that are Public Domain Data.
     • Family circumstances information (e.g., your marital status and dependents) if you are a PEP or a close associate of a PEP.
     • Employment/role and education details (e.g., the organization(s) you work/have worked for, public roles (including political, diplomatic, religious, judicial, military and trade union roles), your job title and your education history).
     • Professional and personal affiliations (e.g., organizations (including sanctioned vessels and aircraft) and individuals that you may be associated with in your professional or personal capacity).
     • Financial information relevant to understanding your income or wealth (e.g., bankruptcy or insolvency filings).
     • Your inclusion (if any) on sanctions lists or on public lists of disqualified directors or other positions of responsibility.
     • Public Domain Data about actual or alleged money laundering or terrorist financing crime, or crimes that are a pre-cursor to money laundering or terrorist financing which are also known as predicate offences (e.g., financial crime, illegal trafficking, environmental offences, smuggling, membership of an organized crime group).
     • Your postings on website, blogs or social media applications.
     • Please review the Refinitiv (LSEG) WorldCheck Privacy Notice for more detail.

The party that employs you or on whose behalf you are serving is the “controller” of your personal data, and determines the purpose and legal basis for processing your personal data.  In connection with the business relationship between that party and Arrowstreet, Arrowstreet processes your personal data for the following purposes:

• To provide the services described in the relevant investment management agreement, subscription agreement, and/or any other product-specific offering documents, or in connection with entering into such agreement(s);
• To provide information about Arrowstreet’s other products and services;
• To perform AML/KYC and other due diligence checks as required by applicable laws and regulations as a result of your professional relationship with one or more of Arrowstreet’s clients or prospective clients, and to comply with other applicable laws and regulations, including, to the extent necessary, in connection with any official legal proceedings;
• To perform and/or deliver client reporting with respect to the services described in the relevant investment management agreement, subscription agreement, and/or any other product-specific offering documents; and/or
• To service our clients’ account(s) as may be appropriate from time in connection with fulfilling our contractual obligations to provide the services described in such agreement.

We are lawfully permitted to process your personal data for the purposes described above because:

• We must do so in order to comply with our regulatory and legal obligations;
• We may be required to do so to in order to establish, exercise or defend our legal rights or in connection with legal proceedings; and/or
• The use of your personal data as described is necessary for our legitimate business interests as a registered investment adviser and discretionary investment manager. Our legitimate business interests include, for example:
  • servicing our clients’ account(s);
  • fulfilling our contractual obligations with our clients;
  • informing prospective clients of relevant products and/or services Arrowstreet may be able to offer, as well as informing our existing clients of Arrowstreet’s additional products and/or services that may be available.

We may need to disclose your personal data to the following non-exclusive list of categories of recipients:

• To third party service providers that the party that employs you or on whose behalf you are serving has engaged to provide them with various services
• To third party service providers Arrowstreet has engaged to provide us with various services including, for example, assistance with fulfilling our various legal and regulatory obligations (such as the screening tool we use to conduct AML/KYC checks)
• To applicable regulatory authorities or judicial courts, to the extent required by applicable law or court order.

The personal data that we have from or about you may be transferred to, stored within, or processed in a country outside of the European Economic Area (“EEA”) and/or the United Kingdom (“UK”). In particular, your personal data may be processed by Arrowstreet staff in the United States, and/or your personal data may be transferred to and processed by certain of our third party service providers in the United States.

The length of time for which we may continue to store and process your personal data will vary. The retention period will be determined by various criteria:

•  The purpose(s), for which we are using your personal data, as detailed above.
  • We will need to keep the data for as long as is necessary for that purpose.
• Our legal and regulatory obligations.
  • Laws or regulations may set a minimum period for which we are required to retain your personal data.

You have a number of legal rights in relation to your personal data. You can find out more information about your rights by contacting the applicable regulatory authority, such as the UK Information Commissioner’s Office, or by searching their website at https://ico.org.uk/.  You can exercise your rights by contacting the party that employs you or on whose behalf you are serving.