Privacy Policy

Privacy Policy

Scope

Pzena Investment Management, LLC and its affiliates (collectively, “PIM”) are committed to protecting your privacy and that of your business and employees, while providing you, your clients, the organization you represent or your organization’s clients, with the opportunity to receive our services. This privacy notice covers all data subjects whose personal data is collected by PIM, in line with the requirements of the GDPR.


Privacy Notice

Who are we?
PIM was founded in late 1995 and began managing assets on January 1, 1996. The Firm is an investment manager based in New York with a strict focus on long-term classic value investing. We offer international, emerging markets, U.S., and other regional equity strategies. The Firm’s offerings span small, medium and large market capitalization thresholds. In addition to our New York headquarters, PIM has business development/client service offices in Melbourne and London.

Pzena Investment Management, LLC is the controller with respect to the personal data described below. Our subsidiary, Pzena Investment Management, Ltd., located at Dashwood House (17th Floor), 69 Old Broad Street, London EC2M 1QS, acts as our representative in the European Union. Further, our Chief Information & Operations Officer and Chief Information Security Officer (“CIOO/CISO”) who is responsible for our data protection and other PIM employees dealing with data protection questions and requests can be contacted directly by e-mail at privacy@pzena.com or by phone at +1 (212) 583-0311.

What Personal Data do we collect?
The personal data on you that we collect and process include your contact details (such as your name, address, email address and telephone number) and information such as your job title, which we may request from you. We may also collect personal data such as bank account details, source of wealth information, accounts, and copies of passport or other official documentation you provide to us, our funds or our affiliates on contracts, onboarding forms, subscription documents or other documents you may submit. Failure to provide such information when requested may mean that PIM is unable to perform its contractual obligations to you, your organization or your organization’s clients, or PIM may be required to cease providing services to you.

If you are applying for employment with PIM, we will collect information about your education and professional experience, professional licenses and certifications, contact details, and personal identification number(s). We may also collect compensation information, work product samples, and references and their relevant contact information. Your personal data through third parties, including recruitment agents, social media platforms (e.g., LinkedIn), business contacts or other referrers, universities, professional associations, and career sites may also be collected. You will also be asked to complete a criminal records check / declaration to confirm that you have no unspent convictions, to provide credit information, and to provide financial information or documents for verification purposes. Failure to provide such information when requested may mean that PIM is unable to perform its contractual obligations to you, or refuse your application for employment. If we make you an offer of employment, PIM will ask you to provide further information for on-boarding purposes, including bank account details and emergency contact details.

In addition, we collect personal data you choose to provide to us, e.g., if you contact us by letter, telephone, email or any other means of electronic or personal communication. We may also use electronic tags called "cookies" and “web beacons” to help us understand and analyze use of our emails and website. Cookies help us to understand how people use our site so that we can improve site functionality. Web beacons allow us to track the activity of anonymous and known individuals coming to our website. Beacons are primarily used 1) to track online web movements of our users and inform us what content is effective, and 2) to track receipt of emails to gauge the effectiveness of our communications. We collect information on what pages have been accessed and for how long, the country from which someone is accessing the site, and certain technical information regarding computer and operating systems, such as the user’s Internet protocol address, domain name and browser type. PIM does not track people over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (“DNT”) signals.

How do we use the personal data collected?
We will use your personal data to deliver investment management services or products to you, your clients, the organization you represent or your organization’s clients. We may also use your personal data to inform you about our services, new developments in the equity markets and our marketing events. If you are applying to work with us or one of our affiliates, we will use your personal data to process your employment application.

Our lawful basis for processing of the personal data will depend on the purpose or purposes of why we collected and need to use your information, however under EU data protection laws, in almost all cases the lawful basis will be:

• to perform the contract we have entered into with you or anticipate entering into with you;

• to comply with a legal obligation; or

• if we (or a third party) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms. Such legitimate interests will be:

o providing of investment management services, and fulfilling our obligations to you, your clients, the organization you represent or your organization’s clients;

o administrative or operational processes within PIM and direct marketing or other communication to you, your clients, the organization you represent or your organization’s clients in respect of our services or products;

o to operate and improve our business and to help maintain quality; or

o to comply with a legal obligation not set out under the laws of EU member states, or under contract, including for the establishment, exercise or defense of legal claims.

Disclosure
PIM will pass on your personal data to third parties without first obtaining your consent. The following third parties may receive your personal data for the following purpose(s) as part of the processing activities:

• Sub-processors as may be necessary to provide services for you, your clients, the organization you represent or your organization’s clients (e.g., brokers, custodians for your accounts).

• Sub-processors to assist us in administering and operating our business to meet client and regulatory expectations (e.g., disaster recovery backups, Global Relay for e-mail retention systems).

• Sub-processors to assist us in communicating with and marketing to you (e.g., Salesforce, Microsoft Office 365).

• Advisers (e.g., auditors, legal counsel and tax advisers) to PIM or our funds relating to the services we provide you, your clients, your employer or your employer’s clients.

• Our affiliates, for the purpose of providing our services.

They may in turn use the services of their affiliates or service providers to process your personal data where necessary or appropriate. Where we share your personal data with such third parties, we require the recipients of that personal data to put in place adequate measures to protect it. We may also share your information with law enforcement agencies; regulatory or tax authorities and other governmental or public agencies or authorities in order to comply with our legal or regulatory obligations or at their request in furtherance of their objectives. Your personal data may be sent to and stored by us and third parties in countries outside the country in which you are located and outside of the European Economic Area (“EEA”). The nature of our business means it is often necessary for us to send your personal data outside the EEA to properly provide our services to you, your clients, the organization you represent, or your organization’s clients. This occurs because our business and the third parties we may use have operations in the United States and countries across the world. We will always ensure that there is a legal basis and a relevant safeguard method for such data transfer so that your personal data is treated in a manner that is consistent with, and respects the EU laws and other applicable laws and regulations on data protection, including by entering into appropriate data transfer agreements with third party recipients of your personal information incorporating standard contractual clauses approved by the European Commission governing data transfer contracts. Please contact PIM at Privacy@pzena.com, if you would like a copy of the model clauses.

Retention period
PIM will retain personal data for as long as it is necessary for the purpose it is being processed for and will store the personal data for a sufficient period to handle or respond to any complaints, queries or concerns relating to such agreement or to satisfy any legal, regulatory, accounting or reporting requirements. The personal data may also be retained so that we can continue to improve our clients’ experience with us.

We will periodically review the personal data we hold in accordance with PIM’s policies. If there is no longer a legal or business need for the personal data to be retained, we delete it securely, or, in some cases, anonymize it.

Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.

• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.

• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.

• Right of portability – you have the right to have the data we hold about you transferred to another organization.

• Right to object – you have the right to object to certain types of processing such as direct marketing, and where we rely on legitimate interests as the basis for processing. These rights may be limited in some circumstances, for example where we are required to process your personal data by law.

• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

• Right to judicial review: in the event that PIM refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in the clause below.


All of the above requests will be forwarded on should there be a third party involved (as stated above) in the processing of your personal data.

Complaints
In the event that you wish to make a complaint about how your personal data is being processed by PIM (or third parties as described above), or how your complaint has been handled, you have the right to lodge a complaint with PIM’s data protection representative, and/or the CIOO/CISO, or directly with the relevant data protection supervisory authority (in the United Kingdom, the Information Commissioner’s Office - see details below).


The details for each of these contacts are:

Supervisory authority contact details
Contact Name: Information Commissioner’s Office
Address line 1: Wycliffe House
Address line 2: Water Lane
Address line 3: Wilmslow
Address line 4: Cheshire SK9 5AF
Address line 5:
Email: casework@ico.org.uk

Telephone: 0303 123 1113 (local UK); +44 1625 545 700 (calling from outside the UK)

CIOO/CISO contact details
Contact Name: Evan Fire
Address line 1: 320 Park Avenue, 8th Floor
Address line 2: New York, NY 10022
Address line 3: USA
Address line 4:
Address line 5:
Email: fire@pzena.com

Telephone: +1 (212) 583-0311