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BBH Privacy Notice

Protecting our clients' privacy is important to us. The purpose of this Privacy Notice is to describe to you our privacy policies and practices, the information we collect about you and how we use it. This Privacy Notice is an overview of our privacy policies and procedures and applies to information we collect relating to current and former clients.

We promise to treat personal information you disclose securely, fairly and lawfully and will only use that information as described in this Privacy Notice. Unless otherwise indicated, we will not collect sensitive personal information from you - this includes information about your race, political opinions, health, religious and other beliefs or sexual orientation.

Information We Collect

BBH, as data controller, collects, retains and uses non-public personal information about you (the “Data” as further described below) in order to: (i) conduct our legitimate business; (ii) comply with laws and regulations; (iii) carry out general internal research, including to analyse the use of our websites; and (iv) understand your financial needs, so that we can service you as well as we can.

The Data are collected from several sources, including:

  • Information we receive from you in writing, in person, by telephone and electronically
  • Information we receive in applications or in other forms
  • Information we receive from credit reporting companies such as credit reports
  • Information we receive through our website, online services and through the Internet

This Data may include:

  • Your name, address, phone number and other contact details
  • Information about your assets, income and debts
  • Information about your transactions with us, our affiliates, and non-affiliated third  parties, which may consist of information about account balances and counterparties to transactions
  • Your country of residence, status as an eligible investor (as obtained through your use of our websites or other means, as applicable) and other information as described below (under the headings “Electronic Communications Protocols”, “Cookies” and “Third Party Cookies and Websites”).

You may request access to, rectification or deletion of your Data from any of the parties above by addressing a request to BBH at the following address: matthew.ives@bbh.com.

Electronic Communications Protocols

In addition to the information specified above, BBH may collect information about your use of our websites through electronic communications protocols. As is true when you visit most website, BBH may automatically receive information from you as part of the communication connection itself, which often consists of network routing information (where you came from), equipment information (browser type), your IP address, and date and time. BBH also uses cookies, embedded URLs and embedded pixels to capture additional information.

Cookies

BBH's server will query your browser to see if there are "cookies" previously set by our websites. A cookie is a small piece of information sent by a web server to store on a web browser so it can later be read back from that browser. Cookies on our websites may collect a unique identifier, user preferences and profile information and membership information from which it is possible to identify individual users. BBH also uses cookies to collect general usage and volume statistical information that does not include personally identifiable information. Some cookies may remain on the user's computer after they leave the website (these are known as persistent cookies).

By using our websites, you agree that we can place cookies on your device which collect the Data and for the purposes described above. If you delete cookies relating to our websites, we will not remember things about you, you will be treated as a first-time visitor the next time you visit the websites and we will not be able to tailor your experience of the websites.

Third Party Cookies and Websites

BBH has engaged one or more third party service providers to track and analyze usage and volume statistical information from visitors to the Web site. The service provider(s) set cookies on behalf of BBH.

BBH also uses cookies to track the performance of BBH advertisements on third party websites.

BBH may re-associate the information provided by the technologies directly above with other personal information we hold about you.

By using our websites, you agree that third parties can place cookies on your device as described above.

You may obtain more information on the cookies (including third party cookies) used or object to the use of cookies at any time by addressing a request to BBH at the following address: matthew.ives@bbh.com.

Information We Disclose

We do not sell any Data that we collect about you. We do not disclose any Data about our current or former clients to anyone, except in connection with the processing purposes described above under the heading “Information We Collect”) (for example, with respect to transacting in certain jurisdictions, we may be required by contract or law to disclose certain personal or trading information) or otherwise with your prior consent.

If we disclose your Data to a location outside the European Economic Area,we take the steps reasonably necessary to ensure that your Data will be afforded an equivalent level of protection as that required from BBH by law and regulation.

Confidentiality and Security of Information

Our employees are governed by a Code of Ethics and are reminded of their obligations about keeping client information confidential through training, operating procedures, and BBH’s Privacy and Data Protection Policy. We also maintain physical, electronic, and procedural safeguards to protect this information.

We reserve the right to change this Privacy Notice at any time. This Privacy Notice is also available at www.bbh.com.