Privacy Notice

    

 

                                                                                                                                                                  Rev. May 2018

 

WHAT DOES LAZARD DO WITH YOUR PERSONAL INFORMATION?

 

Financial companies choose how they share your personal information. U.S. federal law gives our clients the right to limit some but not all sharing. U.S. federal and other applicable law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

We do not disclose nonpublic personal information about our clients or former clients to third parties other than as described below.

Personal information we collect.

We collect personal information about you in connection with our providing advisory services to you. The legal basis for our collection of your personal information is our contract with you and our legitimate business interest to provide contractual services to you. The collection of this information is necessary for us to be able to provide advisory services to you and the failure to provide such information will result in our inability to provide our services. This information includes your social security number (for U.S. persons) and may include other information such as your:

 

  • Assets and income;
  • Investment experience;
  • Transaction history;
  • Credit history; and
  • Wire transfer instructions.

How we collect this information.

We collect this information from you through various means. For example, when you give us your contact information, enter into an investment advisory contract with us, buy securities (i.e., interests in a fund) from us, direct us to buy or sell securities for your account, tell us where to send money, or make a wire transfer. We also may collect your personal information from other sources, such as our affiliates1 or other non-affiliated companies (such as credit bureaus).

1 Our affiliates are companies related to us by common ownership or control and can include both financial and nonfinancial companies. Non-affiliates are companies not related to us by common ownership or control and can include both financial and nonfinancial companies.

 

How we use this information.

All financial companies need to share customers’ personal information to run their everyday business and we use the personal information we collect from you for our everyday business purposes. These purposes may include for example:

  • To provide advisory services to you;
  • To open an account for you;
  • To process a transaction for your account;
  • To market products and services to you; and/or
  • To respond to court orders and legal investigations.

If you are an investor located within a European Union country, please note that personal information may be collected, shared and/or stored outside of the European Union.

Disclosure to others.

We may provide your personal information to our affiliates and to firms that assist us in servicing your account and have a need for such information, such as a broker, counterparty, fund administrator or third party service provider that aggregates data in a central repository for access by a broker, counterparty or fund administrator to provide its services. We may also disclose such information to service providers and financial institutions with which we have a formal agreement to provide services relating to our arrangements with you. We require third party service providers and financial institutions with which we have a formal agreement to provide services relating to our arrangements with you to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them. These sharing practices are consistent with applicable privacy and related laws, and in general, you may not limit our use of your personal information for these purposes under such laws. We note that the U.S. federal privacy laws only give you the right to limit the certain types of information sharing that we do not engage in (e.g., sharing with our affiliates certain information relating to your transaction history or creditworthiness for their use in marketing to you, or sharing any personal information with non-affiliates for them to market to you). We may also share your personal information with non-affiliates (such as a government agency or regulatory authority) as required by applicable law.

 

How we protect your personal information.

To protect your personal information from unauthorized access and use, we use security measures that comply with applicable law. These measures include computer safeguards and secured files and buildings.

 

How long we keep your personal information.

We retain your personal information for the duration of your advisory relationship with us and for a period of time thereafter as required by applicable law.

Your rights with respect to this information.

If you are an investor located within a European Union country, you have the following rights with respect to your personal information:

 

  • The right to request and obtain a copy of your personal information that we maintain;
  • The right to correct your personal information that we maintain;
  • The right to request the erasure of your personal information from our systems, subject to applicable recordkeeping requirements applicable to us; and
  • The right to lodge a complaint with a supervisory authority.

Who is providing this Privacy Notice.

This Privacy Notice relates to the following entities:

  • Lazard Asset Management LLC
  • Lazard Asset Management (Canada), Inc.2
  • Lazard Asset Management Securities LLC

2 Lazard Asset Management (Canada), Inc. does not disclose any non-public personal information about its customers to any third party, except as permitted by or required by any applicable law, including the laws of the United States and Canada.

California Consumer Privacy Act

 

Under the California Consumer Privacy Act of 2018, California residents have certain rights regarding the Personal Information collected by businesses, including Lazard. More information can be found at CCPA.

 

Who to contact with questions.

If you have any questions about this Privacy Notice, please call (800) 823-6300 or visit our website at http://www.lazardassetmanagement.com.

 

 

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