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Information contained on this Website is published solely for general informative purposes and intended only for United States institutional investors, consultants, and financial advisers, and other intermediaries who are who are knowledgeable and experienced in the financial services market and in investment products of this nature. If you are a retail or individual investor then please leave this website immediately. The information is not authorized for use in a jurisdiction where distribution is not authorized and is not intended for distribution to retail clients. If you choose to access this Website from locations outside of the United States, you do so at your own initiative and risk, and are responsible for compliance with all applicable laws.

By accessing this site you confirm that you are an Institutional Investor, you agree not to forward or make the contents of this site available to any person who is not an Institutional Investor, and you agree to be subject to intechinvestments.com terms of use.


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Intech® Privacy Policy

1. Who we are and how to contact us

This is the Privacy Policy of Intech Investment Management LLC (also referred to throughout this policy as ‘Intech, we, us, or ‘our’ and ‘you’ or ‘yourself’ may refer to an individual, Independent Financial Advisor, consultant, company, or other entity visiting this website.

Intech is permitted to provide certain financial services to wholesale clients in Australia pursuant to an exemption from the need to hold an Australian financial services licence under the Australian Corporations Act 2001. Intech is regulated by the United States Securities & Exchange Commission (“SEC”) under U.S. laws, which differ from Australian laws. Unless stated otherwise, information on this website is provided by the issuer of the applicable financial product.

At Intech, maintaining your privacy is important to us and we take precautions to safeguard your information. We aim to maintain a high standard of compliance with the Commonwealth Privacy Act of 1988 (“Privacy Act”) and the Australian Privacy Principles (“APPs”) in the Privacy Act and any other applicable privacy laws when handling personal information. This Privacy Policy explains the way we manage, collect, use, and disclose your personal information including in relation to our website at www.intechinvestments.com/au. In this Privacy Policy, “personal information” means any information or opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not, and whether recorded in material form or not.

If you have any questions or concerns regarding our Privacy Policy, or how we process your information, please contact us via email at info@intechinvestments.com or by postal service at:

Intech
Attn: Chief Compliance Officer
250 S. Australian Ave., Suite 1800
West Palm Beach, FL 33401
United States of America

2. Collection of Personal Information

By “Personal Information” we mean information about you from which you can reasonably be identified as well all the personal and financial information about you that we collect, use, share, and store. Most of the information collected by us is information that you have provided to us directly, whether this is from you signing up online such as on our website www.intechinvestments.com/au or by your providing information to us when becoming a client.

When you visit our website, we may collect technical and navigational information, such as device type, browser type, internet protocol address (ITP), pages visited, and average time spent. Information is collected via our website through cookies that store technical information about your use of the website. For more information, please see 9. Dealing with us online – how we use cookies below as well as our Cookie Policy.

3. Legal and/or regulatory requirements

Intech as well as Janus Henderson Investors Australia (“Janus Henderson Australia”), our affiliate, do not typically collect sensitive information. However, in the event that we consider its collection necessary, we will seek your prior consent. Should Intech or Janus Henderson Australia receive unsolicited personal information deemed irrelevant to our business relationship, that information will be destroyed lawfully.

4. Use of Personal Information

We use the information we collect in compliance with this Privacy Policy, unless otherwise permitted or required by law. We may collect your Personal Information, such as your name, phone number, or email address when you complete forms online or wish to download certain content from our website. We collect this information for the purpose of providing you with communications and marketing materials that we think may be of interest to you by post, email, or other means; improving your browsing experience by personalizing the Website; generating information about you to potentially provide advisory services or products, to meet our regulatory obligations, and for other legitimate purposes permitted by applicable law.

We will retain Personal Information as needed to fulfill the purposes for which it was collected. We will retain and use your information as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements.

We will not retain your information for longer than is reasonably necessary. You can contact us at any time if you do not want to receive such materials or information from us or you can use the unsubscribe function in the email or SMS. Although we will not contact you any longer, we may still store your information to protect our interests or to meet regulatory or other legal requirements.

5. Sharing of Personal Information

We may share Personal Information with third party service providers to help us perform statistical analysis, or provide client support, which may be converted into statistical or aggregated data and cannot be used to re-identify you. It can then be used to produce statistical research and reports that may be shared with our affiliates. This information will be used to analyse the efficiency of our marketing campaigns, improve products or services, and improve our website design and functionality. We prohibit  service providers from using your Personal Information except as required to provide their services, and they are required to maintain the confidentiality of your information. We will never sell your Personal Information to other organizations and will not provide parties external to Intech or Janus Henderson Australia with your personal information for purposes unrelated to the purpose for which it was collected.

We will share your information outside Intech and Janus Henderson Australia under the following circumstances:

Legal obligations: we share information: (i) to the extent that we are required to do so by applicable law, governmental body, regulatory authority, law enforcement agency, or for crime prevention purposes (including fraud protection); (ii) in connection with any legal proceedings (including prospective legal proceedings); or (iii) in order to establish or defend our legal rights.

Service providers: we share information with service providers who perform services for us (including cloud services, portfolio accounting, data storage, sales, marketing, proxy voting, and customer support). Our contracts with our service providers include commitments that they agree to limit their use of information and to comply with privacy and security standards at least as stringent as the terms of our Privacy Policy.

Third-party relationships: we share your information with third parties, including our affiliates. These third parties will be subject to appropriate data protection obligations and they will only use your information as described in our Privacy Policy.

Consent: when you request that we share your information with someone else (for example if you engage the services of a professional consultant after you have become a client of ours and request that we provide information about your account to that professional consultant) or when we have otherwise obtained your consent. If we share information other than as permitted or described above, we will provide you with a choice to opt in to such sharing and you may choose to instruct us not to share the information.

Business sale: if we sell some or all of our business or assets we may need to disclose your information to a prospective buyer for due diligence purposes. If we are acquired by a third party, the information held by us about you will be disclosed to the third party buyer.

The recipients to whom we disclose your personal information may be located in Australia, the United States and the United Kingdom.

6. Access to your Personal Information

Upon request, we will provide you with information about whether we hold any of your Personal Information. It is important to provide us with sufficient detail to make the information reasonably retrievable.

If we are holding your Personal Information, you may request the following with respect to that information, unless otherwise set out in the law:

  • To review your Personal Information without charge. However, there may be circumstances where we may deny you access to your Personal Information. If we deny you access to review your Personal Information, we will inform you of the reason in writing within 30 calendar days.
  • To request that we correct any errors, outdated information, or omissions in the Personal Information.
  • To request that your Personal Information not be used unless we are required to use it for a legitimate reason (e.g., we may need to use your Personal Information to comply with a legal or regulatory obligation).
  • To request that your Personal Information be removed from any solicitation list that we use.
  • To request that your Personal Information be deleted from our records unless we are required to maintain such information pursuant to regulatory or legal requirements.

Please contact Intech at info@intechinvestments.com or by mail to:

Intech
Attn: Chief Compliance Officer
250 S. Australian Ave., Suite 1800
West Palm Beach, FL 33401
United States of America

We will respond to your request to change, correct, or delete your information within 30 calendar days and notify you of the action we have taken.

7. Security of Personal Information

We will endeavour to keep your Personal Information secure and take all reasonable steps to safeguard it from loss, and unauthorised access, modification or disclosure.

We retain information for so long as may be necessary to respond to issues that may arise at a later date, and longer in appropriate cases where required by law. When Personal Information is no longer required by us, it is destroyed.

We have physical, administrative, procedural, and technical safeguards in place to protect your information from unauthorised access, use, or disclosure. We also contractually require that our third party service providers protect such information. We regularly adapt these controls to respond to changing requirements and advances in technology.

As a condition of employment, Intech and Janus Henderson Australia employees are required to follow all applicable laws and regulations, including data protection laws. Access to sensitive information is limited to those employees who need it to perform their roles. Unauthorised use or disclosure of confidential client information by an employee is prohibited and may result in disciplinary measures. If you believe that the personal information we hold about you has been subjected to misuse or unauthorised access, modification or disclosure, please let us know so we can investigate and take appropriate steps.

8. Can you deal with Intech or Janus Henderson Australia anonymously?

Both Intech and Janus Henderson Australia provide financial services subject to strict prudential and regulatory requirements and do not provide our products and/or services to clients on an anonymous basis. General enquiries, however, can be made anonymously.

9. Dealing with us online – how we use cookies

Intech uses cookies and similar technologies to track users’ movements around the website, and gather demographic information about our user base as a whole to analyse trends and evaluate the website. We also use cookies to administer the website and to help you personalize your online experience.

A cookie is a text file that is placed on your hard disk by a Web server. Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to your computer, and can only be read by a Web server in the Internet domain that issued the cookie. One of the primary purposes of cookies is to provide a convenience feature to save you time by telling the Web server that you have returned to a specific page. For example, if you register for downloadable content on our website, a cookie helps us to recall your specific information on subsequent visits so that when you return to the website, the information you previously provided can be retrieved, bypassing the need to register again.

You should be aware that cookies and other similar identification methods may be used to associate you (as a user) with the computer or device that you are using. These cookies do not reveal your identity to us or provide us with personally identifiable information about your use of the Website. Some cookies may be stored on your computer and are not deleted when you close your browser. These permanent cookies retain your preferences for a particular website, allowing those preferences to remain for future browsing sessions, but do not collect information from you.

Intech also uses cookies to keep track of the pages you (as a user along with other users) visit in order to determine what portion of the website is the most popular or most used. This data is used to deliver customized content within the website to users whose behaviour indicates that they are interested in a particular subject area. You may opt-out of communications from us at any time or manage your email preferences to select the types of communications you would like to receive in the future.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the website.

Refer to our Cookie Policy for additional information.

9.1 Log files

We may collect demographic information, through log files. This information can include your IP address, geographic location, pages visited, browser type, domain names, internet service provider (ISP), the files viewed on our Website (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. We use this information to obtain general statistics regarding website use. For these purposes, it is possible for us to link this automatically collected data to your Personal Information such as your name, business email address, business address, and contact number.

9.2 Clear Gifs (Web Beacons/Web Bugs/Tracking Pixels)

We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs/Tracking Pixels), that help us better manage the website by informing us what content is effective. These are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user's computer hard drive, they are embedded invisibly on Web pages or in emails and are about the size of the period at the end of this sentence. These features let us know which emails have been opened by recipients allowing us to gauge the effectiveness of certain communications and the effectiveness of our marketing efforts. We tie the information gathered in emails to our clients' Personal Information. If you would like to opt-out of these emails, please see "Opting Out and Unsubscribing.”

9.3 Flash Cookies

The Adobe Flash Player (and similar applications) used on our website, employs technology to remember settings, preferences and usage similar to browser cookies, but these are managed through a different interface than the one provided by your Web browser. This technology creates locally stored objects that are often referred to as "Flash Cookies." Our website does not use Flash Cookies. We do not have access or control over these Flash Cookies, however, but you may access your Flash management tools from Adobe's web site directly here.

9.4 Wistia

Our website uses Wistia to power its videos. Wistia tracks how you interact with the videos on this site: how much of a video you watch, at what points in a video you pause or rewind, etc. In some videos, we may pause the video and request that you provide your email address or name. You are under no obligation to provide this information, but we reserve the right to limit certain videos to identified users. Wistia aggregates the data collected through the videos here, including names and email addresses, and provides it to us. Wistia does not sell or provide the data it collects to third parties.

9.5 Advertising

We collaborate with a third party ad network to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personal information about your activities on other Web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here: http://preferences.truste.com/. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

9.6 Third Party Tracking Technologies

Our Privacy Policy does not cover the use of cookies and web beacons by any tracking utility company.

10. To unsubscribe from our communications

You may unsubscribe from Intech’s marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, or by email to info@intechinvestments.com or by mail to:

Intech
Attn: Chief Compliance Officer
250 S. Australian Ave., Suite 1800
West Palm Beach, FL 33401
United States of America

Note: Existing Intech clients cannot opt out of receiving transactional emails related to their advisory account with us through this means.

11. Resolving disputes

If you have a dispute with us relating to our privacy practices, please contact info@intechinvestments.com. Most disputes can resolved that way. If we do not resolve a complaint to your satisfaction, you may refer the matter to the Office of the Australian Information Commissioner (“OAIC”). The OAIC has the power to investigate the matter and make a determination.

Please note that the OAIC generally requires that any complaint must first be made to the respondent organisation. The law also allow 30 days for the respondent organisation to deal with the complaint before a person may make a complaint to the OAIC.

The Commissioner can be contacted at:

Office of Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Fax: +62 2 9284 9666
Email: enquiries@oaic.gov.au
www.oais.gov.au

12. Making changes to this information

We may, from time to time, amend this Privacy Policy, in whole or part, in our sole discretion. Any changes to this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy on our website. Depending on the nature of the change, we may announce the change on our website. By continuing to access our services following any changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Privacy Policy, as amended from time to time, in whole or part, you must not access our website.

Thank you for taking the time to read this Privacy Policy and exploring our website.

Effective 2019/09/01

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