Privacy Policies

United States and Canada Privacy Policy

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.

Your privacy is important to Intech. This Privacy Policy applies to our website www.intechinvestments.com (“Website”) as well as to certain direct marketing communications you may receive from us via e-mail. Intech strives to protect your online privacy, while providing an enjoyable website experience that among other functions, provides information about our firm, and products and services that are relevant and useful to you.

The purpose of this Privacy Policy is to notify and inform you of how and the purposes for which we collect, use, and disclose Personal Information (as defined below). It also describes your choices regarding our use of your Personal Information.

Please review this Privacy Policy carefully. By using the Website, you are accepting the terms of this Privacy Policy as well as our Terms of Use, which means that you will be consenting to our collection, use, disclosure, and retention of your Personal Information as described in this Privacy Policy. If you do not agree with any part of this Privacy Policy or our Terms of Use, you are not permitted to use this Website.

This Privacy Policy is currently only provided in English. For investors located in Quebec, please contact info@intechinvestments.com for a French version of this document.

1. Important Information

1.1. Changes to this Privacy Policy

We may update this Privacy Policy from time to time by posting a new version online. You should check this page occasionally to review any changes. The date on which the Policy was last revised appears at the bottom of the page so that you can easily determine if we have made changes since the last time you reviewed this Policy. If we make any material changes, we will notify you by posting the revised Privacy Policy on our Website. By using the Website, including providing us with your Personal Information, after changes are made to this Policy, you will be agreeing to the terms of the updated Privacy Policy. If you do not accept any changes to this Privacy Policy, you must stop using the Website.

1.2. Contact Us

If you have any questions about this Privacy Policy or our treatment of your Personal Information, please contact us by email 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

2. Personal Information We Collect

2.1. When You Visit Our Website

You are free to explore the Website without providing any information about yourself except Navigational Information (see below). You may choose to share your Personal Information with us but doing so is voluntary, except as otherwise set out in this Policy.

2.2. “Personal Information”

This refers to any information that identifies you personally, including contact information, such as your name, e-mail address, home address, contact number, and other information about yourself that is collected by us through the Website.

2.3. “Navigational Information”

This refers to information about your computer and your visits to this Website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please also see the “Navigation Information” section below.

2.4. Information About Children

The Website is not intended for or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13. If you believe that we have collected information about a child under 13, please contact us at info@intechinvestments.com, so that we may delete the information.

3. How We Use Personal Information We Collect

3.1. Compliance with Our Privacy Policy

We use the information we collect in compliance with this Privacy Policy, unless otherwise permitted or required by law.

3.2. We Never Sell Personal Information

We will never sell your Personal Information to any third party.

3.3. Use of Personal Information

In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to: (a) improve your browsing experience by personalizing the Website; (b) send information to you that we think may be of interest to you by post, email, or other means; and (c) send you marketing communications or other information relating to our business. We may share personal information with service providers to help us perform statistical analysis or provide client support. In our contracts with them, we prohibit such 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.

3.4. Use of Navigational Information

We use Navigational Information to operate and improve the Website. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about Intech.

3.5. Service Providers

We employ other companies and people to provide services to users of our Website and may need to share your Personal Information with them to provide information, products, or services to you. Examples may include removing repetitive information from prospect lists, analyzing data, providing marketing assistance, and supplementing the information you provide us in order to provide you with better service.

In all cases where we share your information with such persons, we explicitly require them to acknowledge and adhere to our privacy and other client data handling policies to ensure that the information in its care is properly safeguarded at all times.

3.6. Security of Your Personal Information

We have physical, administrative, procedural, and technical safeguards in place to protect your information from unauthorized access, use, or disclosure. We regularly adapt these controls to respond to changing requirements and advances in technology. We also contractually require that our third-party service providers protect such information. When sensitive Personal Information (such as geo-location data) is collected on our Website and/or transmitted to other websites, it is protected using encryption, such as the Secure Socket Layer (SSL) protocol.

As a condition of employment, Intech employees are required to follow all applicable laws and regulations, including data protection laws, and receive periodic training on data protection. Access to sensitive information is limited to those employees who need it to perform their roles. Unauthorized use or disclosure of confidential client information by an employee is prohibited and may result in disciplinary measures.

If you have any questions about the security of your Personal Information, you can contact us at info@intechinvestments.com.

3.7. Social Media Features

Our Website and third party social media venues may include social media features, such as the Facebook “Like” button and Widgets, such as “Share.” These features may collect your IP address, which page you are visiting on our Website, and set a cookie on our Website to enable the feature to function properly. Social media features and Widgets are either hosted by a third party or hosted directly on our Website. This Privacy Policy does not apply to features hosted on third party websites. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them, which can be found on their respective websites.

3.8. External Websites

Our Website may sometimes provide links to other websites. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to their own privacy and other policies.

3.9. Public Forums

We may offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you choose to post any information on our public message boards, blogs, or forums, this information will be publicly available and may be collected and used by other users. We will correct or delete any information you have posted if you so request, as described in “Opting Out and Unsubscribing” below, however we are not able to require the deletion of information collected by other users. We suggest you give careful consideration before posting information on our publicly accessible message boards, blogs, and community forums.

3.10. Retention of Personal Information

We retain Personal Information that you provide us as long as we consider it potentially useful in contacting you about our services, unless you withdraw your consent for us to contact you, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements, and then we securely delete the information. We will delete your Personal Information from our servers at an earlier date if you so request, as described in “Opting Out and Unsubscribing” below unless such information is required to be maintained pursuant to regulatory or legal requirements.

3.11. Corporate Events

Upon the sale or transfer of Intech and/or all or part of its assets, your personal information will be among the items sold or transferred. We will request a purchaser to treat our data under the privacy policy in place at the time of its collection. In this event, you will be notified via email and/or a prominent notice on our Website, of any change in ownership.

3.12. Additional Uses and Disclosures

In addition to the use of your Personal Information set out above and the disclosure of your Personal Information that is required to provide you with our products, services, and other information that you have requested, we reserve the right to use or disclose your Personal Information if required by law, a court order or legal process, or if we reasonably believe that the use or disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud or other violations or suspected violations of the law. Your Personal Information will be processed in the United States and subject to applicable privacy laws. Your Personal Information may be accessible to law enforcement as well as federal and state authorities.

4. How We Use Cookies

4.1. 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 analyze 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, but do provide us with personally identifiable information and data statistics about your use of the Website. Please see Section 4.6. for further information regarding how cookies apply to targeted emails that may be sent to you.

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 behavior 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.

For more information about deleting or blocking cookies, please visit www.allaboutcookies.org.

4.2. 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.

4.3. 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.”

4.4. 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. 

4.5. 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.

4.6. Information Collected from Marketing Emails

When you receive content from us through marketing emails, you have to select one of two options before being able to view the content as follows: (1) accept and be tracked or (2) continue without tracking. If you agree to be tracked, we will know if you opened the content, and how long you viewed each page of content. We collect this information for marketing and statistical purposes as well as for internal analytics.

When you interact with our targeted emails, we automatically receive and record information on our server logs from your browser including your IP address via a cookie that is placed on your computer. This particular cookie saves your preference so that when returning you will not have to make the selection again. Refer to our Cookie Policy for additional information.

4.7. Advertising

We collaborate with a third-party ad network to manage any 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.

4.8. Third Party Tracking Technologies

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

5. Opting Out and Unsubscribing

5.1. Reviewing, Correcting and Removing Your Personal Information

Upon request, Intech 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. (Please also see Section 7 if you are a resident of the State of California).

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

• To review your Personal Information without charge. However, there are certain exemptions that allow us to deny 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.

To exercise any of these rights, please contact us 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.

5.2. To Unsubscribe From Our Communications

You may unsubscribe from our 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.

6. Disputes

6.1. Resolving Disputes

If you have a dispute with us relating to our privacy practices, please contact info@intechinvestments.com. Most disputes can be resolved that way. 

7. Important Information for California Residents

California residents have certain privacy rights as specified under California law, including the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act (the “CPRA”). Please click on the following link to view our California Privacy Notice: https://www.intechinvestments.com/california-privacy-notice/.

8. Contact Information

If you have questions or comments about our Privacy Policy, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at:

Phone: 1-561-775-1100

Email: info@intechinvestments.com

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

We thank you for taking the time to read this Privacy Policy.

Effective 2023-09-11

Europe Privacy Policy

At Intech, maintaining your privacy is important to us and we take precautions to safeguard your information. After all, your relationship with us is built on trust and our goal is to preserve that trust. This policy applies where we are acting as a data controller with respect to your information; in other words, where we determine the purpose and means of the processing of that information. This policy sets out the basis on which your information is collected, stored, and used by us.

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 collects and uses information in the ordinary course of business and is therefore responsible for ensuring that it uses that information in compliance with all applicable data protection laws. This Privacy Policy governs the handling of your information by Intech.

This Privacy Policy explains how your information may be held by Intech and how it may also be shared with and used by Janus Henderson Investors (“Janus Henderson”), in which we mean Janus Henderson Group Plc (reg. 101484), and its subsidiaries companies, including UK and international subsidiaries.

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

Janus Henderson Investors
Data Privacy Office
201 Bishopsgate
London
EC2M 3AE
United Kingdom

2. Information We Collect

By “information” we mean all of 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) or by your providing information to us when becoming a client of ours.

Information we collect from you when you visit and/or request to receive information from our website (by way of a non-exhaustive list):

• personal contact information (e.g. first name, family name, position in the company, company name, company email address, business phone number, business address, city, postcode and country); and
• how you access and use our website or other digital services (e.g. your IP address, your location, the device and software being used, pages visited, content viewed, links and buttons clicked through, etc.).

Information that we collect or generate about you includes (by way of a non-exhaustive list):

• the Intech services or products which you have engaged with and our interactions with you; and
• your visits to our website including information collected through cookies that store technical information and data statistics about the services that you use and how you use them, including your use of the Website and targeted emails that may be sent to you. For more information on the cookies used by Intech, please see our Cookie Policy.

If you are looking to become a client of ours, or are already a client of ours, in addition to the above, we may also collect or generate additional information about you. We typically obtain (by way of a non-exhaustive list):

• financial information associated with managing your account with us, including bank account numbers and account transactions;
• investment details including aims and/or objectives, and risk profile;
• regulatory requirements, such as country of tax residency, tax identification number, signature, death and marriage certificates, appointed power of attorney, appointed court of protection order, bankruptcy orders, change of name deed, and trust deed;
• information about other people you are financially linked to (e.g. your spouse) or who have an interest in or association with any of your accounts (e.g. where you have opened an account for the benefit of a child);
• new account information, including date of birth and/or age, city or country of birth, and nationality;
• employment status including whether you are employed, retired, or receive benefits;
• proof of identification information, which may include a copy of your driver’s license, passport, or other appropriate identification documentation (depending on what you provide to us); and
• any other relevant information provided by you to us in correspondence, whether by email, written letter, or telephone call.

There may be some instances where we receive information about you from a third party such as an investment consultant. This includes (by way of a non-exhaustive list):

• information received when you use an investment professional/consultant during the preparation of an advisory contract;
• information received from any fraud protection agency in relation to you, your account or any of your investments;
• background checks including information from social media; and
• events which you registered for and/or attended that featured an Intech or Janus Henderson investment product.

In addition to the categories of information described above, we will also process further anonymised information and data that is not processed by reference to a specific individual. Your information may be converted into statistical or aggregated data which cannot be used to re-identify you. It may then be used to produce statistical research and reports, which may be shared within Intech or Janus Henderson.

3. How and Why We Use Your Information

We process your information to the extent necessary for us to carry out investment activities, provide communications to you, meet our regulatory obligations and for other legitimate purposes permitted by applicable law. Your information may be stored and processed by us in the following ways and for the following purposes (by way of a non-exhaustive list):

• opening of accounts, administering and managing your investment account(s) (as applicable), updating your records and tracing your whereabouts to contact you about your account;
• understanding your needs and interests;
• allowing you to use and access the functionality provided by our website services;
• communicating with you, where you have requested or consented, regarding any product or service or any other situation where you have engaged us to provide you with information;
• recording of incoming and outgoing calls for training, monitoring, and security purposes;
• ensuring the security of your investments by obtaining and/or verifying instructions either directly from you or through an agent appointed to act on your behalf;
• notifying you about any change to your investments, and/or to contact you about and enable you to exercise any rights in relation to your investments;
• investigating any complaint, dispute and/or any concerns relating to your investments and or activity on your account;
• identification verification, money laundering and other checks to confirm your identity and to ensure that the investments which we handle for you are done in compliance with our legal obligations;
• maintaining a register of investors;
• reviewing and improving the performance of our website and your use of it (including any personalisation which you may have indicated and which we have retained using cookies (refer to our Cookie Policy for additional information));
• managing and administering our business;
• complying and assessing compliance with applicable law, rules and regulations and internal policies and procedures;
• administering and maintaining databases that store information;
• for some of our profiling and other automated decision making, which may be relevant to your investments and/or the way we manage your investments;
• anonymisation that enables us to undertake market research, analysis and developing statistics from information that is not referenced to a specific individual;
• for marketing communications (where it is lawful for us to do so and where you have not objected to the use of your information for these purposes), including certain direct marketing communications you may receive from us via email;
• when you receive content from us through marketing emails, you have to select one of two options before being able to view the content as follows: (1) accept and be tracked or (2) continue without tracking. If you agree to be tracked, we will know if you opened the content, and how long you viewed each page of content. We collect this information for marketing and statistical purposes as well as for internal analytics;
• when you interact with our targeted emails, we automatically receive and record information on our server logs from your browser, including your IP address via a cookie that is placed on your computer. This particular cookie saves your preferences so that when returning you will not have to make the selection again. Refer to our Cookie Policy for additional information;
• to carry out searches at fraud protection agencies pre-application, at the application stage, and periodically after that; and
• to deal with requests from you to exercise your rights under data protection laws.

Whenever we use information, we make sure that the usage complies with all applicable laws. Data protection laws require us to have one or more of the following reasons:

• ‘Contract performance’ – the information needed to deliver your account, product or service (e.g. we’ll need to hold your transaction history to give you an account statement).

• ‘Legal obligation’ – we are required by law to process your information (e.g. to verify your identity).

• ‘Legitimate interest’ – we’re allowed to use your information where, on balance, the benefits of us doing so are legitimate and not outweighed by your interests or legal rights (e.g. we have an interest in knowing what our clients do and don’t like so we can offer better products and services).

• ‘Consent’ – in some cases we may obtain your consent to use information in a particular way or where the law requires consent to be obtained (e.g. if you consent to us sending information about new products. Whenever ‘consent’ is the only reason for us using the information you have the right to change your mind and change or withdraw your consent).

4. Sharing of Your Information

We may share your information within Janus Henderson (both in the UK and internationally) for the purposes described above. All of our employees and contractors are required to follow our data privacy and security policies when handling information.

We may also share your information outside Janus Henderson 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.

5. Your Rights

You have the following rights under data protection laws within the EU. In most cases you can exercise them free of charge. However, since Intech is based in the United States, you may not be entitled to all of the rights set out in this section.

You have the right to:

• be informed about the processing of your information;

• have your information corrected if it is inaccurate and to have incomplete information completed;

• object to or restrict processing of your information. Please note that there may be circumstances where you object to, or ask us to restrict our processing of your information, but we are legally entitled to refuse that request;

• withdraw your consent to processing of your information at any time. Please note, however, that we may still be entitled to process your information if we have another legitimate reason for doing so (e.g. we may need to retain information to comply with a legal obligation);

• have your information erased in certain circumstances. Please note that there may be circumstances where you ask us to erase your information but we are legally entitled to retain it;

• request access to your information and to obtain information about how we process it;

• move, copy, or transfer your information;

• receive some information in a structured commonly used and machine-readable format and/or request that we transmit that data to a third party where technically feasible. Please note that this right only applies to information which you have provided directly to Janus Henderson and may not always apply;

• lodge a complaint with the relevant data protection regulator if you think any of your rights have been infringed by us;

• be informed how your information is used in relation to automated decision making which has a legal effect on or otherwise significantly affects you.

You can exercise your rights by submitting an online request or contacting us via email at privacy@janushenderson.com.

Please note that if you withdraw your consent for the future processing of your information we may be unable to send you some marketing communications or information regarding events sponsored by Intech or Janus Henderson. Additionally note, when we send you marketing, you will always be provided with an option to unsubscribe or opt out of receiving further marketing from us.

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

Janus Henderson Investors
Data Privacy Office
201 Bishopsgate
London
EC2M 3AE
United Kingdom

In the EU, you have the right to complain to the data protection regulator in your jurisdiction. Since Intech is a subsidiary of a European company headquartered in the UK, you can also contact the Information Commissioner’s Office, which enforces data protection laws: https://ico.org.uk/.

6. Storage, Transfers and Retention

The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (the “EEA”). It may be processed by staff operations outside the EEA who work for us or for one of our service providers.

Where we transfer your information to another country outside the EEA, and/or outside your country of citizenship or residency, we will ensure that it is protected and transferred in a manner consistent with legal requirements. For example, this may be done in one of the following ways:

• the country that we send the information to might be approved by the European Commission or the relevant data protection authorities as offering an adequate level of protection for information;
• the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your information;
• the country that we send the information to may subscribe to an “international framework” intended to enable secure data sharing; or
• in other circumstances the law may permit us to otherwise transfer your information outside the EEA and/or outside your country of citizenship or residency.

You can obtain more details of the protection given to your information when it is transferred outside the EEA (including a copy of the standard data protection clauses, which we have entered into with recipients of your information) by contacting us via email at privacy@janushenderson.com or via postal service at:

Janus Henderson Investors
Data Privacy Office
201 Bishopsgate
London
EC2M 3AE
United Kingdom

We will retain 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.

7. Security

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 to the standard required in the EEA. We regularly adapt these controls to respond to changing requirements and advances in technology.

As a condition of employment, Intech and Janus Henderson 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.

8. Making Changes to This Information

We will keep this information up to date and it will always be available at intechinvestments.com or upon request at any time. The date at the bottom of this Privacy Policy indicates when it was last updated.

9. Important Information for California Residents

This additional information is being provided as required by the California Consumer Privacy Act (the “CCPA”). The CCPA provides California residents with specific privacy rights, including the right to:

• Know what personal information we collected about you during the last 12 months;
• Request the deletion of your personal information collected or maintained by us;
• Receive equal treatment for exercising these rights (i.e., we shall not discriminate against you for exercising any of your rights under the CCPA); and
• Receive this information in a readily assessable format.

10. Making Changes

We will keep this information up to date and it will always be available at intechinvestments.com or by request at any time.

Thank you for taking the time to read this Privacy Policy.

Effective 2023-09-26

Australia 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 conduct financial services in Australia pursuant to an exemption from the need to hold an Australian financial services licence under the Australian Corporations Act 2001. Intech has a services agreement with Janus Henderson Investors (Australia) Limited (ABN 47 124 279 518) and its subsidiary entities Janus Henderson Investors (Australia) Funds Management Limited (ABN 43 164 177 244) and Janus Henderson Investors (Australia) Institutional Funds Management Limited (ABN 16 165 119 531). Intech is registered and regulated by the United States Securities & Exchange Commission (SEC) under U.S. laws, which differ from Australian laws (SEC File No.: 801-60987). Unless stated otherwise, information on this website is provided by Intech.

At Intech, maintaining your privacy is important to us and we take precautions to safeguard your information. We comply with the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (“APPs”) in the Act and any other applicable privacy laws when handling personal information.

Intech collects and uses information in the ordinary course of business and is therefore responsible for ensuring that it uses that information in compliance with all applicable data protection laws. This Privacy Policy explains the ways we collect, hold and disclose your Personal Information including in relation to our website, www.intechinvestments.com, as well as to certain direct marketing communications you may receive from us via email. “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

Or, in Australia, you may contact us at:

Privacy Officer
Level 36, Grosvenor Place
225 George Street Sydney NSW 2000

By email: RiskComplianceAustralia@janushenderson.com

By calling our Sydney office: +61 2 8298 4000.

2. Collection of Personal Information

In the course of our business activities, we may collect and hold personal information about you. Most of the personal information collected by us is personal information that you have provided to us directly, whether this is from you signing up online to receive information from us or by you providing information to us when becoming a client of ours. When you invest in a financial product that is offered by us, personal information about you (such as your name, postal address, date of birth, bank account information and tax file number) is collected primarily through our standard forms (such as our application form).

When you visit our website, we may collect technical and navigational information, such as device type, browser type, internet protocol address, pages visited, and average time spent, user journeys and demographics. Information is collected via our website through cookies that store technical information about the services that you use, and how you use them. For more information on the cookies used by us please see below under the heading “Dealing with Intech online.”

The types of personal information we collect may include your name, investor number, residential and postal address, phone number, email address, postcode and date of birth when you complete forms or sign up to publications on our website. We collect your personal information for the purpose of:

• providing you with communications and marketing material;
• generating information about you to provide Intech/Janus Henderson Australia investment services or products;
• carrying out investment activities;
• interacting with you when you visit our website; and
• complying with our legal and regulatory obligations, including under Anti Money Laundering and Counter Terrorism Financing (“AML/CTF”) laws.

As a specialist investment manager, we do not typically collect sensitive information (for example health information or information about any criminal record). However, in the event we consider the collection of this sensitive information is necessary, we will seek your prior consent and we will only collect, use and disclose sensitive information it in accordance with the APPs.

There may be some instances where we receive your personal information from a third party. This includes personal information received when you use a financial adviser or investment consultant to make an application with us, personal information received when you are being screened to comply with AML/CTF laws, and personal information received when you register for and/or attend events that featured a Janus Henderson or Intech investment product.

3. Use and Disclosure of Personal Information

We may use or disclose your personal information for the purpose for which it was collected and/or for a purpose you consent to or if we are authorised or required by an Australian law.

We may process further anonymised or de-identified information and data that is not processed by reference to a specific individual. For example, information may be converted into statistical or aggregated data, which cannot be used to re-identify you. It may then be used to produce statistical research and reports, which may be shared within Janus Henderson. This information may be used by us to analyse the efficacy of our marketing campaigns, improve our products and services, and improve our website design and functionality.

We may disclose your personal information to our related companies within the Janus Henderson Investors group of companies (both in Australia and internationally) who assist us in supplying our services or manage and administer investments, handle complaints, or supply administrative or other functions on our behalf. All of our employees and contractors are required to follow our global data privacy and security policies when handling personal information. We may also disclose your personal information to others in the following circumstances:

• where we outsource some of our administrative and related functions to external third parties;
• to relevant Government bodies to meet our legal and regulatory obligations (such as ASIC, ATO, AUSTRAC or a law enforcement agency);
• with your prior consent to parties authorised by you such as a licensed financial adviser or dealer group; to any joint holder of an investment; and
• to a third party buyer for due diligence purposes if we sell some or all of our business or assets.

We use third party software, investment administrators, and registries to support the administration of our financial products. We have contractual arrangements with these service providers to ensure they comply with the Privacy Act and the APPs when dealing with your personal information.

Some of the recipients to whom we disclose your personal information may be located outside of Australia. The countries in which the recipients are likely to be located include the United States and the United Kingdom.

We will not sell your personal information to other organisations and will not provide parties external to Janus Henderson Australia with your personal information for purposes unrelated to the purpose for which it was collected, or to comply with our legal or regulatory obligations.

4. Direct Marketing

If you consent to receiving direct marketing from us in order for us to tell you about our products, services, offers, investment or events that we think may be of interest to you, we may use your personal information to contact you by mail, email or SMS for direct marketing. You can contact us at any time to opt out of receiving direct marketing at any time, or using the unsubscribe function in the email or SMS, if you do not wish to receive such materials or information.

4.1 Information Collected from Marketing Emails

When you receive content from us through marketing emails, you have to select one of two options before being able to view the content as follows: (1) accept and be tracked or (2) continue without tracking. If you agree to be tracked, we will know if you opened the content, and how long you viewed each page of content. We collect this information for marketing and statistical purposes as well as for internal analytics.

When you interact with our targeted emails, we automatically receive and record information on our server logs from your browser, including your IP address via a cookie that is placed on your computer. This particular cookie saves your preference so that when returning you will not have to make the selection again. Refer to our Cookie Policy for additional information.

5. Accessing and Correcting Personal Information

If you feel your personal information is not accurate, complete, or up to date, please notify us. If we are satisfied that any personal information we hold about you is inaccurate, incomplete, out of date, misleading or irrelevant (having regard to the purpose for which it is held) we will take reasonable steps to correct that personal information. If we do not agree that your personal information needs correction, you may ask that we attach a statement to this effect to our record.

You may also request access to your personal information (subject to certain legal exceptions). If a legal exception applies and we decide not to provide you with access to any personal information we hold about you, we will advise you of the reasons for our decision and how you can complain.

Please contact our Privacy Officer at:

Privacy Officer
Level 36, Grosvenor Place
225 George Street Sydney NSW 2000

By email: riskcomplianceaustralia@janushenderson.com

By calling our Sydney office: +61 2 8298 4000.

6. Integrity, Security and Storage of Personal Information

We will take reasonable steps to keep your personal information secure and take all reasonable steps to safeguard your personal information from misuse or loss, and unauthorised access, modification or disclosure, and to ensure that the personal information we collect and hold about your is correct. To assist us, please ensure that the information you provide is accurate, up-to-date, and complete and let us know if your details change.

We have physical, electronic and procedural safeguards to protect your information, which is held by us. For example, your personal information is stored in secured office premises, electronic databases requiring logins and passwords for access and/or at one of our secured warehouses, we use encryption when transmitting personal information, firewalls, and intrusion detection systems to help prevent unauthorised persons from gaining access to the personal information. Access to information stored electronically is restricted to staff whose job purpose requires access.

As a condition of employment, 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 any misuse or unauthorised access, modification or disclosure, please let us know so we can investigate and take appropriate steps.

We will retain information as needed to fulfil 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. If we hold personal information about you that is no longer needed for any purpose for which we are permitted to use or disclose it, we will take reasonable steps to destroy or permanently de-identify that personal information.

7. Can You Deal With Intech or Janus Henderson Anonymously?

We are a financial services provider subject to strict regulatory requirements. We thus do not provide our products and/or services to clients on an anonymous basis. General enquiries however can be made on an anonymous basis.

8. Dealing With Intech Online

We may use “cookies” to help us tailor our website to better suit your needs (e.g. cookies to enable us to save any personal preferences indicated by you) and to provide more effective web navigation. A cookie is a small data file that contains information about your visit to our website. This information is provided by your computer during your first visit to our website. Our server records this information in a text file and stores this file on your hard drive. When you visit our website again, our server looks for the cookie and may structure itself based on the information contained in the cookie. A cookie only identifies your computer when you visit our web site; it does not identify you. Refer to our Cookie Policy for further information.

9. Contacting Us

If you have any questions about this Privacy Policy or wish to make a complaint about how we have handled your personal information, please contact our Privacy Officer (contact details provided above). If you make a complaint, we may need to verify your identity and request further information in order to respond. We will provide a response within a reasonable period of time.

We will endeavour to answer any questions, correct any error on our part or resolve any complaint you may have about our information handling practices. 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 the OAIC generally requires that any complaint must first be made to the respondent organisation. The law also allows 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
https://www.oaic.gov.au/

10. Changes to this Privacy Policy

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 services including our website.

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

Effective 2023/09/26