This Privacy Notice is provided to help you understand how we collect, use, share, and otherwise process your Personal Data in connection with your relationship with us as a Thornburg customer, acting for a customer or are generally interested in our products and services in accordance with applicable data privacy laws and the General Data Protection Regulation (“GDPR”) which will come into effect on 25 May 2018.

If you have any questions concerning this Privacy Notice, please contact us at privacy@thornburg.com.

“Personal Data” means any information relating to you such as your name, contact information, account details, etc. Personal data does not include data from which you can no longer be identified such as anonymized aggregate data.

Information we collect, how we use it and what we use it for

You typically provide Personal Data when communicating with us or other persons, in writing, by phone or electronically. Examples of this information include:

Name,
Address,
Social security number,
Date of birth, and
Information about your transactions.

This information may be provided in account applications, other forms and from your transactions with our affiliates, other persons and us. We also may request information for identification purposes, to fulfill regulatory requirements, and to assist you in making financial decisions and in performing transactions for you.

We will only process your Personal Data if (i) you have consented to us doing so, (ii) we need it to perform services under a contract we have entered into with you, (iii) we need to comply with a legal obligation, or (iv) 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 the providing of investment account services by us, administrative or operational process within Thornburg and direct marketing.

We will use your Personal Data to deliver investment related communication to you and to inform you about our products and services and our marketing events.

Please be aware that we may use or disclose your Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

Information on request

We may need to request certain information from you to help us confirm your identity and ensure your right to access your Personal Data, or to exercise any of your other rights. This security measure is reasonably designed to ensure that your Personal Data is not disclosed to anyone without a right to receive it.

If you choose not to provide us with some or all of the Personal Data we request, we may not be able to provide investment related services to you, enter into a contract with you, or send investment related communication to you as you may request.

Accuracy of information

It is important that the Personal Data we have about you is accurate and up-to-date. Please inform us when your Personal Data changes during your relationship with us.

Change of purpose, anonymization

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

Sharing your information

Any information described above may be shared among our affiliates which provide services in connection with your investment. We also may share this information with unrelated financial service providers, non-financial companies and others, which supply services related to your Thornburg account. Examples of these services are:

Transaction processing,
Account servicing,
Communications with shareholders, and
Developing and marketing new services and products.

We may also share your Personal Data with regulators, public institutions, courts or other third parties.

For the purposes described above we may have to transfer your Personal Data from the European Economic Area (EEA) to a Thornburg office or a third party outside of the EEA and in a jurisdiction not being subject to an adequacy decision of the European Commission. 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 consistent with, and in respect of EU and other applicable laws and regulations on data protection. If you require further information about this you can request it from privacy@thornburg.com.

Your rights related to your Personal Data

You have certain rights related to your Personal Data, including the right to:

Please contact us at privacy@thornburg.com if you want to exercise one of your rights.

You also have the right to make a complaint at any time with the Irish Data Protection Commissioner, or another competent supervisory authority within the EU.

Withdrawing consent

You have the right to fully or partially withdraw your consent to the collection, processing and transfer of your Personal Data. To do so, please contact us at privacy@thornburg.com. Unless we have compelling legitimate grounds for further processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims, we will stop processing your Personal Data for the purposes to which you originally consented to. You have the right to object at any time if your Personal Data was processed for direct marketing purposes and your Personal Data will no longer be processed for such marketing purposes.

Retention of your Personal Data

We will only retain your Personal Data for as long as necessary to fulfill any purpose for which it was collected and processed, as well as to satisfy any legal, regulatory or reporting requirements.

In determining how long to retain your Personal Data, we will consider the amount, nature and sensitivity of the Personal Data, the purposes for which we processed your Personal Data and if any other purposes are in existence, the risk of harm from unauthorized use or disclosure of your Personal Data and any applicable legal requirements.

We will destroy your Personal Data in accordance with applicable laws and regulations upon expiration of the applicable retention period.

Fees

In general, you will not have to pay a fee to exercise your rights under this Privacy Notice. In the event your request is unfounded or excessive, we may charge a reasonable fee or refuse to comply with your request depending on the circumstances.

Changes to this Privacy Notice

From time to time we may modify our Privacy Notice without notice, you are invited to review the policy periodically for changes.