Cookie & Privacy Policy

Scope

Pzena Investment Management, LLC and its affiliates, including Pzena Investment Management, Ltd and Pzena Investment Management Europe Limited, (collectively, “PIM”) are committed to protecting your privacy and that of your business and employees, while providing you, your clients, the organization you represent or your organization’s clients, with the opportunity to receive our services.

Privacy Notice

Who are we?

PIM was founded in late 1995 and began managing assets on January 1, 1996. The Firm is an investment manager based in New York with a strict focus on long-term classic value investing. We offer global, international, emerging markets, U.S. and other regional long-only equity products. In 2014, Pzena launched our inaugural long/short equity strategy. The Firm’s experience and offerings span small, medium and large market capitalization thresholds. In addition to our New York headquarters, PIM has business development/client service offices in Australia and England and an operationally focused office in Ireland.

What Personal Data do we collect?

For the 12-month period prior to the date of this Privacy Policy, we explain here what categories of personal information we have collected, where we got it, why it is needed, and with whom we shared it:

Category of Personal Information Collected	Source of Information	Purpose for Collection	Categories of Recipients
Contact and Background information, such as your name, address, email address, telephone number, and job title	From you or from the platforms or advisers through whom you invest	To deliver investment management services or products to you, your clients, the organization you represent or your organization’s clients; to inform you about our services, new developments in the equity markets and our marketing events; to perform the contract we have entered into with you or anticipate entering into with you; to comply with a legal obligation; for administrative or operational processes within PIM; and for direct marketing or other communication to you, your clients, the organization you represent or your organization’s clients in respect of our services or products	Service providers as may be necessary to provide services for you, your clients, the organization you represent or your organization’s clients (e.g., brokers, custodians for your accounts); service providers who assist us in administering and operating our business to meet client and regulatory expectations (e.g., disaster recovery backups, e-mail retention systems); service providers who assist us in communicating with and marketing to you (e.g., CRM systems, Microsoft Office 365); advisers (e.g., auditors, legal counsel and tax advisers) to PIM or our funds relating to the services we provide you, your clients, your employer or your employer’s clients; and our affiliates, for the purpose of providing our services.
Personal and financial data, such as bank account details, source of wealth information, accounts, and copies of passport or other official documentation	From you (through contracts, onboarding forms, subscription documents or other documents you may submit) or from the platforms or advisers through whom you invest	To deliver investment management services or products to you, your clients, the organization you represent or your organization’s clients; to perform the contract we have entered into with you or anticipate entering into with you; or to comply with a legal obligation.	Service providers as may be necessary to provide services for you, your clients, the organization you represent or your organization’s clients (e.g., brokers, custodians for your accounts); advisers (e.g., auditors, legal counsel and tax advisers) to PIM or our funds relating to the services we provide you, your clients, your employer or your employer’s clients; and our affiliates, for the purpose of providing our services.
Information you choose to provide to us, including communications from you to PIM by letter, telephone, email or any other means of electronic or personal communication; if you are applying to work with us, we will collect information about your education and professional experience, professional licenses and certifications, we may also collect work product samples and references and their relevant contact information	From you or third parties including recruitment agencies, social media platforms (e.g., LinkedIn), business contacts or other referrers, universities, professional associations, and career sites.	To handle your requests and to contact you when necessary or requested, including to respond to your comments and questions and provide customer service; if you are applying to work with us or one of our affiliates, we will use your personal data to process your employment application.	Service providers who assist us in communicating with and marketing to you (e.g., CRM systems, Microsoft Office 365); our affiliates, for the purpose of providing our services.
Information automatically collected from your browser, such as information on what pages have been accessed and for how long, the country from which you access our site, and certain technical information regarding computer and operating systems, such as the user’s Internet protocol address, domain name and browser type, and information collected from cookies and web beacons	From you; from our website technology’s interaction with your browser or devices	To make sure our website technology works properly with your device and make sure you can see and use our website on the device you are using understand how people use our website so that we can improve site functionality; to track the activity of anonymous and known individuals coming to our website; to inform us what content is effective; and to track receipt of emails to gauge the effectiveness of our communications.	Service providers who assist us in administering and operating our business to meet client and regulatory expectations (e.g., disaster recovery backups, e-mail retention systems); service providers to assist us in communicating with and marketing to you (e.g., CRM systems, Microsoft Office 365); and our affiliates, for the purpose of providing our services. PIM does not track people over time and across third party websites to provide targeted advertising.
Legal information, such as fraud checks or flags raised about your transactions, suspected crimes, complaints, claims and accidents	From you, the police, crime and fraud prevention agencies, the public, regulators, and your and our professional advisors and representatives	To protect you and our business against criminal activities and risks, make sure we understand and can meet our legal obligations to you and others and can defend ourselves	We may share your information with law enforcement agencies, regulatory or tax authorities and other governmental or public agencies or authorities in order to comply with our legal or regulatory obligations or at their request in furtherance of their objectives

In addition to the sharing of your personal information as described above, we also may disclose personal information we collect as follows:

In Connection with Business Transfers: In the event that a division or part or all of PIM is bought, sold or otherwise transferred, or is in the process of a potential transaction, customer information will likely be shared for evaluation purposes and included among the transferred business assets.

To Comply with Laws: PIM may also disclose specific information when such disclosure appears necessary to comply with the law, a subpoena or other litigation process or to protect the interests or safety of its visitors and customers, PIM employees or others. This may include transfers of information to law enforcement agencies; regulatory or tax authorities and other governmental or public agencies or authorities in order to comply with our legal or regulatory obligations or at their request in furtherance of their objectives.

With Third Parties: As noted above, PIM shares your personal data with certain categories of third parties, including service providers without first obtaining your consent. They may in turn use the services of their affiliates or service providers to process your personal data where necessary or appropriate. Where we share your personal data with such third parties, we require the recipients of that personal data to put in place adequate measures to protect it.

Pzena Cookie Statement

In order to enhance your website browsing experience, we place cookies onto your computer. Cookies are text files containing small amounts of information that are downloaded to your device when you visit a website. Cookies are useful because they allow us to customize and improve the users’ experience of our website. We also use cookies and anonymous identifiers that enable our computer system to recognize you when you next visit our site. Standing alone, cookies do not identify you personally; they merely recognize your browser. We also use web beacons on our websites and in email communications. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to our website. Such technologies are used to operate and improve our website and email communications, and we may tie the information gathered to your personal information.

By using our website you agree that, unless you have set your device’s browser to reject them, we may place the types of cookies set out below on your device, and use that data in accordance with this policy. PIM does not track people over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (“DNT”) signals.

What types of cookies are used and what choices do you have?

Changing your cookie preferences

The “Help” menu in the toolbar of most web browsers will tell you how to change your browser’s cookie settings, including how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. If you would like to find out more about cookies in general and how to manage them, please visit www.allaboutcookies.org.

For California Residents

Your California Privacy Rights

California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information.  As discussed elsewhere in this Privacy Policy, we do not currently share the personal information of California residents with third parties for their own direct marketing purposes. However, if you have further questions about our privacy practices and compliance with California law, please contact us as explained below.

If you are a California resident, the California Consumer Privacy Act provides you with the following rights with respect to your personal information:

• The right to request to know the categories or specific pieces of personal information we have collected, used, disclosed and sold about you. To submit a request to know, you may call us at 833-932-1492 or visit https://www.pzena.com/ccpa/. You also may designate an authorized agent to make a request for access on your behalf on our website at https://www.pzena.com/ccpa/.
• The right to request that we delete any personal information we have collected about you. To submit a request for deletion, you may call us at 833-932-1492 or visit https://www.pzena.com/ccpa/. You also may designate an authorized agent to make a request for deletion on your behalf on our website at https://www.pzena.com/ccpa/.

When you exercise these rights and submit a request to us, we will verify your identity by asking you to log in to your account if you have one with us. Or if you do not, we may ask for your email address or other proof of identity. PIM also may use a third-party verification provider to verify your identity.

The fact that you have elected to exercise these rights will have no adverse effect on the price and quality of our services. PIM does not sell your personal information to third parties.

Children’s Privacy. PIM does not knowingly solicit or collect personally identifiable information from children under the age of thirteen (13) without verifiable parental consent. If PIM learns that a child under the age of thirteen (13) has submitted personally identifiable information online without parental consent, PIM will take all reasonable measures to delete such information from our databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any personally identifiable information we have collected from children under thirteen (13), please contact us at Privacy@pzena.com.

Minors under 18 years of age may have the Personal Information that they provide to us deleted by sending an email requesting deletion to Privacy@pzena.com. Please note that, while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that data from all systems.

Questions

If you have questions regarding this Privacy Notice or to request this Privacy Notice in another form, please email us at Privacy@pzena.com.

For UK and European Individuals

This section of the privacy notice covers all personal data collected by PIM, the protection of which is governed by the European Union General Data Protection Regulation (“GDPR”). This privacy notice also covers all personal data collected by PIM, the protection of which is governed by the UK Data Protection Act 2018 and/or the GDPR as retained in Ireland.

PIM is the controller with respect to the personal data described below. Pzena Investment Management, Ltd. of 34-37 Liverpool Street, London EC2M 7PP is our representative in the UK for UK data protection purposes.  Pzena Investment Management Europe Limited. of Fitzwilliam Hall, Fitzwilliam Place, Dublin 2, Dublin, D02 T292 is our representative in Ireland for European data protection purposes.

Our Chief Information Officer (“CIO”) who is responsible for our data protection and other PIM employees dealing with data protection questions and requests can be contacted directly by e-mail at privacy@pzena.com or by phone at +1 (347) 643-0915.

Our lawful basis for processing of the personal data will depend on the purpose or purposes of why we collected and need to use your information, however under EU and UK data protection laws, in almost all cases the lawful basis will be:

• to perform the contract we have entered into with you or anticipate entering into with you;
• to comply with a legal obligation; or
• if 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:
  • providing of investment management services, and fulfilling our obligations to you, your clients, the organization you represent or your organization’s clients;
  • administrative or operational processes within PIM and direct marketing or other communication to you, your clients, the organization you represent or your organization’s clients in respect of our services or products;
  • to operate and improve our business and to help maintain quality; or
  • to comply with a legal obligation not set out under the laws of EU member states and / or the UK, or under contract, including for the establishment, exercise or defense of legal claims

International Transfers

Your personal data will be sent to and stored by us and third parties in countries outside the country in which you are located and outside of the European Economic Area (“EEA”) and / or the UK. The nature of our business means it is necessary for us to send your personal data outside the EEA and / or the UK to properly provide our services to you, your clients, the organization you represent, or your organization’s clients. This occurs because our business and the third parties we may use have operations in the United States and countries across the world. 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 that is consistent with, and respects the EU and / or UK laws and other applicable laws and regulations on data protection, including by entering into appropriate data transfer agreements with third party recipients of your personal information incorporating standard contractual clauses governing data transfer contracts which have been approved by the European Commission and / or approved by the UK government (as relevant). Please contact PIM at Privacy@pzena.com, if you would like a copy of the model clauses.

Disclosure

PIM will pass on your personal data to third parties without first obtaining your consent. The following third parties may receive your personal data for the following purpose(s) as part of the processing activities:

• Processors or sub-processors as may be necessary to provide services for you, your clients, the organization you represent or your organization’s clients (e.g., brokers, custodians for your accounts).
• Processors or sub-processors to assist us in administering and operating our business to meet client and regulatory expectations (e.g., disaster recovery backups, e-mail retention systems).
• Processors or sub-processors to assist us in communicating with and marketing to you (e.g., CRM systems, Microsoft Office 365).
• Advisers (e.g., auditors, legal counsel and tax advisers) to PIM or our funds relating to the services we provide you, your clients, your employer or your employer’s clients.
• Our affiliates, for the purpose of providing our services.

They may in turn use the services of their affiliates or service providers to process your personal data where necessary or appropriate. Where we share your personal data with such third parties, we require the recipients of that personal data to put in place adequate measures to protect it.

Retention period

PIM will retain personal data for as long as it is necessary for the purpose it is being processed for and will store the personal data for a sufficient period to handle or respond to any complaints, queries or concerns relating to such agreement or to satisfy any legal, regulatory, accounting or reporting requirements. The personal data may also be retained so that we can continue to improve our clients’ experience with us.

We will periodically review the personal data we hold in accordance with PIM’s policies. If there is no longer a legal or business need for the personal data to be retained, we delete it securely, or, in some cases, anonymize it.

Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organization.
• Right to object – you have the right to object to certain types of processing such as direct marketing, and where we rely on legitimate interests as the basis for processing. These rights may be limited in some circumstances, for example where we are required to process your personal data by law.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that PIM refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in the clause below.

All of the above requests will be forwarded on should there be a third party involved (as stated above) in the processing of your personal data.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by PIM (or third parties as described above), or how your complaint has been handled, you have the right to lodge a complaint with PIM’s data protection representative, and/or the CIO or directly with the relevant data protection supervisory authority (in the United Kingdom, the Information Commissioner’s Office and in Ireland, the Data Protection Commission). A list of data protection authorities is available at https://edpb.europa.eu/about-edpb/board/members_en. The details for each of these contacts are:

For the UK:

	Supervisory authority contact details	Chief Information Officer contact details
Contact Name:	Information Commissioner’s Office	Tracy Karagianis
Address line 1:	Wycliffe House, Water Lane	320 Park Avenue, 8th Floor
Address line 2:	Wilmslow	New York, NY 10022
Address line 3:	Cheshire SK9 5AF	USA
Email:	casework@ico.org.uk	karagianis@pzena.com
Telephone:	0303 123 1113 (local UK) +44 1625 545 700 (calling outside the UK)	+1 (347) 643-0915

For Europe:

	Supervisory authority contact details	Chief Information Officer contact details
Contact Name:	Data Protection Commission	Tracy Karagianis
Address line 1:	21 Fitzwilliam Square	320 Park Avenue, 8th Floor
Address line 2:	D02 RD28 Dublin 2	New York, NY 10022
Address line 3:	Ireland	USA
Email:	info@dataprotection.ie	karagianis@pzena.com
Telephone:	+353 76 110 4800	+1 (347) 643-0915