Effective Date: March 23, 2020
Hotchkis and Wiley Capital Management, LLC (H&W) and the Hotchkis and Wiley Funds (HW Funds) (collectively, “we”) value your trust and want you to be familiar with how we collect, use, and disclose information. This Online Privacy Policy describes our practices in connection with data that we may collect, maintain, and use in the course of providing information and access to reports though our website.
H&W and the HW Funds are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, you can be assured that it will only be used in accordance with this Privacy Policy.
Residents of California should review the privacy notice for the California Consumer Privacy Act of 2018 (CCPA).
H&W clients and persons invested in, or managing investments in, the HW Funds should review the appropriate privacy notice.
Personal Information We May Collect
The term Personal Information as used in this policy means any information that identifies you as an individual or relates to an identifiable person. The kinds of Personal Information we may collect depends on the nature of the relationship you have with us. This information may include your name, job title, employer, and contact details such as your address, email address, and telephone number. For job candidates, we may also collect information on your professional and employment background, level of education, social media profile URL and other protected characteristics under federal law (e.g., gender, ethnicity, disabilities, veteran status, etc.).
In addition to the information stated above, we may collect certain information about your use of our website, for example, we may capture your IP address, operating system, or browser, as explained in greater detail below in our “How We Use Cookies” section of this policy.
How We May Collect Personal Information
In most cases, we collect information directly from the person or entity with whom we have the relationship through client correspondence, information request forms, general website usage, or job applicant information portal.
How We May Use Personal Information
We require and use this information to understand your needs and provide you with a better service. More particularly, we use information we gather to do the following:
- Maintain internal records;
- Provide and/or improve our products and services;
- Send promotional email with information which we think you may find interesting using an email address which you have provided;
- Conduct recruiting activities; and
- Contact you by email, phone, fax or mail to respond to inquiries made through our website.
Security
We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
How We Use Cookies
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. Our cookies do not give us access to your computer or any information about you, other than the information you choose to share with us.
You can choose 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. This may prevent you from taking full advantage of the website.
Links to Other Websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Policy. You should exercise caution and look at the Privacy Policy applicable to the website in question.
Controlling Your Personal Information
We do not share your Personal Information with third parties for use in marketing their products and services. However, we may share your Personal Information in the following circumstances:
- Where we have your permission to do so;
- With authorized representatives (including consultants, attorneys or accountants);
- With financial intermediaries (such as broker-dealers or custodians), but only as permitted by law and only as necessary to provide agreed services and products to you;
- With other unaffiliated service providers which we have business arrangements to help administer our business; and
- With government agencies, other regulatory bodies or law enforcement officials in response to inquiries or as required by law.
Our service providers are obligated by law or contract to keep the Personal Information we share with them confidential and use it only to provide services specified by H&W or the HW Funds.
Important Notice to all Non-US Residents
Our servers are located in the U.S. If you are located outside of the U.S., please be aware that any information provided to us, including Personal Information, will be transferred from your country of origin. Your decision to provide such data to us, or allow us to collect such data through our services constitutes your consent to this data transfer.
Retention Period
We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Online Privacy Policy unless a longer retention period is required or permitted by law.
Updates to This Privacy Policy
We may change this Online Privacy Policy. The “Effective Date” at the top of this page indicates when this Online Privacy Policy was last revised. Any changes will become effective when we post the revised Online Privacy Policy on the Website. Your use of the Website following these changes means that you accept the revised Online Privacy Policy.
Contact Us
If you have any questions about this Online Privacy Policy, please contact us via email at: [email protected].
