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This California Privacy Notice (“Notice”) supplements the information contained in the Lord, Abbett & Co. LLC (“Lord Abbett” or “we” or “us” or “our”) U.S. Online Privacy Notice and provides additional information as a notice to residents of California (“you”) in accordance with the California Consumer Privacy Act (the “CCPA”). In the event of a conflict between this Notice and any other Lord Abbett policy, statement, or notice, this Notice will prevail as to California residents and their rights under the CCPA.
Note that nonpublic personal information that we process about customers under the federal Gramm Leach Bliley Act and implementing regulations is covered by our Regulation S-P Privacy Notice.
As used in this Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Unless otherwise noted, the disclosures in this Notice that describe how and why we collect and use your Personal Information also describe how we have collected and used Personal Information in the preceding twelve (12) months.
Personal Information We Collect
We may collect the following Personal Information directly from you; automatically when you use our website, including through the use of cookies, pixels, and other tracking technologies; and from vendors who are acting on our behalf. Our processing may depend on your relationship with us and your interaction with our website.
- Identifiers, including name, postal address, unique personal identifier, online identifier, IP address, email address, other similar identifiers;
- Customer Records Information described in Cal. Civ. Code § 1798.80(e), including, name, signature, address, telephone number, education and employment information;
- Characteristics of Protected Classifications under California or federal law, including age, date of birth, race, and gender;
- Internet or Other Electronic Network Activity Information, including browsing history, search history, and information regarding a user’s interaction with a website, application, advertisement;
- Geolocation Data, including location data inferred from your device IP address; and
- Professional or Employment-Related Information, including your occupation, title, and information necessary to assess your employment candidacy (such as your resume or Curriculum Vitae; prior employment details; professional certifications or licenses; referral names and contact information; and any other information you choose to provide in your application materials or during an interview).
How We Use and Disclose Personal Information
We may use and disclose the Personal Information described above for the following business purposes:
- Delivering products and services that you have requested; processing and managing interactions and transactions for our products and services; and providing you with information, including through our website (Identifiers, Customer Records, Electronic Network Activity Information, Geolocation Data, and Professional or Employment-Related Information);
- Communicating with you and responding to your inquiries (Identifiers, Customer Records, and Professional or Employment-Related Information);
- Marketing, advertising, analytics, and similar services (Identifiers, Customer Records, Electronic Network Activity Information, Geolocation Data, and Professional or Employment-Related Information);
- Managing and maintaining your application records or entering into an employment contract with you (Identifiers, Characteristics of Protected Classifications, and Professional or Employment-Related Information); and
- Detecting security incidents and protecting against malicious, deceptive, or illegal activity; troubleshooting our services and website to identify and repair issues; internal research and development; quality and safety assurance, and improving, upgrading, and enhancing our products and services; as permitted by law to carry out our obligations and enforce our rights; and as separately described to you at the time of collection, as your direction, or with your consent (Identifiers, Customer Records, Characteristics of Protected Classifications, Electronic Network Activity Information, Geolocation Data, and Professional or Employment-Related Information).
We may disclose the Personal Information described above to the following categories of recipients as described below:
- Our business partners, service providers, and vendors that provide services on our behalf, including companies that help us deliver content to you; and vendors that provide web analytics, data processing, advertising, email distribution, and other services;
- Other entities within our group, including our affiliates and subsidiaries, as part of our regular reporting activities, in the context of a business reorganization or group restructuring exercise, or in connection with the operation of group-wide functions and services;
- Our professional advisors, including lawyers, bankers, auditors, and insurers to the extent such information is relevant to the performance of their services;
- Regulators, courts, law enforcement agencies, other government bodies, and other parties when reasonably necessary to comply with the law, our obligations, judicial processes, or other legal processes; as we deem appropriate in response to a request from law enforcement, including in response to activities that are illegal or a violation of our policies; or to protect and defend our rights or property;
- Successors and other parties, in the event of a merger, acquisition, divestiture, change of control, or other transaction concerning our business (or in anticipation of such an event); and
- Other parties to whom you direct us to disclose the information or otherwise consent to the disclosure.
We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.
How Long We Keep Personal Information
We will retain Personal Information for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. In determining retention periods, we consider the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from any unauthorized use or disclosure of Personal Information; the purposes for which we process Personal Information and whether we can achieve those purposes through other means; and applicable legal requirements. Generally, we keep information relevant to our dealings with you for seven (7) years following the last date of activity. We securely destroy Personal Information when no longer needed in accordance with our record keeping policies.
Sales and Sharing of Personal Information
Although we do not sell Personal Information in exchange for money, some of the ways in which we disclose Personal Information for targeted advertising purposes may be considered “sales” or “sharing” under California law. You may opt out of this type of selling and sharing of your Personal Information through our Cookie Settings button. We do not knowingly sell the Personal Information of California residents under the age of 16.
California Resident Privacy Rights
As a California resident, you have certain rights in relation to your Personal Information.
Right to Know
You have the right to know:
- the categories and/or specific pieces of Personal Information we have collected about you;
- the categories of sources from which we have collected your Personal Information;
- the business or commercial purpose(s) for collecting, selling, or sharing your Personal Information;
- the categories of recipients with whom we disclosed your Personal Information;
- the categories of Personal Information that we disclosed for a business purpose in the preceding twelve (12) months, and the categories of recipients to whom we have disclosed each category of Personal Information for a business purpose; and/or
- the categories of Personal Information we have sold or shared to third parties in the preceding twelve (12) months, and the categories of third parties to whom we have sold or shared each particular category of Personal Information.
Right to Make a Deletion Request
You have the right to request that we delete your Personal Information that we have collected or received.
Right to Request Correction
If you believe the Personal Information that we maintain about you is inaccurate, you have the right to request that we correct that information.
Right to Opt-Out of Sales or Shares of your Personal Information
You have the right to opt-out of the sale of your Personal Information and to request that we do not share your Personal Information for cross-context behavioral advertising. To opt-out, please use the Cookie Settings button at the beginning of the Notice.
We rely on a service provider to implement a tool in an effort to recognize and honor “do not track” signals. If you choose to use the Global Privacy Control (GPC) browser signal, you will only be opted out of online sales or sharing of Personal Information and will need to turn it on for each browser you use.
Rights Related to Automated Decision-Making
Because we do not use automated decision-making to evaluate consumers, this right is not applicable.
How to Exercise Your California Privacy Rights
If you wish to exercise your California privacy rights, please call us toll free at (888) 522-2388 or complete and submit a privacy request through our Privacy Webform. If you maintain an account with us, we may ask you to submit your request through that account. We will never discriminate against you for exercising your California privacy rights.
Authorized Agents
You can authorize an agent (“Authorized Agent”) to exercise your California privacy rights on your behalf. You or the Authorized Agent must provide Lord Abbett with signed permission demonstrating that the Authorized Agent has been authorized by you to act on your behalf. To submit a request to Lord Abbett on behalf of another person as an Authorized Agent, please call us toll free at (888) 522-2388 or complete and submit a privacy request through our Privacy Webform.
Verifying Your Requests
California privacy rights requests are subject to a verification process. We will not fulfill a request unless we have been provided sufficient information for us to reasonably verify that the requestor is the consumer about whom we collected the Personal Information. To verify your request, we may require authentication of you or the Authorized Agent acting on your behalf that is reasonable in light of the nature of the Personal Information requested.
If you request that we provide you with specific pieces of information about you, we may apply heightened verification standards. We will let you know via email if we need more information from you to verify your request. Please reply to our requests promptly.
Changes to Our California Privacy Notice
From time to time, Lord Abbett may update or revise this Notice at our discretion. We will indicate changes to this Notice by updating the “Last Updated” date at the beginning of this Notice. We encourage you to periodically review this Notice to be aware of our current privacy practices.
How to Contact Us
If you have questions about this Notice, please contact us at DataPrivacy@lordabbett.com.