This Privacy Notice for visitors from outside the United States (‘Notice’) applies to information about you that Lord, Abbett & Co. LLC and its subsidiaries and affiliates (‘Lord Abbett’, ‘we’, ‘our’, ‘us’) may obtain when you visit www.lordabbett.com and any of its subdomains (the ‘Website’) from outside the United States. This Notice describes how we may collect, use, or share information about you; your choices regarding our use of your information; how we safeguard such information; and how you may contact us regarding our privacy practices.

This Notice supplements other Lord Abbett policies and notices. If there is a conflict between any other Lord Abbett policy or notice and this Notice, this Notice will prevail as to individuals accessing the website from outside the United States, including residents of the European Economic Area (‘EEA’), United Kingdom (‘UK’), Cayman Islands, and Dubai International Financial Centre, United Arab Emirates (UAE). Lord Abbett is the data controller for your personal data collected through the Website. For visitors from the Cayman Islands, the Fund is the data controller. We may process your personal data ourselves or rely on others acting as data processors on our behalf.

U.S. financial services clients, customers, and potential clients may review our Regulation S-P Privacy Notice which governs how we collect, use, and share your nonpublic personal information while delivering financial products or services to you.

California residents may review our California Consumer Privacy Notice.

Residents of other U.S. states may review our U.S. Online Privacy Notice.

If you have any questions about this Notice, you can contact us by emailing DataPrivacy@lordabbett.com.

What personal data do we collect?
When you use our Website, we may collect and process different types of personal data from you, including personal data that you provide directly to us and personal data that we collect automatically while you use our Website.

Direct Personal Data Collection.
The personal data we collect may include your name, residential address, email address, contact details, corporate contact information, signature, nationality, place of birth, date of birth, tax identification, credit history, correspondence records, passport number, bank account details, source of funds details, and details relating to your investment activity.  We may also record electronic communications or phone calls. We collect personal data directly about you when, for example, you:

  • contact us and provide personal data in the course of your correspondence with us, such as your name, contact details, and other information contained in the contents of your communications or our own records of the correspondence;
  • sign up to receive or otherwise request any information related to our funds or services;
  • complete the account registration process and choose to access your investment information via our Website; or
  • complete the certification form or other acknowledgment on our Website. 

Tracking Technologies and Automatic Data Collection.
Certain information, such as IP addresses, device identifiers, browser types, operating systems, and other information about your device or use of our Website may be collected automatically using tracking technologies when you navigate our Website.

Our Website uses cookies, which are small files stored on your device, to collect your data. Cookies allow our Website to recognize you, your device, or your user preferences when you visit our Website. Our Website cookies also collect information about how you use our Website, your previous interactions with our Website, and other technical data that can help us maintain and improve our Website to better serve you. We use cookies to: 

  • maintain an operational Website;
  • understand how users arrive at, use, and navigate our Website;
  • learn about how many users visit our Website;
  • provide users with customized experiences when they visit our Website; and
  • identify when a user has accepted applicable terms and conditions and disclaimers or provided other consents on our Website.

A cookie can be either a ‘first-’ or ‘third-’ party cookie, depending on whether the cookie is placed directly by the Website that the user is visiting (‘first-party cookie’) or whether the cookies are set by a third-party entity through the Website that the user is visiting (‘third-party cookie’). For example, we allow third-party companies to collect certain information when you visit our Website. We may also allow web beacons or other similar tracking technologies. This information can be used, in part, to serve ads for our products or services when you visit this Website or other websites. This Notice does not cover any use of information that third parties may have collected from you for their own purposes, or the methods used by the third parties to collect that information. The length of time that a cookie stays on your device will depend on whether the cookie is a ‘persistent’ or ‘session’ cookie. Persistent cookies remain on a user’s device until the cookie expires or is deleted, and they are activated each time the user visits the Website that placed the persistent cookie. Session cookies are created temporarily once a user opens a browser window and are deleted from your device once the browser is closed. We use both session and persistent cookies on our Website.

Certain cookies we use are necessary for the Website to function. We will set these cookies without requesting your consent. We also use cookies for purposes that are not strictly necessary for our Website to function. These include cookies used for purposes, such as collecting information about how visitors are using the Website, analyzing and evaluating user experience on the Website, or providing you with relevant content or advertisements. You will have the opportunity to accept our use of cookies that are not strictly necessary and may change your mind and update your cookie preferences at any time using our cookie preference center.

How do we process your personal data?
The purposes for which we may collect, store, use, and otherwise process personal data about you and our lawful bases for processing this personal data are set out below. It is important that the personal data we hold about you is accurate and up to date. Please let us know if your personal data changes during your relationship with us, and we will correct it.

Data privacy laws specify certain ‘lawful bases’ which permit our use of your personal data for the purposes we disclose below:

  • The processing is necessary for us to provide you with the products and services you request, respond to your inquiries, or otherwise fulfill our contractual obligations to you.
  • We have a legal obligation to process your personal data, or we reasonably believe that it is necessary to protect our rights or the rights of another or to comply with judicial or regulatory proceedings, a court order, or other legal process.
  • We have a legitimate interest in processing your personal data. In particular, we have a legitimate interest in the following instances:
    -To promote our products and services, grow our business, and provide information about our services and product offerings
    -To limit access to information to appropriate persons and enable investors to access confidential information securely;
    -To analyze and improve the safety and security of our Website, business, products, and services, including by implementing and enhancing security measures and safeguards and protecting against fraud, spam, and other abuse;
    -To otherwise maintain and improve our Website, products, and services; and
    -To operate our Website and provide you with information and communications about our products and services that are tailored to, and in accordance with, your preferences. 
  • You have consented to our processing of your personal data. When you have consented to our processing of your personal data, you have the right to withdraw your consent for that processing at any time.  To withdraw your consent, please complete a global data access request on our Website. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless we have an alternative legal basis for doing so.

You will not be subject to decisions based solely on automated decision-making that will have a significant impact on you unless we have notified you and have a lawful basis for doing so.

What if you do not provide the personal data requested?
Unless and until you make a decision to engage in a business transaction with us, you are not required to provide us with any information. However, we may not be able to grant you access to certain parts of our Website if you do not provide some types of personal data.

How do we share your personal data?
We may share your personal data with:

  • other entities within our group 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;
  • fund administrators to manage and provide services related to our funds;
  • our professional advisers, including lawyers, bankers, auditors, and insurers to the extent such information is relevant to their performance of their services;
  • other parties in the context of the possible sale or restructuring of our business;
  • regulators, courts, tax authorities, and other government bodies when reasonably necessary to comply with the law, our obligations, or judicial process; and
  • our vendors where such information is relevant to the performance of their services.

Does Lord Abbett transfer personal data across international borders?
Certain of our subsidiaries, affiliates, advisers, and vendors may be located outside your country of residence, including in the United States. When we transfer personal data across international borders, we transfer the personal data to parties that provide appropriate safeguards for your personal data in accordance with applicable law, including through the use of valid personal data transfer mechanisms, such as the European Union’s Standard Contractual Clauses. If you would like further information about how we transfer your personal data, you can email dataprivacy@lordabbett.com.

For individuals residing in United Arab Emirates
As outlined above, we may need to transfer your Personal Data from the DIFC to a third party outside of the DIFC and in a jurisdiction that is not subject to an adequacy decision of the DIFC Commissioner of Data Protection (“the Commissioner”) or the DIFC supervisory authority for data protection issues. There will be a legal basis and a relevant safeguard method for such data transfer to ensure that your Personal Data is treated in a manner that is consistent with, and respects the applicable laws and regulations on data protection.

A Data Subject who contends that there has been a contravention of the applicable law or an alleged breach of his rights under the applicable law may lodge a complaint with the Commissioner via email at commissioner@dp.difc.ae.

For individuals residing in the Cayman Islands
Any transfer of your data by us or our duly authorized affiliates and/or delegates outside of the Cayman Islands shall be in accordance with the requirements of the Cayman Islands Data Protection Act (as revised).  We and our duly authorized affiliates and/or delegates shall apply appropriate technical and organizational information security measures designed to protect against unauthorized or unlawful processing of your data, and against accidental loss or destruction of, or damage to, your data.  We shall notify you of any data breach that is reasonably likely to result in a risk to the interests, fundamental rights, or freedoms of either you or those data subjects to whom the relevant data relates.

How long will we retain your personal data?
We will retain your personal data 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 any personal data retention period, we consider the amount, nature, and sensitivity of the personal data; the potential risk of harm from any unauthorized use or disclosure of your personal data; the purposes for which we process your personal data 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 data when no longer needed in accordance with our record keeping policies.

What rights do you have with respect to your personal data?
Based on your country of residence or other locality, you may have the right to:

  • request access to your personal data (commonly known as a data subject access request) and request certain information about our personal data processing;
  • request correction of your personal data; 
  • request that we restrict our processing of your personal data;
  • request the deletion of your personal data;
  • object to our processing of your personal data, including for direct marketing purposes; and
  • request the transfer of your personal data to another party.

If you want to exercise one or more of these rights, please contact us using the information provided in the ‘Contact Us’ section below. Before we are able to respond to your request, we may ask that you verify your identity. We may also ask you for more details to help us respond to your request. Please note that applicable law may require or permit us to decline your request. If we decline your request, in whole or in part, we will tell you why, subject to any legal restrictions on providing this information. If you believe that we have violated any of your data protection rights, you may contact us or make a complaint at any time to your data protection authority.

Security
We have put in place reasonable physical, electronic, and procedural controls to safeguard the information we collect from and about you. However, transmission via the Internet and online digital storage are not completely secure, and we cannot guarantee the security of your information collected through the Website

Changes to the Notice
Our practices with respect to personal data may change from time to time. We reserve the right to update this Notice at any time, and we will make an updated copy of such Notice available on our Website. You can see when this Notice was last updated by checking the date at the top of this Notice.

Contact Us
This Notice was written with brevity and clarity in mind and is not an exhaustive account of all aspects of our collection and use of personal data. If you require any further information, please contact us at dataprivacy@lordabbett.com OR

Lord Abbett (UK) Limited
Attn: General Counsel, Legal Department
70 St Mary Ave, Suite 407
London, EC3A 8BE
United Kingdom

OR

Lord, Abbett & Co. LLC
Attn: General Counsel, Legal Department
90 Hudson Street
Jersey City, NJ 07302
United States

If you would like to exercise any of your personal data protection rights, please complete and submit our webform located here.