CCPA Privacy Notice | Lord Abbett
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CCPA Privacy Notice

This Lord Abbett Notice at Collection and Privacy Notice (“California Privacy Notice”) supplements the information contained in our Online Privacy Notice. It is delivered on behalf of Lord, Abbett & Co. LLC (“Lord Abbett” or “we” or “us” or “our”) and governs certain personal information we collect from California residents (“you”) via lordabbett.com (“Website”).

 

We have adopted this California Privacy Notice to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”).  Please take the time to read and understand this California Privacy Notice.

Scope

 

Most of the personal information we collect about California residents is not covered by this California Privacy Notice at this time. The CCPA includes certain exemptions that may apply to our collection and processing of your personal information. Therefore, it is possible that not all personal information we collect from or about you is fully covered by the CCPA. Therefore, this California Privacy Notice and the CCPA privacy rights set out herein may not apply to you or to all of your personal information.  For example, the following personal information is not covered by this California Privacy Notice:

  • Personal information that is collected, processed, sold or disclosed pursuant to the federal Gramm Leach Bliley Act (“GLBA”) and implementing regulations is not covered by this California Privacy Notice. To understand how we collect, use and share your nonpublic personal information in accordance with the GLBA, please read our Regulation S-P Privacy Notice.
  • Personal information that we collect about you in a business-to-business context, including when you are communicating with us as an employee of a business to whom we are providing or receiving a product or service is not covered by this California Privacy Notice.
  • Personal information we have from individuals in their capacity as California-resident current or former Lord Abbett employees or California-resident Lord Abbett job applicants is not covered by this CCPA Notice. Please see below for how to obtain information regarding the personal information we collect about California-resident employees and job applicants.
  • California-Resident Lord Abbett Employees: Please contact DataPrivacy@lordabbett.com to receive a copy of Lord Abbett’s California Staff Privacy Notice.
  • California-Resident Lord Abbett Job Applicants. Please visit our CCPA Job Applicant Privacy Notice.

In addition, publicly available information, de-identified data and aggregate California resident information (as those terms are used in the CCPA) are not personal information for purposes of the CCPA. This California Privacy Notice does not apply to such information.

Notice at Collection

 

We may collect the following categories of personal information from you:

  • Identifiers
  • Categories of personal information described in Cal. Civ. Code Section 1798.80(e)
  • Geolocation data
  • Internet or other electronic network activity information
  • Inferences drawn from other personal information

 

We may use your personal information for the following purposes:

 

  • To present our Website and its contents to you
  • To deliver the information, products and services you requested from us
  • To reach out to you about and market or promote new information to you
  • To communicate with you
  • To help us improve our Website and deliver a more personalized experience
  • To deliver targeted, interest-based and other advertising to you
  • To carry out our obligations and enforce our rights
  • In any other way we describe when you provide the information, or otherwise at your direction or with your consent
  • As permitted by law or as we may notify you

Our Prior Collection, Use and Sharing of Personal Information

 

The CCPA requires us to give you specific information about the categories of personal information we collect about you, the sources from which we have obtained that information, the purposes for which we collect it and the categories of entities with whom we share it. The table below sets out our relevant practices over the last twelve months. Our collection, use and disclosure of personal information depends on your relationship with us and your interaction with our Website. For more information regarding the personal information we collect from you via our Website, please read our Online Privacy Notice.  

 

Category of Personal Information

Categories of Sources From Which Collected

Business or Commercial Purpose for Collecting the PI

Categories of Third Parties and Other Entities With Whom We Share

  • Identifiers, such as IP address, mobile device id, cookies and or other online identifiers
  • Categories in Cal. Civ. Code 1798.80(e)
  •  
  • Internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with our Website, application or advertisement
  •  
  • Geolocation data, such the state or country associated with your IP address
  •  
  • Inferences drawn from this information, such as preferences or other Website visitor characteristics
  • Directly from you such as when you visit our Website, register for one of our events, or register for an online account
  • From your devices
  • Via cookies and other tracking technologies
  • From our affiliates
  • To present our Website and its contents to you
  • To deliver the information, products and services you requested from us
  • To reach out to you about and market or promote new information to you
  • To communicate with you
  • To help us improve our Website and deliver a more personalized experience
  • To deliver targeted, interest-based and other advertising to you
  • To carry out our obligations and enforce our rights
  • In any other way we describe when you provide the information, or otherwise at your direction or with your consent
  • As permitted by law or as we may notify you
  • Our affiliates
  • Entities that provide marketing services
  • Our business partners, service providers and vendors
  • Legal authorities as required by law or to protect our rights
  • Advertising, analytics and marketing service providers and partners
  • Social media platforms
  • Affiliated and nonaffiliated third party as may be permitted by law (such as in connection with the sale or restructuring of all or part of our business)

 

 

 

 

 

How We Share Personal Information

 

In the last twelve months, we have disclosed the following categories of personal information for business purposes:

  • Identifiers
  • Categories of personal information described in Cal. Civ. Code Section 1798.80(e)
  • Geolocation data
  • Internet or other electronic network activity information
  • Inferences drawn from other personal information

Sales of Personal Information for Purposes of the CCPA

The CCPA defines the term “sale” very broadly. We do not currently sell your personal information for purposes of the CCPA. In the past 12 months, we have disclosed the following categories of personal information to third parties that provide services to us, such as website advertising and analytics services. Such prior disclosures may be considered a “sale” for purposes of the CCPA:

  • Identifiers
  • Categories of personal information described in Cal. Civ. Code Section 1798.80(e)
  • Geolocation data
  • Internet or other electronic network activity information
  • Inferences drawn from other personal information 

We do not have actual knowledge that we sell the personal information of minors under the age of 16.

Cookies, Online Tracking and Interest-Based Advertising

As set out above, we and third parties may collect and use your personal information for online tracking and to deliver targeted, interest-based and other advertising to you. Please see our description of Cookies and Other Tracking Technologies section of our Online Privacy Notice for more information.

If at any time you would like to manage your cookie preferences, please visit the Cookie Preference Center, which appears at the bottom of our privacy policy homepage.

If you opt-out of the placement of certain categories of cookies, an “opt-out cookie” will be placed on your device.  Opt-out cookies are device- and browser- specific, meaning that you must opt-out across all of your devices and browsers.  If you clear your cache or delete cookies from your browser, the opt-out cookie will also be deleted, meaning you will need to opt-out again.

Your Rights as a California Resident

 

As a California resident, you have certain rights in relation to your personal information.

Right to Know

You have the right to know how we have collected, used and shared your personal information over the last twelve months. Specifically, you have the right to know:

 

  • The categories 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 for which we collect or sell your personal information.
  • The categories of third parties with whom we share your personal information.
  • The categories of personal information that we disclosed for a business purpose and the categories of third parties to whom your personal information was disclosed for a business purpose.
  • The categories of personal information we have sold to third parties and the categories of third parties to whom we have sold your personal information.

You have the right to know the specific pieces of personal information we have collected about you over the last twelve months.

Right to Make a Deletion Request

 

You have the right to request that we delete your personal information that we have collected or received. Subject to certain exceptions, we must delete your personal information and direct our service providers to delete your personal information.

 

Right to Opt-Out of Sales of your Personal Information

 

You have the right to opt-out of the sale of your personal information.

Right to Non-Discrimination

 

You have the right not to be discriminated against by us for choosing to exercise your rights under the CCPA.

How to Exercise Your California Privacy Rights

If you wish to exercise your rights to know, access or delete your personal information, please call us at (888) 522-2388 or contact us at DataPrivacy@lordabbett.com.  If you maintain an account with us, we may require you to submit a request through that account.

Information for Authorized Agents

You can authorize a person registered with the California Secretary of State (“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, otherwise a request submitted by an Authorized Agent on your behalf may be denied.  To submit a request to Lord Abbett on behalf of another person as an Authorized Agent, please call us at (888) 522-2388 or contact us at DataPrivacy@lordabbett.com.

Verifying Your Requests

We only respond to requests that you make which are “verifiable.” To verify your requests, 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. 

We may need additional information from you to verify your request. In order to verify your request, we may need to obtain additional information about you to match the information we already have about you. If you provide us with new personal information that we did not already have about you, we will use it solely for the purposes of verifying your request. We will let you know via email if we need more information from you to verify your request.  Please reply to our requests promptly.

We will communicate with you about your requests via email. We will use the email address you provided when submitting your request.

If we cannot verify your request, we will let you know.

Responding To Your Requests

For requests exercising your rights to know or delete your personal information, we aim to promptly verify your requests and respond to your requests within 45 days of receipt, but may require up to a total of 90 days to respond to your requests. If we require additional time beyond the initial 45 days and that time is reasonably necessary, we will let you know within the first 45 days.

We do not ordinarily charge a fee for our response to your requests. However, we may do so to the extent your request(s) are excessive, repetitive, or manifestly unfounded. If we determine that charging a fee is warranted, we will let you know and will provide you with an estimate of the associated costs of responding to your request(s).

If we determine that we cannot or will not take the action that you requested, we will let you know. We will inform you of our reasons for not taking action and any rights you may have to appeal the decision.

 

Unless you tell us that you would like to receive a response via postal mail, we will respond to you via email regarding your requests to know and to access the specific pieces of personal information we have about you. We will contact you at the email address you provided when submitting your request(s). If you would like to receive responses to a request to know or access personal information via postal mail rather than email, please let us know when submitting your request(s).

 

Limitations

The CCPA does not apply in full to all personal information we collect from California residents. As set out in “Scope” above, the CCPA is not fully applicable to much of the personal information we collect from California residents.  Therefore, even if you are a California resident and submit a verifiable request, we may not be required to comply with your request.

We are only required to respond to certain requests twice in any twelve-month period. We are not required to provide you access to specific pieces of personal information more than twice in any twelve-month period. Similarly, we are not required to comply with your “requests to know” more than twice in any twelve-month period.

It is not possible for us to verify requests for certain types of personal information that we may collect from you, such as clickstream data. We therefore will generally not include such information in response to consumer requests. 

Do Not Track

We rely on a third-party service provider to implement a tool in an effort to recognize and honor “do not track” signals.

 

Changes to Our California Privacy Notice

From time to time, Lord Abbett may update or revise this California Privacy Notice. If there are changes to the terms of this California Privacy Notice, documents containing the revised policy on the relevant website(s) will be updated.

How to Contact Us

If you have any questions or concerns about this California Privacy Notice, please contact us at DataPrivacy@lordabbett.com.    

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