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Privacy Policy (US)

Important information about your privacy
GAM ® CUSTOMER PRIVACY NOTICE

This notice describes the privacy policy of GAM regarding how GAM handles and protects personal information that it collects about individuals or entities who are prospective, current or former investment advisory clients or shareholders of GAM funds.

Facts
What does GAM USA Inc. do with your personal information?
Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What? The types of personal information we collect and share depend on the product or service you have with us. This information can include:
  • your Social Security number or tax ID number, name, address, e-mail address, date of birth, occupation, citizenship, employment information, assets, income, tax information, bank account information, account balances, transaction history, account transactions, financial information including net worth information and information regarding your transactions with us or our affiliates (“Personal Information”).

When you are no longer our customer, we continue to share your information as described in this notice.

How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons GAM USA Inc. chooses to share; and whether you can limit this sharing.

 

Reasons we can share your personal information
Does GAM USA Inc. share?
Can you limit this sharing?

For our everyday business purposes such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes. GAM may share Personal Information described above for business purposes with a non-affiliated third party if the entity is under contract to perform transaction processing or servicing on behalf of GAM and otherwise as permitted by law. Any such contract entered by GAM will include provisions designed to ensure that the third party will uphold and maintain privacy standards when handling Personal Information. GAM may also disclose Personal Information to regulatory authorities as required by applicable law. No

For our marketing purposes to offer our products and services to you

Yes. GAM may share Personal Information described above for marketing purposes. No
For joint marketing with other financial companies No We don’t share
For our affiliates’ everyday business purposes—information about your transactions and experiences Yes. GAM may share Personal Information described above with its affiliates, including the parent company of GAM, for business purposes, such as to facilitate the servicing of accounts and to provide information about new products and services. No
For our affiliates’ everyday business purposes—information about your creditworthiness Yes. GAM may share Personal Information described above with its affiliates, including the parent company of GAM, for business purposes, such as to facilitate the servicing of accounts and to provide information about new products and services. No
For non-affiliates to market to you No We don’t share


Questions?
Call us at 1.212.407.4600 or go to www.gam.com
Who we are
Who is providing this notice GAM USA Inc. (“GAM”)
What we do
How does GAM USA Inc. protect my personal information?

To protect your Personal Information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

GAM limits access to Personal Information to those individuals who need to know that information in order to process transactions and service accounts. These individuals are required to maintain and protect the confidentiality of Personal Information. GAM maintains physical, electronic and procedural safeguards to protect Personal Information.

How does GAM USA Inc. collect my personal information? We collect your personal information, for example, when you:
  • open an account
  • invest in a GAM Fund

GAM collects Personal Information about you for business purposes, such as evaluating your financial needs and background, processing your requests and transactions, providing customer service and communicating information about our products and services. Personal Information you provide is obtained from application forms, subscription documents, and other transaction related forms, as well as from information you provide on GAM.com or to GAM service representatives.

Why can’t I limit all sharing? Federal law gives you the right to limit only
  • sharing for affiliates’ everyday business purposes—information about your creditworthiness
  • affiliates from using your information to market to you
  • sharing for non-affiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.



Definitions
Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

  • GAM Holding AG, a Swiss corporation, is the ultimate parent company of GAM USA. GAM USA may share Personal Information with its affiliates across the globe, including but not limited to GAM International Management Limited, GAM Fund Management Limited, GAM London Limited and GAM Systematic.
Non-affiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

  • GAM may share Personal Information described above for business purposes with a non-affiliated third party performing transaction processing or servicing on behalf of GAM and otherwise as permitted by law.
 
Joint marketing

A formal agreement between non-affiliated financial companies that together market financial products or services to you.

  • GAM USA Inc. does not jointly market.
 


Other important information





Last modified: December 4, 2018.

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