How Does Neuberger Berman Treat Your Personal Information?

Our commitment to privacy

Neuberger Berman is committed to preserving your privacy and strictly adheres to applicable law, which requires us to tell you how we collect, use, disclose, process and protect your personal information. Where there is inconsistency between this statement and applicable law, we will apply the standard that affords a stronger level of protection. Please read this statement carefully to understand what we do.

Who is providing this statement

This notice is provided by Neuberger Berman Asia Limited

Types of personal information we collect

The types of personal information we collect, use and disclose will depend on our relationship with you and may include:

  • your name, address, occupation, email address, telephone/facsimile number(s), identification document number
  • marital status, date of birth, number of dependents
  • your financial status, income, assets and transaction history
  • your education and/or employment history
  • your credit history and credit scores
  • government related identifiers that identify you (in Australia, this may include ABN, Medicare card number, pension card number, driver’s licence number and tax file number)
  • other information relating to your relationship with Neuberger Berman

When our relationship with you ceases, we may continue to retain, use and disclose your information as described in this statement provided there is a business or legal purpose to do so.

Why we collect your personal information

Generally, we collect, use, disclose, process and update personal information for our everyday business purposes, which may include:

  • providing you with Neuberger Berman product(s) or services
  • your employment with Neuberger Berman
  • complying with our obligations under applicable law relating to the Neuberger Berman product(s) or service or your employment with Neuberger Berman (as the case may be)
  • meet our ongoing obligations to you in providing you with the Neuberger Berman product(s) or service or as your employer (as the case may be)
  • processing your transactions
  • maintaining your account(s) or administering any facility you have with us
  • protecting against fraud
  • meeting our obligations under applicable law, such as customer identification requirements relating to “know your client” (“KYC”) due diligence, search and registration purposes, data collection and retention, taxation anti-money laundering (“AML”), and/or combating terrorist financing (in Australia these laws include the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), the Personal Property Securities Act 2009 (Cth), the Taxation Administration Act 1953 (Cth), the Income Tax Assessment Act 1997 (Cth) and other taxation laws (for example, to comply with obligations relating to employment or with information requests issued by the Commissioner of Taxation))
  • responding to government agency's requests, court orders and legal investigations
  • receiving reports from, or reporting to, credit bureaus
  • to share your personal information with related bodies corporate

How we collect your personal information

We may collect your personal information when, for example, you

  • open an account or provide account information
  • become an employee of Neuberger Berman (for example through your curriculum vitae or from references given to us in connection with your employment)
  • transact with us or others (including information regarding your income and transaction history)
  • seek advice about your investments or give us your income information
  • give us your contact information
  • use our website

We may also collect your personal information from other sources, such as credit bureaus, affiliates or other third parties who provide us with specific information to assist us in delivering our products and services to you.

How we protect your personal information

Your personal information may be stored in hard copy documents or electronically in our software or systems. When no longer required, we take reasonable steps to destroy or de-identify your personal information.

To protect your personal information from unauthorized access, disclosure, use and other similar risk, we take security measures that comply with applicable law. These measures include technological, administrative and organizational measures including computer safeguards and secured files and buildings.

We restrict access to your personal information to those personnel at Neuberger Berman, and our service providers, who have a bona fide need for this information in order to perform their job responsibilities.

You can sometimes access other organisations’ websites through links on our websites. Please note that we are not responsible for the privacy standards and processes of those organisations and external websites.

What happens if you don’t allow us to collect your personal information

If you do not provide us with any requested personal information this may mean that we are unable to provide you with a product or service.

For example, if you choose to restrict our website from placing a “cookie”* on your hard drive, you may not be able to use some of the features on our website that depend on cookies .

* Cookies are tiny packets of information that websites store on your computer’s hard drive so that your computer will “remember” information about your visit. Our website makes use of these cookies to enhance your experience when you visit.

Who your personal information may be disclosed to and their locations

We may disclose your personal information to affiliates in order to meet our obligations to you and for other purposes as described above. We may also disclose your personal information for such purposes to other organizations, such as:

  • external service providers involved in our provision of products and services to you, such as mailing houses, professional advisers (such as our lawyers and compliance advisers), identity verification services, call services, researches, data analysts, auditors
  • your agents, advisers or lawyers, in such circumstances where you have obtained a product or service from us through them or are otherwise dealing with us in any way through them
  • parties involved in markets and systems related to the products and services we provide to you, such as market operators and participants, counterparties, intermediaries and custodians
  • entities assisting us to maintain and improve our systems, products and services
  • entities to whom we are required or authorised by applicable law to disclose your personal information, such as government and regulatory bodies
  • members of the Neuberger Berman group and related entities
  • other financial institutions, government bodies and credit providers
  • your nominated referees
  • organisations through whom you choose to make payments to the Neuberger Berman group
  • organisations wishing to acquire an interest in any part of Neuberger Berman’s business for assessing or implementing any such acquisition

Because our operations involve activities both within and outside the jurisdiction in which you have a relationship with Neuberger Berman, some of these disclosures may be to entities that are overseas. It is not practicable to list every country in which such recipients are located but it is likely that the countries to which your information may be disclosed include the United States of America, the United Kingdom, Ireland, China, Australia, Hong Kong, Taiwan and Singapore.

How long will your personal information be retained

We will retain your personal information for as long as is necessary to satisfy the purpose for which it was collected or as required by relevant laws, whichever is the longer. We will cease to retain your personal information if there is no longer any business or legal purpose to do so.

How we use your personal information

We may collect, process and use your personal information manually or through automated means (such as through computers), provided always that we will collect, process and use your personal information by means which are lawful and fair in the circumstances.

Access to personal information and other rights

You have the right to request access to your personal information which we hold. Your access rights are subject to some exceptions allowed by applicable law. We will respond to your request in accordance with applicable law. If we deny your access request we will provide you with reasons for doing so. Please note that we may charge a fee for complying with your request.

We aim to keep your personal information held by us up-to-date. If you believe that the personal information we hold about you is incorrect, please let us know so we can correct this.

To access or update your personal information, please contact our Data Protection Officer (details for whom are set out below).

How we will deal with a compliant?

If you believe your personal information has not been treated consistently with our legal obligations or that we have failed to comply with our legal obligations, please contact our Data Protection Officer (details for whom are set out below). You will receive an acknowledgement of receipt of your complaint from us as soon as reasonably practicable after we receive it.

We investigate all complaints and will respond to you as soon as reasonably practicable. We aim to resolve your complaint within a reasonable time after we receive your notice.

Contacts

To access or update your personal information, please write to us at:

Neuberger Berman Data Protection Officer
20th Floor, Jardine House
1 Connaught Place, Central, Hong Kong

or call:

Hong Kong
+852.3664.8800
Australia
+61.3.9649.0900
Singapore
+65.6645.3760
Shanghai
+86.21.6062.6282

If you have any complaints regarding our handling of your personal data, please let us know at:

Neuberger Berman Complaints Officer

20th Floor, Jardine House
1 Connaught Place, Central, Hong Kong