This notice informs you of the privacy practices of Gurtin Fixed Income Management, LLC dba Gurtin Municipal Bond Management (“Gurtin”) and applies to all non-public personal information of current, prospective, and former clients (collectively, “Clients,” “You,” and “Your”). Our relationship with our clients is Gurtin’s most important asset. We understand that our clients have entrusted us with their private information, and we are committed to maintaining the confidentiality, integrity, and security of that information.
Gurtin will obtain access to non-public personal information through each client’s account application, investment management agreement, and correspondence with Gurtin representatives, through our website and through transactions with Gurtin. This information may include:
In addition, we may collect non-public information from the following sources:
We take our responsibility to protect the privacy and confidentiality of your information very seriously. We maintain physical, electronic, and procedural safeguards to store and secure information about you from unauthorized access, alteration, and destruction, including by restricting access to non-public personal information to those employees responsible for the management and servicing of the Account or to whom access is necessary for another proper business purpose.
We may disclose the information that we collect, as described above, in the following circumstances and as otherwise required or permitted by law: Gurtin may disclose non-public personal information to affiliates and to non-affiliated third parties, such as brokers and custodians, as necessary, to facilitate the acceptance and management of our relationship. We may also disclose non-public personal information to companies Gurtin hires to help administer its business and to affiliates and other financial institutions with whom we have joint marketing arrangements. In addition, non-public personal information may be released to the appropriate client or to such client’s authorized agent or representative, if compelled to do so by law, or in connection with any government or self-regulatory organizational request or investigation, or as otherwise permitted by law.
Last Updated: June 26, 2020
Last revised: June 26, 2020
This Gurtin Privacy Notice for California Residents (“California Privacy Notice”) supplements the information contained in our Privacy Notice and is delivered on behalf of Gurtin Fixed Income Management LLC dba Gurtin Municipal Bond Management, (“Gurtin”) and our affiliates and governs certain personal information we collect from California residents (“you”) via www.gurtin.com.
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.
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. Accordingly, 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:
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.
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.
Category of Personal Information
Categories of Sources From Which Collected
Business or Commercial Purpose for Collecting the Personal Information
Categories of Third and Other Entities Whom We Share
In the last twelve months, we have disclosed the following categories of personal information for business purposes:
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 online advertising and analytics services. Such prior disclosures may be considered a “sale” for purposes of the CCPA:
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:
In addition, 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.
If you wish or your authorized agents wishes to exercise your rights to know, access or delete your personal information, please submit a request by calling us at 866-746-2615 or contact us at AmericasPrivacy@pimco.com. If you maintain an account with us, we may require you to submit a request through that account.
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.
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).
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 or 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.
We may update or revise this California Privacy Notice from time to time. If there are changes, the documents containing the revised policy on the relevant website(s) will be updated.
If you have any questions or concerns about this California Privacy Notice, please contact us at AmericasPrivacy@pimco.com.