Privacy Notice

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.

Information We Collect

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:

  • Name and address
  • E-mail address
  • Phone number
  • Social security number
  • Taxpayer identification number
  • Assets
  • Income
  • Account balance
  • Investment activity
  • Accounts at other institutions 

In addition, we may collect non-public information from the following sources:

  • Information we receive on Subscription Agreements, Mutual Fund account documents, Managed Account Agreements, and other Subscription and Account Opening Documents
  • Information we receive in the course of establishing a customer relationship including, but not limited to, applications, forms, questionnaires, and data through our website
  • Information about your transactions with us, our affiliates, or others
  • Publicly available information
  • Other Personal Information you provide directly to us

How We Safeguard Your Information

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.

How We Share Information We Collect

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.

Information Automatically Collected on our Website

Gurtin uses cookies and similar technology to collect and retain certain technical and navigational information about you and other visitors to Gurtin’s website, such as, for example, device type, browser type, internet protocol address, pages visited, and average time spent on Gurtin’s website (collectively, “Website Data”), unless you expressly opt out of allowing Gurtin to collect such Website Data. This collection is used: to provide a variety of financial services, including investment management and financial advice; to facilitate investment in a variety of investment products; to engage in marketing and advertising in relation to such products and services; to help us improve our website and provide a more personalized experience; and to engage in analytics and better understand your use of our website. Some of these cookies may be placed by third parties, such as Google Analytics. You can refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you delete or reject cookies, some website pages may not function properly. Gurtin does not look for web browser “do not track” requests.

Changes to the Privacy Policy

From time to time, Gurtin may update or revise this privacy policy. If there are changes to the terms of this privacy policy, documents containing the revised policy on the relevant website will be updated.

Last Updated: June 26, 2020

Privacy Notice for C alifornia Residents

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.

Scope

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:

  • Personal information that is collected, processed, sold or disclosed pursuant to the federal Gramm Leach Bliley Act (“GLBA”) and implementing regulations;
    • To understand how we collect, use and share your nonpublic personal information in accordance with the GLBA, please read our 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.

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.

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.

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

  • Identifiers, such as IP address, mobile device id, cookies and other online identifiers
  • Categories in Cal. Civ. Code 1798.80(e)
  • Internet or other electronic network activity information, such as browsing history, search history or other information regarding your interaction with our Website
  • 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
  • Via cookies and other tracking technologies
  • To present our Website and its contents to you
  • To communicate with you
  • To deliver the information, products and services you requested from us
  • To help us improve our Website and deliver a more personalized experience
  • To engage in analytics and better understand your use of our Website
  • To reach out to you about and market or promote new information to you
  • To deliver interest-based 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
  • Advertising networks and analytics providers
  • Legal authorities as required by law or to protect our rights
  • 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)
  • Internet or other electronic network activity information
  • Geolocation data
  • Inferences drawn from other personal information

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:

  • 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

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.

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.

How to Exercise Your California Privacy Rights

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.

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

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 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.

Changes to Our California Privacy Notice

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.

How to Contact Us

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