Privacy & Security
NOTICE: We have updated our Online Privacy Code. By visiting this website or responding to any electronic communications from us after February 16, 2016, you agree to this Online Privacy Code.
Our Online Privacy Code
Effective Date: February 16, 2016
Your privacy is important to us and we value your trust. This Online Privacy Code (this “Code”) describes our online privacy practices.
This Code applies to online services operated by Epoch Investment Partners, Inc. (“Epoch”) and its service providers (together referred to as “we”) including:
- Our website; and
- Our electronic communications (such as email messages) with you.
This Code explains how we (directly or through our service providers):
- Collect, use and share information when you visit or interact with our online services; and
- May associate this information with other information about you.
Consent: By visiting our website or responding to any electronic communications we may send you, you agree to this Code.
Check the Effective Date: This Code may be revised from time to time, so we encourage you to periodically check the current version available. If we revise this Code in a material way, we will change the “Effective” date shown at the top of this page and provide a conspicuous notice on our website before any changes take effect.
Important – Clients: If you have a financial product or service with us, we will use and share your personal information in accordance with our privacy notice, which is available upon request.
What Information do we Collect?
Personal information: We may collect personal information from you through our online services. For example, you may provide us with your name, mailing address, phone number, email address and other information when you fill out a form on our website to subscribe to Epoch Insights or our white papers or contact us.
Other information: When you visit our website or view any of our electronic communications, we may collect information from your computer(s), and your smartphone(s), tablet(s) or other mobile devices (together referred to as “mobile devices”). This information includes:
- The make and model of type of the computer(s) or mobile device(s) you use to visit, use, view or interact with our online services, unique device identifier, browser version, hardware, operating system and MAC address;
- Your mobile phone number, mobile country code and other mobile device-related information such as mobile device International Mobile Station Equipment Identity (IMEI), Integrated Circuit Card Identifier (ICCID), information about the screen size of your mobile device(s) and the date and time of your use;
- Your Internet Protocol (IP) address and related information, such as your internet service provider and general location;
- Your browsing habits on our website, such as what pages you visit, how long you stay and what actions you take;
- Search terms that directed you to our website, which websites you came from, and which websites you visit right after leaving one of our websites;
- Which online content on our website you view, access or click on; and
- Any actions you take in response to electronic communications that we send to you, such as opening the message or clicking an embedded link
Third party information: We may also collect information about you from additional online and offline sources, including our affiliates, credit reporting agencies and other third-party sources.
Association of information:
- We may associate the above information from your computer(s) or mobile device(s) through various means, including a unique identifier (such as IP address or visitor ID) by using cookies (small data files saved to your browser by websites) and other tracking technologies. When used, these unique identifiers enable us to track your activity on our online services, for the purposes described in the following section.
- If you are one of our customers, we may associate the above information with your personal profile (contact information, and information about your holdings, transactions and demographics) and use it for the same purposes.
How do we use your information?
We may use the information discussed above in a number of ways, to:
- Deliver products, services and information you request to you, which includes:
- Contacting you or your designated representative(s) by mail, telephone, email, facsimile, etc., in connection with your relationship and account with us;
- Providing you with information (such as investment research), recommendations, or advice concerning products and services offered by us; and
- Facilitating the operation of our website;
- Market our products and services, including contacting you in response to a message from you via our website or based upon your visits to our website (based upon your IP address collected during previous visits to our website);
- Prevent and detect fraud and enhance the security of your account and our online services;
- Conduct market research, reporting and development, including to better understand our clients and website visitors, improve our website, and improve our products and services; and
- In other ways as required or permitted by law or with your consent.
Aggregated/anonymized information: We may also use information about you that has been aggregated or anonymized (so that it does not identify you individually) for various business purposes as permitted by law.
How do we share your information?
We will not sell your personal information. We do not disclose your personal information to non-affiliated third parties, except as described in this Code.
We may share personal information about you, and information collected from your computer(s) and mobile device(s), including:
- Our service providers for purposes such as servicing accounts or conducting transactions, or providing services to us including legal, regulatory, audit, technology, or other services;
- Our affiliates (i.e., companies related to us by common ownership or control);
- Other individuals or entities, when we believe that disclosure is necessary to detect, prevent or report suspicious activities, prevent physical harm, financial loss, or violations of our agreements and policies;
- Our affiliates or non-affiliated third parties in connection with a corporate transaction, such as a sale of our businesses;
- Regulators and other organizations or individuals who are legally entitled to receive such information; and
- For specific products or services, when you have given your consent.
Aggregated/anonymized information: We may also share aggregated or anonymized information (which does not identify you individually) for various business purposes as permitted by law, including:
- Third parties to help develop, market and deliver products and services that are better tailored to our customers, website visitors and mobile app users; and
- Our advertising partners for online advertising purposes.
To protect your personal information from unauthorized access and use, we use security measures that comply with applicable law. These measures include:
- The use of specialized technology such as firewalls;
- Monitoring of our systems infrastructure to detect weaknesses and potential intrusions;
- Implementing controls to identify, authenticate and authorize access to various systems or sites;
- Protecting information during transmission through various means including, where appropriate and practical, encryption; and
- Providing our personnel with relevant training and updating our security practices in light of new risks and developments in technology.
We do not respond to “do not track” signals transmitted by web browsers or similar mechanisms.
Third-Party Sites and Services
Our online services may contain links to third-party websites and other online services, which are not governed by this Code. We encourage you to learn about the privacy and security practices of those third parties. We are not responsible for the privacy or security of such websites and other online services, nor the online collection, use or sharing of personal or other information by third parties.
Updating Your Information
The accuracy of your account information is important. If you have a financial product or service with us and you find that any personal information we have or have reported to another party does not appear to be accurate, please contact us as follows:
Epoch Investment Partners, Inc.
399 Park Avenue
New York, NY 10022
Please include your account number, if available.
Protecting Children’s Online Privacy
Our online services are not intended for children under 13 years of age. We do not knowingly collect personal information from such children, or send them unsolicited promotions, without parental consent.
Visitors Residing Outside the United States
If you visit, use, view or interact with our online services, information about you or your computer(s) or mobile device(s) may be collected, stored, used and processed in and transferred to, from and within the United States. In such instances, applicable U.S. federal and state laws shall govern. If you are a non-U.S. resident, such laws may not provide the same level of protection as the laws of the country of your residence.
If you have any questions or comments on our Online Privacy Code, please contact us at:
Epoch Compliance Department
399 Park Avenue
New York, NY 10022