Last Updated: November 2023
Brown Brothers Harriman & Co. and all other related aﬃliates and subsidiaries (collectively “BBH”, “we” or “us”) respect your concerns about privacy.
BBH is the data controller for personal information that we collect through the Sites. We are also the controller for personal information we collect for our key business contacts. For personal information provided in relation to our business products there are times when we are a controller. If you have questions about when we are acting as a controller or our processing of your personal data, please ﬁnd our contact details, including the contact details of our Data Protection Oﬃcers in the How to Contact Us section at the end of this policy.
Please read this policy carefully. Your use of the Sites and/or the Services, including your disclosure of any personal information to the Sites and/or Services is subject to and governed by this policy.
- Personal information we collect about you;
- How we use personal information;
- How we share personal information
- How we transfer and store personal information;
- How long we keep personal information;
- Your rights;
- Children’s privacy;
- Effective date and policy changes; and
- How to contact us.
Personal Information We Collect About You
We collect and store information that you voluntarily provide to us, information related to your Sites visit and usage, as well as information provided to us by or through our clients in connection with our Services. We also collect certain information when you:
- submit inquiries via an online form;
- sign up to Services offered by BBH;
- apply for jobs with BBH via our online portal; browse our Sites; or
- engage with our electronic marketing communications (also referred to below as emails).
Information that you provide us
Personal information that you provide directly to us will be apparent from the context in which you provide it, for example:
- if you ﬁll out a form on our Sites, you will generally provide your name, contact details and any other information required by the form, such as the content of your inquiry;
- if you sign up to receive electronic marketing communications from us, you will generally provide your name, email address and other contact information, and your product or topic preferences;
- if you sign up for any of the online Services we provide, you will generally provide your name and contact information and any other information necessary to access the feature;
- if you apply for a role with BBH via our online application facility, you will generally provide your name, contact details and a copy of your CV or resume, and if you apply using your LinkedIn proﬁle, you will generally provide information about your LinkedIn account.
- If you are a key contact in a business that has a business account with BBH, we generally have your name, email address, phone number, title and other information relevant to your interaction with BBH on behalf of your employer.
- If you are a person that we hold information on in relation to Services provided by us, we generally have the information you have provided in the relevant account opening and/or fund subscription documentation which you completed in order to open and administer your account and or the register of the Fund(s) you own shares of, which could include data to detect and prevent fraud, anti-money laundering and terrorism ﬁnancing as well as to perform negative news and sanctions screening.
Information that we collect automatically
When you interact with our Sites or open our emails, we may obtain certain information by automated means, such as through cookies, web server logs, web beacons (including pixels and tags), scripts, and other technologies. These technologies help us (1) remember your information so you do not have to re-enter it; (2) track and understand how you use and interact with the Sites; (3) tailor the Sites to your preferences; (4) measure the usability of the Sites and the effectiveness of our communications; (5) authenticate your identity, protect against fraud and provide our products and services; and (6) otherwise manage and enhance our services, and help them work properly.
We may use these automated technologies through our Sites to collect information about your device, browsing actions, usage patterns and location. We obtain information about your device and web browser in this manner such as your device IP address, general location information, unique device identifiers, device type and model, device characteristics and settings, browser settings and characteristics, operating system type and version, language and country preferences, usage statistics, referring emails and web addresses, and other device details. We also may obtain information about your interactions with our Sites, such as pages visited, links clicked, features used, referring or exit URLs, dates and times of usage, session information, clickstream and page-scroll data and other information about your interactions with our Sites and emails.
If you are a client of BBH
In addition to collecting information directly from you, we may collect personal information from third-party sources to satisfy our due diligence obligations in connection with your new account opening. This third-party data allows us to verify the information you have provided to us, for example, to comply with our legal obligations under “know your customer” laws. For more information regarding the personal information we collect to perform this verification, please see BBH's New Account Policy.
We recognize that certain jurisdictions have enacted laws that require higher protection of certain sensitive personal information, such as state or national ID numbers, or other information regarding racial or ethnic origin, health or medical records (“Sensitive Data”). As a general rule, we do not seek to collect Sensitive Data from you.
In the limited cases where we do seek to collect such information, we will seek to do so only in accordance with applicable data privacy law requirements.
How We Use Personal Information
We may use the personal information you provide for a number of reasons, including:
- To respond to inquiries or service requests and monitor such responses;
- To provide information about and market our products or Services which we believe may be of interest. This includes tailored product, thought leadership, and event communications.
- To manage and improve the Sites and assess their usage and effectiveness;
- To develop our business and to inform our marketing strategy, in particular, by monitoring the effectiveness of marketing campaigns;
- To assess the usage of the Services we provide;
- To operate our business in accordance with industry standards and applicable law, which may include, in addition to supporting the Services; responding to inquiries and requests, prevent fraud; and monitoring and archiving communications; and
- To administer client accounts, including anti-money laundering, sanctions and anti-fraud checks.
We use the personal information for the purposes described above because we have a legitimate interest in operating and improving our business that is not overridden by your interests, rights and freedoms to protect personal information about you. We will only send you direct marketing materials if you have given consent for us to do so, unless such consent is not required, in which case you will be provided the opportunity to opt-out of receipt of direct marketing materials.
Other uses of your personal information
We also may use the personal information that we collect to protect against and prevent fraud, claims, and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use personal information for these purposes when it is necessary to protect, exercise or defend our legal rights, or when we are required to do so by law that applies to us.
Mobile Phone Information
In connection with certain of our products and services, we may authenticate instructions which purport to come from you by calling back a telephone number which you have previously provided to us. By providing us with a mobile phone number for call back purposes, or by submitting an instruction, you authorize (on behalf of yourself and any Authorized Person) that the appropriate carrier (AT&T, Sprint, T-Mobile, U.S. Cellular, Verizon or any other branded operator) may disclose to us and our third-party service providers the mobile number, network status, customer type, customer’s role, billing type, mobile device identiﬁers (IMSI [International Mobile Subscriber Identity] and IMEI [International Mobile Equipment Identiﬁer]) and other subscriber status and device details, if available, solely to verify the caller’s identity and prevent fraud for the duration of the relationship. Please note that this information is used only as part of the call back procedure to verify your instruction, and this information is not retained by us after completion of the veriﬁcation.
In addition to the uses described above, we may use personal information that you provide to us or that we collect for other purposes. Where this is the case, we will provide an additional privacy notice to you that describes the purposes for which we will use the personal information and our legal basis for doing so.
PB Mobile App Diagnostic Data
The BBH Private Banking mobile app includes Crashlytics functionality from Firebase, a Google company, which can track use of the app and collect and forward diagnostic data about the app and how it is being used if the app crashes. The diagnostic data that the app collects include information about the state of your device at the time of the crash, including what kind of device you are using, the version of its operating system and its location at the time of the crash, and information about what the app was doing when it crashed. A full list of the information collected can be viewed on the Crashlytics Diagnostic Data page. If you permit us to receive diagnostic data, it will only be provided to BBH and to Firebase, and will only be used to help us detect, diagnose and correct problems with the app. Please note that while the diagnostic data would not contain your name, email address or other information which would directly identify you, it might be possible to identify you from the diagnostic data. However, we will not use the diagnostic data for this purpose.
How We Share Personal Information
We do not sell any personal information that we collect about you.
In addition, we may disclose your personal information (i) at the request of a bank or other regulatory agency or in connection with an examination of us by bank or other examiners; (ii) to our internal or external auditors or attorneys; (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or ﬁnancial loss; (iv) if we are required or permitted to do so by law or legal process, for example due to a court order or a request from a law enforcement agency; (v) if disclosure is necessary to protect the vital interests of a person; or (vi) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).
How We Transfer and Store Personal Information
BBH is a global organization; personal information we collect may be transferred internationally throughout the world to countries where we do business, which may not have the same data protection laws as the country in which you reside. We have internal policies and procedures in place to achieve an equivalent level of protection in place across our organization. The transfer of personal information to other countries is based on a business need or to comply with applicable laws. Personal information stored or processed in a foreign jurisdiction may be accessed under a lawful order made in that jurisdiction.
If you are resident in the European Economic Area (“EEA”), the United Kingdom or Switzerland, we will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries outside of the EEA, the United Kingdom and Switzerland. In all such cases, we will only transfer your personal information if:
The country to which the personal information will be transferred to has been granted a relevant adequacy decision;
We have put in place relevant and appropriate safeguards in respect of the transfer, for example the EU Model Clauses for transfers of personal data originating in the EEA;
The recipient of the personal information has adopted Binding Corporate Rules in relation to the personal information transferred or, if relevant, is a participant in the EU-US Data Privacy Framework; or
The transfer is otherwise authorized by applicable legal requirements.
You may request a copy of the safeguards that we have put in place in respect of transfers of personal information by contacting us as described in the How to Contact Us section below.
How Long We Keep Personal Information
The time period for which we keep personal information depends on the purpose for which we collect it. In all cases we keep it for as long as is necessary to fulﬁl the purposes for which we collected it. We will then delete or anonymize the personal information, unless we are legally required to retain it or if we need to retain it in order to comply with our legal obligations (for example, for tax and accounting purposes).
Subject to any applicable legal requirements, we typically retain personal information as follows:
- Personal information you provide to us through our Sites: we keep this personal information for as long as necessary to respond to your request, and for a short further period in the event that you send us further requests.
- Personal information you provide when you sign up to receive direct marketing communications: we keep most of this personal information for the duration of our relationship with you until you opt out of receiving future marketing communications or we do not have any contact with you for a long period of time.
- Personal information collected for analytics purposes: we keep this personal information for up to 25 months to carry out the analytics. We anonymize or aggregate personal information used for analytics once it is no longer required.
- Website logs: we keep audit logs for our Sites, which may contain your personal information, for up to 25 months. These logs include access logs (to monitor and maintain the security of our Sites), error logs (to track and record errors), and security logs (to track and record security related events, such as, unauthorized access attempts).
You may inquire as to the nature of the personal information processed by us. You may submit such an inquiry by sending a request in writing to: DPO@bbh.com.
If you are resident in the EEA, the United Kingdom, or Switzerland, you may have the following rights in relation to your personal information that we hold about you:
- To request conﬁrmation of whether we process personal information relating to you and, if so, to request a copy of that personal information;
- To request that we rectify or update your personal information that is inaccurate, incomplete or outdated;
- To request that we erase your personal information in certain circumstances, such as where we collected personal information on the basis of your consent, and you withdraw your consent;
- To request that we restrict the use of your personal information in certain circumstances, such as while we consider another request that you have submitted, for example as a request that we update your personal information;
- Where you have given us consent to process your personal information, to withdraw your consent; and
- To request that we provide a copy of your personal information to you in a structured, commonly used and machine-readable format in certain circumstances.
To help protect your privacy and provide security, we may take reasonable steps to verify your identity before we satisfy your request.
You also have the right to lodge a complaint with the data protection supervisory authority in your country.
Our Sites and Services are not aimed at or intended for children.
Effective Date and Policy Changes
How To Contact Us
By email at: GlobalPrivacy@bbh.com.
In writing at:
Attention: Privacy Officer
50 Post Office Square
Boston, Massachusetts 02110
You may also contact our Data Protection Officers:
By email at: DPO@bbh.com
In writing at:
Attention: Data Protection Officer
Brown Brothers Harriman Luxembourg
80 Route d'Esch, 1470 Luxembourg
Attention: Data Protection Officer
Brown Brothers Harriman
30 Herbert St, Grand Canal Dock, Dublin 2, Ireland
California Consumer Privacy Act Disclosures
Last Updated: October 2023
This Statement uses certain terms that have the meaning given to them in the CCPA and its implementing regulations.
Notice of Collection and Use of Personal Information
Depending on the nature of your relationship with us, we may collect (and may have collected during the 12-month period prior to the effective date of these Disclosures) the following categories of personal information about you:
- Identiﬁers: identiﬁers such as a real name, alias, postal address, unique personal identiﬁer (such as a device identiﬁer; cookies, beacons, pixel tags, mobile ad identiﬁers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identiﬁers), online identiﬁer, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identiﬁers
- Additional Data Subject to Cal. Civ. Code § 1798.80: signature, state identiﬁcation card number, insurance policy number, education, bank account number, credit card number, debit card number, and other ﬁnancial information, medical information
- Protected Classiﬁcations: characteristics of protected classiﬁcations under California or federal law, such as national origin, age, sex, gender, sexual orientation, marital status, medical condition, disability, citizenship status, and military and veteran status
- Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
- Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
- Geolocation Data
- Sensory Information: Audio and video
- Employment Information: professional or employment-related information
- Education Information
- Inferences: inferences drawn from any of the information identiﬁed above to create a proﬁle about you reﬂecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulﬁlling orders and transactions, verifying customer information, processing payments
- Providing advertising and marketing services
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
- Short-term, transient use, such as nonpersonalized advertising shown as part of your current interaction with us
- Helping to ensure security and integrity;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
- Debugging to identify and repair errors
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them.
- Managing career opportunities with Brown Brothers Harriman.
We do not collect or process sensitive personal information for purposes of inferring characteristics about consumers.
To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.
Retention of Personal Information
Sources of Personal Information
Depending on the nature of your relationship with us, during the 12-month period prior to the effective date of these Disclosures, we may have obtained personal information about you from the following categories of sources:
- Directly from you, such as when you enter your personal information on our Site or contact us
- Your devices, such as your online activity when you visit our Site, including how you interact with our Site
- Others who use our Services, such as your employer and colleagues
- Our aﬃliates
- Vendors who provide services on our behalf
- Our joint marketing partners
- Data analytics providers
- Government entities
- Operating systems and platforms Social networks
- Recruiting and talent agencies
- Job references, such as your employers or teachers
- Data brokers
Disclosure of Personal Information
Depending on the nature of your relationship with us, during the 12-month period prior to the effective date of these Disclosures, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:
|Category of Personal Information||Category of Third Party|
|Identifiers||Affiliated companies, vendors who provide us with services to support our business, data analytics providers, government entities, operating systems, platforms, employers, credit reporting agencies, background check service providers|
|Additional Data Subject to Cal. Civ. Code § 1798.80 Law||Government entities|
|Protected Classifications||Government entities|
|Commercial Information||Government entities, employers|
|Online Activity||Data analytics providers, operating systems and platforms, employers|
|Sensory Information||Government entities|
|Employment Information||Government entities|
|Education Information||Government entities|
In addition to the categories of third parties identified above, during the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement, we may have disclosed personal information about you to third parties in connection with corporate transactions, such as mergers, acquisitions or divestitures.
We do not sell any personal information or share personal information for cross-context advertising purposes, nor do we use third-party cookies on our Sites to enable third parties to collect personal information about your online activities over time and across different websites. As such, our Sites are not designed to respond to a browser's Do Not Track signal.
Rights under the CCPA
Under the CCPA, California residents have certain speciﬁc rights with respect to their personal information. The following describes these rights:
Right to Request Information
You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
Right to Request Correction of Personal Information
You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
Right to Request Deletion of Personal Information
You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
Opt-Out of Sale
You have the right to opt out of the sale of your personal information or share personal information for cross-context behavioral advertising purposes. As noted above, we do not sell any personal information or engage in such sharing, including but not limited to personal information of minors under sixteen (16) years of age.
How to Exercise Your Rights
We offer three methods by which you may submit a request for information or for deletion of your personal information:
- You may submit a request using the dedicated request form on our website.
- You may submit a request via email to GlobalPrivacy@bbh.com; or
- You may call us toll-free at 800-672-1818 and ask to speak to the BBH Privacy Officer.
Please note that for us to act on your request, we must verify that you are the individual to whom the request relates. The procedure for verifying your request will vary depending on the nature of your request and your relationship with us but will typically involve requiring you to provide us with two or more pieces of identifying information matching your personal information already in our records. In addition, if you ask us to provide you with speciﬁc pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. We will notify you if we are unable to verify your request as required by the CCPA.
To submit a request as an authorized agent on behalf of an individual, you must provide us with written and signed permission from the individual to submit requests on their behalf, in addition to any other information which would be necessary if the individual were making the request directly.