Brown Brothers Harriman Privacy Policy
Last Updated: June 26, 2015

Brown Brothers Harriman & Co. and all other related affiliates and subsidiaries (collectively “BBH”) value your privacy.  This online privacy policy applies to our privacy practices for handling information relating to your use of the bbh.com website (the “Site”) and our online services on the Site (the “Services”).

Please read this policy carefully.  Your use of the Site and/or the Services, including your input of any personal information into the Site and/or Services is subject to and governed by this policy. 

Information we collect

We collect and store information that you voluntarily provide to us as well as data related to your Site visit and usage. 

For example, in order to access some of the Services, you will be required to input your username and password.  These Services are password protected.  Accordingly, once you submit your username and password, BBH will recognize who you are and collect all information that you submit, including electronic instructions.

BBH may collect information on certain technical information regarding your device, such as the operating systems, unique identifier and model name or your device, as well as its user configuration and settings. 

The information we collect enables us to provide you with access to the Site and Services on your device.  We use that information to offer you an enhanced, personalized online experience.

Other than collection of information as described in this Privacy Policy, we will not collect personal information about you when you use the Site or the Services, unless you choose to directly provide such information to us when contacting us via email or other method.  We will use your personal information to process your request and, when applicable, respond to you.  By contacting us in this manner you consent to the collection and use of your personal information for purposes of responding to your request and in the support of services requested.

Sensitive data

We recognize that certain jurisdictions have enacted laws that require higher protection of certain sensitive personally identifiable 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 require such Sensitive Data from you.

In the limited cases where we do seek to collect such information, we will seek to do so in accordance with applicable data privacy law requirements. If you choose to provide us with unsolicited sensitive personal information, you consent to us using the information, subject to applicable law as described in this Privacy Policy.

How we use and share personal information

In addition to uses described above, we use collected information to make available and to improve our Services.  Your information may be processed for a number of reasons, including, but not limited to:

  • To respond to inquiries or service requests and monitor such responses
  • To provide information about and market our products or Services
  • To manage the Site and assess its usage and 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.

We do not sell any personal information that we collect about you. We do not disclose any personal information about our current or former clients to anyone, except as permitted by contract or law and subject to confidentiality obligations that apply in certain jurisdictions.

We may disclose or share personal information about our customers to affiliates, as permitted by law, in order for our affiliates to provide services.  This may, where permitted by local law, include archiving your personal information in a jurisdiction other than your own, which may not have equivalent data protection laws.

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 in connection with an investigation of suspected or actual illegal activity and/or ( v) if disclosure is necessary to protect the vital interests of a person.

We may disclose or share personal information about our customers to nonaffiliated third parties with whom we have contracted to perform services on our behalf. We require our third-party servicers to agree to comply with appropriate privacy and security standards or to undertake to provide similar and appropriate levels of protection as we do when processing personal information. In addition, we may share personal information and other information collected through the Site and the Services with a successor entity in the event of a merger, acquisition or similar transaction. 

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 in an effort 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.

By providing your information to BBH in the course of your access and use of the Site or the Services, you agree that your personal information, for the purposes explained in this Privacy Policy, may be transferred to and stored in other countries where BBH does business, which may not have the same data protection laws as the country in which you reside.

Your rights 

As a person who provides us with personal information, you may inquire as to the nature of the personal information stored at and/or processed by us. You will be provided reasonable access to your personal information held by us and, where appropriate, with the ability to review and correct inaccuracies. We will cooperate in providing such access. All such requests for access may be made by sending a request in writing to: GlobalPrivacy@bbh.com.

To help protect your privacy and provide security, we take reasonable steps to verify your identity before granting access to information. We shall respond to such reasonable request made by you within such time period as required under applicable law after your identity has been confirmed and you have clarified the specific personal information that you require. If you demonstrate that the purpose for which the personal information is being processed is no longer legal or appropriate, the personal information will be deleted, unless the law or applicable data retention requirements require otherwise.

Children’s Privacy

We recognize the need to provide particular privacy protections with respect to personal information that may be collected from children.  This Site and Services are not aimed at or intended for children. 

Governing law

This Privacy Policy is governed by the laws of the State of New York, U.S.A. without giving effect to any principles of conflict of law.

Effective date and policy changes

Each time you use this Site, the current version of the Privacy Policy will apply. When you use this Site, you should check the date of this Privacy Policy (which appears at the top of the Policy) and review any changes since the last version. This policy is subject to change from time to time. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you. We will not materially change our policies and practices to make them less protective of your privacy without your consent.

How to contact us

If you have questions or comments about this Privacy Policy, or about how your data is processed, please contact GlobalPrivacy@bbh.com