Parametric Portfolio Associates® LLC (“Parametric”) considers the protection of current, prospective, and former clients’ personal and financial information to be a paramount obligation and is committed to maintaining its confidentiality, integrity, and security. As a matter of policy and practice, Parametric does not disclose client personal information externally, except as required or permitted by law and to certain service providers, as described further below.
For the purposes of this policy, client personal information (“Client PI”) includes, but is not limited to, a client’s name, address, phone number, social security or tax identification number, and bank or custodial account numbers. Client PI generally includes information that is not already publicly available and is provided to Parametric by the client.
Parametric may engage third parties to provide various services on behalf of firm clients, such as unaffiliated transfer agents, custodians, and broker-dealers. Such services may require that Client PI be provided to the service provider. Parametric provides only the information necessary for the providers to perform the services, provided the service providers agree to act only under Parametric instructions and to not use Client PI for any other purpose. Parametric always uses best efforts to ensure that the service providers will keep Client PI secure. As required, Parametric will deliver to each new client a privacy notice summarizing its treatment of Client PI and notify all existing clients when its treatment of Client PI materially changes.
This notice supersedes all previously issued privacy disclosures.
Parametric Privacy Notice
Parametric Portfolio Associates® LLC (Parametric) considers client privacy to be a fundamental aspect of its relationship with clients and is committed to safeguarding all client-related personal information as defined under the privacy rules published under Section 504 of the Gramm-Leach-Bliley Act, as amended. Parametric does not disclose nonpublic personal information concerning its prospective clients, clients, former clients, or investors in certain private funds over which the firm acts as a general partner or manager, to any other party or person except as permitted or required by law or an applicable regulatory authority, or as outlined below.
Parametric may, in limited circumstances, need to collect nonpublic personal information about its clients and investors in certain private funds over which the firm acts as a general partner or manager. This information may include but is not limited to:
- Name, address, telephone number, and tax identification number.
- Government-issued identification such as a driver’s license or passport.
- Assets, income, bank and investment accounts, credit information, custodian, IRS tax status, or other financial or investment-related information.
- Applications, subscriptions, suitability, and similar forms or questionnaires.
- Legal documents such as trust agreements, financials, and ownership records.
Parametric may collect personal information when an individual account is opened or when the information is provided by that client’s advisor. This material may be accumulated from sources such as account applications and related documents; other written, electronic, or verbal correspondence; transactions; a brokerage or financial advisory firm, financial advisor, or consultant; information captured on Parametric’s website; and other sources. Parametric retains the personal information of current and former clients in accordance with applicable regulatory or internal record retention requirements.
Parametric may share client information with its affiliates, subsidiaries, or third-party vendors or service providers as needed to conduct business. From time to time Parametric may engage the services of third-party vendors, consultants, or service providers to assist with the management of client portfolios, administrative tasks, or other tasks such as those performed by unaffiliated transfer agents, custodians, or broker-dealers. In that respect, information will be provided on a need-to-know basis only and the external parties will agree to hold all such information confidential, to act only under Parametric instructions, and to not use client-related personal information for any other purpose. Parametric may also disclose or share information, to the extent permitted by law, with other financial institutions with which Parametric or its clients have a joint business arrangement in managing or servicing the client.
Parametric’s procedures are designed to restrict access to nonpublic personal information to appropriate personnel. Parametric maintains physical, electronic, and procedural safeguards that comply with federal standards to safeguard current and past client-related personal information.
Parametric does not sell nonpublic personal information to any external source and does not distribute this information to unrelated third-party providers unless necessary for business-related purposes in connection with the servicing and management of client assets. Parametric cannot, however, guarantee clients against information theft, which is beyond its reasonable technological abilities and controls.
Parametric seeks to comply with the laws of the jurisdictions in which it operates.
Clients are provided with Parametric’s Privacy Notice at the time their account is incepted. Parametric reserves the right to periodically review and revise its Privacy Notice and will provide updates when materially amended or as required by applicable law. At all times, a client may notify Parametric in writing to restrict all nonpublic personal information from being distributed (except to regulators or by law) to any external parties, including affiliates, consultants, and client-related financial advisors. Clients are forewarned, however, that doing so may severely inhibit Parametric’s ability to properly manage the client’s assets or appropriately conduct business on behalf of the client. Please direct any questions or concerns to Parametric at 800 Fifth Avenue, Suite 2800, Seattle, WA 98104, or +1 206 694 5575.
Revised: March 30, 2020