Privacy policy

Your privacy is important to us. This Privacy Policy describes the types of information Legal & General Investment Management America, Inc. (“LGIM America”) collects from you when you visit www.lgima.com or any other of our websites where this policy is posted (each a “Site”) or otherwise interact with us online.

This Privacy Policy also explains how LGIM America may use and disclose your information, as well as your ability to control certain uses of your personal information. This Privacy Policy is in addition to any separate Privacy Notice that LGIM America may send you under applicable privacy law.

Information collection

Information collected about clients and visitors to our website

We collect information from you when you choose to share it with us. This may include when you visit our Sites, request information from us, or contact us.

The information we collect from you may include:

  • Contact information, including your name, address, email address, telephone, or mobile number;
  • Employer-related information, such as your title and the company’s name, address, and phone number;
  • LGIM America account number;
  • Location Information (IP address, IP address locations, information about your location);
  • Owned Website Activity (how you use our sites, pages viewed, time of service, date of service, duration of service, time since last visit, links clicked, information about pages viewed on sites);
  • Off-Website Activity (referring website addresses, information about the site you came from); and
  • Information About Your Device (device type, computer type, internet connection type, linking multiple devices to the same user) and Browser (type, language, version, font settings).

Information collected about prospective employees and job applicants

We may collect the following information about you that you either provide to us directly, that we receive from third parties, or that we collect automatically as you access any of our LGIM America sites:

Prospective employees:

  • Career-related information (job title, job role, profession, education, industry, years of experience, skills);
  • Location information (IP address, IP address locations, information about your location);
  • Owned website activity (how you use our site, pages viewed, time of service, date of service, duration of service, time since last visit, links clicked, information about pages viewed on sites);
  • Off-website activity (referring website addresses, information about the site you came from);
  • Information about your device (device type, computer type, internet connection type, linking multiple devices to the same user) and browser (type, language, version, font settings); and
  • Advertising information (interests, activities, social network activities and data, purchases, media, advertising network categories, technology usage, ads received and clicked).

Job applicants:

  • Information about your identity (e.g., name, personal email address, cell phone number, mailing address, password, username);
  • Career demographics (job title, job role, profession, education, industry, years of experience, skills);
  • Location information (IP address, IP address locations, information about your location);
  • Career interests (career topics, current student, expected date of graduation for current students, majors, locations interested in working, profession category (e.g., financial, tech), work area of interest (e.g., trading, legal), interests in upcoming events);
  • Information you provided in-person (e.g., events attended);
  • Topics you have expressed interest in;
  • Owned website activity (how you use our site, pages viewed, time of service, date of service, duration of service, time since last visit, links clicked, searches conducted, registration for event, clicks on event registration links, language choice, comments, ratings, preferences and settings, information about pages viewed on sites);
  • Email activity (emails opened, email program used, IP address of email open, clicks in email);
  • Off-website activity (referring website addresses, information about the site you came from, profile information from social media sites);
  • Information about your device (device type, computer type, internet connection type, linking multiple devices to the same user) and browser (type, language, version, font settings);
  • Information you submit to us (e.g., submitted images, photos, videos; other items you submit; details about your requests made to us);
  • Advertising information (interests, activities, social network activities and information purchases, media, advertising network categories, technology usage, ads clicked); and
  • Job applied for or interested in (including the job opening’s education and experience description).

Information collected from third parties or other sources

We may obtain personal or other information about you from third parties or other sources, and combine this information with the information we collect from you. This might include any other information obtained through companies that have business relationships with us, such as our licensees, affiliates, and business partners.

We may also obtain information about you from other online sources, including when you connect with LGIM America through its official corporate pages on third party social networks (such as LinkedIn) or the “apps” on those pages. This information may include your name, user name, demographic information, updated address or contact information, interests, and publicly-observed data. We may combine this information with the information we collect from you through the Sites.

Information automatically collected

We may use cookies, web beacons, pixel tags, JavaScript, or other technologies to collect certain information about visitors to our Site and interactions with our emails and online or mobile advertisements, and to allow LGIM America to keep track of analytics and certain statistical information which enables us to improve our Site and provide you with more relevant content and advertising on our Site.

Per Legal & General policy, cookies collected on the website do not directly identify individual visitors. Session cookies are temporarily stored until the browser is closed at which point they are deleted.

We may also use third party cookies and other technologies to support our Sites, provide services on our behalf, complete business transactions, or provide relevant advertising to you. Some of these third parties may use technology such as cookies, web beacons, pixel tags, log files, or Flash cookies on our Site or Apps, which may send them some of the above-referenced information. The use of this information by those third parties will be governed by their own privacy policies.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). We may use this information collected about you in order to recruit potential job candidates and communicate with employees and employee alumni. For example, we may use the information we have collected from you to enable us to in order to recruit potential job candidates (e.g., display advertisements about relevant positions to our target audiences). Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, we may assume that you meet the target criteria.

Deletion of cookies, tracking options and California do not track disclosures

You are free to set your browser or operating system settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Site. Please refer to your Web browser’s or operating system’s website or “Help” section for more information on how to delete and/or disable your browser or operating system from receiving cookies or controlling your tracking preferences.

Our system responds to most Do Not Track requests or headers from some or all browsers. To learn more about the use of cookies or other technologies to deliver more relevant advertising and to know your choices about not having this information used by certain service providers, please click on the “Cookie Settings” weblink found on the www.LGIMA.com website.

On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising.

Information use

LGIM America may use the information we collect from and about you for any of the following purposes:

  • To deliver’s LGIM America’s services you;
  • For recruiting, position advertising, talent management and employment purposes (recording, examination, assessment, selection, conclusion of an employment offer, and with your consent the storage in our recruitment database for a possible future offer of employment, etc.);
  • To enhance your online experience, including as a way to recognize you and welcome you to the Site or App;
  • To develop new products or services and to conduct analysis to enhance current products and services;
  • To review the usage and operations of our Site, and improve our content, products, and services;
  • To recognize your online activities over time and across different websites and devices;
  • To provide you with customized Site content, or with your consent where applicable via email, telephone, text message, by mail and other marketing channels;
  • As applicable and with your consent where applicable, to contact you with information, newsletters and promotional materials from LGIM America or on behalf of our business partners, licensees, and affiliates;
  • To contact you when necessary, including for employment purposes, by email, telephone text message, or by mail;
  • To use your data in an aggregated non-specific format for analytical purposes;
  • To address problems with the Services, or our business;
  • To protect the security or integrity of the Site, and our business, such as by protecting against and preventing fraud, unauthorized transactions, claims and other liabilities, and managing risk exposure, including by identifying potential hackers and other unauthorized users; and
  • As otherwise described to you at the point of data collection.

Additionally, if you use the Site to connect with third party services you authorize us to use information from you, on your behalf, to interact with these third party services based on your requests.

Information sharing

LGIM America may disclose the personal information we collect from you with the following categories of third parties and in the following ways:

  • With our affiliated companies;
  • With our third party service providers that provide business, professional or technical support functions for us;
  • As necessary if we believe that there has been a violation of our Terms of Use or of our rights or the rights of any third party;
  • To respond to judicial process or provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law; and
  • As otherwise described to you at the point of collection.

LGIM America may also share aggregate or anonymous non-personal information with third parties for marketing or analytics uses on behalf of LGIM America.

We may share your personally identifiable information (“PII”) in connection with a merger, financing, acquisition, dissolution transaction, bankruptcy or proceeding involving sale, transfer, divestiture of all or a portion of our business or assets. If another entity acquires our business or assets, that entity will have your PII collected by us and will assume the rights and obligations regarding your information as allowed by this privacy policy.

Links to other websites

The Site, and email messages from us, may contain links to third-party websites, which may have privacy policies that differ from our own. You should be aware that the collection, retention and use of any data you provide on these websites will be governed by the privacy policy of the company providing the website and not by this Privacy Policy. We are not responsible for the practices of such websites.

Children’s privacy

Protecting children’s privacy is important to us. We do not direct the Site to, nor do we knowingly collect any personal information from, children under the age of thirteen. If we learn that a child under the age of thirteen has provided personally identifiable information to the Site, we will use reasonable efforts to remove such information from its files.

Data security

We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about our customers and Site visitors. While we make every effort to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures.

Data storage

LGIM America is part of a global company. Therefore, your personal information may be stored on servers in the United States, United Kingdom, or the European Union depending on the interactions of applications used by LGIM America. It is subject to the laws of the United States, where the data protection and other laws may differ from those of other countries. Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the countries in which we operate.

Your options and access to you personal information

To access, review, or update your information stored by LGIM America, you may contact your respective LGIM America office or account representative to have them update your information in our system. If you have any additional questions concerning access to or updating your personal information, please contact us at the information provided in the “Contact Us” section below.

Contact us

We hope this Privacy Policy answers your questions about our collection, use and disclosure of your personal data. If you have additional questions about this Privacy Policy or the practices described herein, you may write to us at communications@lgima.com or the following address:

Legal & General Investment Management America, Inc.
71 S. Wacker Drive, Suite 800
Chicago, IL 60606
Attn: Legal Department

Revisions to this privacy policy

LGIM America reserves the right, at its sole discretion, to change, modify, add, remove, or otherwise revise portions of this Privacy Policy at any time. If we do, we will provide access to the immediately prior version of the Privacy Policy on the Site. Your continued use of the Site following the posting of changes to these terms means you accept these changes.

Non-affiliated third parties are independent from LGIM America and if you wish to receive information about your disclosure choices or stop communications from such third parties, you will need to contact those non-affiliated third parties directly.

California residents

This provides eligible California residents with specific rights with respect to our collection, retention, and use of Personal Information. Any terms not defined in this section have the same meaning as defined in the CCPA.

A. Information we collect:

In the course of our business, we collect information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). Depending on how you have interacted with us, we may have collected the following categories of Personal Information from you in the last twelve (12) months, which we may also share with third parties for the purposes outlined in this Privacy Notice. The categories below are those identified in the California Consumer Privacy Act (CCPA).

Please note that we have not collected every type of Personal Information identified in the Examples below, and the types of Personal Information we have collected on any consumer depends on how the consumer has interacted with us.

Category

Examples

Collected?

Identifiers.

This category may include: name, postal address, unique personal identifiers, online identifiers, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. Under the CCPA, “unique identifiers” or “unique personal identifier” means a persistent identifier that can be used to recognize a consumer, a family, or a device that is linked to a consumer or family, over time and across different services, including, but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device.

YES

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) and protected classification characteristics under California or federal law.

This category may include: name, signature, Social Security number, physical characteristics, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education or employment information, financial account numbers, medical information, health insurance information, age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex and gender information, veteran or military status, or genetic information.

YES

(for prospective employees and job applicants)

Commercial information.

This category may include: records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

NO

Biometric information.

This category may include: imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a face print, a minutiae template, or a voiceprint, can be extracted.

NO

Internet or other electronic network activity information.

This category may include: browsing history, search history, and information regarding interactions with an Internet Web site, application, or advertisement. LGIM America does make reasonable efforts to respect Do Not Track settings in browsers.

YES

Geolocation data.

This category may include: physical location or movements of your device or if you share the information with us at an event.

YES

(only for IP address data which may approximate a visitor’s general location)

Sensory data.

This category may include: audio, electronic, visual, thermal, olfactory, or similar information.

NO

Professional or employment-related information.

This category may include: current or past job history or performance evaluations.

YES

Non-public education information

This category may include: education records directly related to a student maintained by an educational institution or party acting on its behalf (e.g., grades, transcripts, schedules, and student ID numbers).

YES

(for prospective employees, consultants, or contractors)

K. Inferences drawn from other personal information.

This category may include: inferences drawn from the above information that may reflect your preferences, characteristics, predispositions, behavior, interests, attitudes, or similar behavioral information.

YES

Please note that some of the categories of personal information described in the CCPA overlap with each other; for instance, your name is both an Identifier and a type of data described in Cal. Civil Code 1798.80(e).

Personal information does not include publicly available information from government records or any deidentified or aggregated consumer information. In addition, the CCPA excludes the following from its scope: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

B. Use and sharing of personal information:

We may use or disclose the personal information we collect for the purposes described in the “Information Use” and “Information Sharing” Sections above.

In the preceding twelve (12) months, LGIM America has disclosed the following categories of personal information for a business purpose: professional or employment-related information (for prospective employees, contractors or consultants); non-public education information (for prospective employees only); and inferences drawn from other personal information.

C. Sales of personal information:

In the preceding twelve (12) months, LGIM America has not sold personal information.