Aristotle reserves the sole discretion to change this policy by updating this page. You should review this page periodically to ensure that you are comfortable with any changes.
Details about collection and use of data
The information we collect varies depending on your activity and use of the services or products offered by Aristotle. This Policy describes our practices with respect to the website, and any time you contact Aristotle through the website, via email, or otherwise, submit a request for information, proposals, or engage in any other activity through the website in which personal information is provided to Aristotle. Other websites that Aristotle may provide as a service to clients have their own dedicated websites and privacy policies, which you can find on the applicable website.
Categories of Personal Information
Aristotle collects the following categories of personal information:
- Contact and/or Personal Information – including your name, telephone number, address, and email address, IP address, and other information you provide through our website messaging portal or send to Aristotle by email or another electronic means. Additionally, if you apply to an Aristotle job, we may also ask you to provide additional personal data as part of our job application process. By submitting information to Aristotle on or through this website or through any other means, you acknowledge that you have read this Policy, understand it, agree to its terms, and authorize Aristotle to collect, use and disclose information pursuant to this Policy.
- Data on how you use this website – including your URL clickstreams, pages viewed, how long you view our pages, how often you visit our website, and other similar information.
- Data that identifies you – including your IP address, browser type and version, browser plug-in types, operating system and version, login information, and geolocation information about where you might be.
- Browsing information – including the website you came from, the website you visit next, and other similar information. Such information is collected through cookies and other technologies described below.
Recipients / Categories of Recipients
Your personal information may be shared with:
- Our service providers – including, as applicable, IT service providers, commercial email providers, security consultants, compliance administrators, payment processors, and other vendors Aristotle engages so that they may provide services to us or on our behalf.
- Other third parties – pursuant to a regulatory request or subpoena and / or when Aristotle believes it is required by, or necessary to comply with, applicable law. Aristotle may also provide your personal information to third parties when you ask us to do so.
Data Retention and Protection
Your personal data is generally stored until Aristotle receives a request to remove it or as otherwise required by internal policies and procedures, applicable law and/or contractual terms. Aristotle stores the data it collects in the United States and subjects such data to Aristotle’s Cybersecurity Policies & Procedures (to the extent applicable). Aristotle uses reasonable physical and technical measures to prevent unauthorized access or loss, and/or unlawful processing.
Information about processing of personal data
Purpose for Processing
The personal data Aristotle collects will be used for the following purposes:
- Marketing purposes – including sending you emails regarding service offerings and other content.
- Internal business operations – including (1) providing you with information pursuant to a request, responding to inquiries, and providing Aristotle’s services; (2) communication with you regarding Aristotle’s services; (3) compliance with our legal obligations; (4) in response to court orders or regulatory requests and in exercising Aristotle’s legal rights; (5) in protecting our and our clients’ rights and property; and/or (6) screening and other activities in connection with your employment or other engagement.
Legal Basis for Processing
Aristotle’s legal basis for processing your personal data that we receive through the website is based one or more of the following legal bases
- Your consent – By submitting Information to Aristotle on or through the site, a user acknowledges that he or she has read this Policy, understands it, agrees to its terms, and authorizes Aristotle to collect, use and disclose Information pursuant to the terms of this Policy.
- To comply with your instructions
- As is necessary for our legitimate interests, including direct marketing or fulfilling a service obligation; and/or
- To comply with the law and our legal obligations.
Know Your Rights
You have various legal rights regarding how your personal data is collected and processed. Your rights vary depending on the jurisdiction and laws applicable to you, which may include those described below. Where applicable, you may exercise your rights by contacting us as provided below. In reviewing your request, we may request additional information, as reasonable necessary to understand and authenticate the request.
- The right to access information Aristotle holds on you.
If applicable, you may request additional information about: (1) the categories of data we’re processing; (2) the purposes of data processing; (3) the categories of third parties to whom the data may be disclosed; (4) how long the data will be stored (or the criteria used to determine that period); (5) your other rights regarding our use of your data. Aristotle will provide you with the information within one month of your request, unless doing so would adversely affect the rights and freedoms of other (e.g. another person’s confidentiality or intellectual property rights). Aristotle will tell you if your request can’t be met for that reason.
- The right to opt-out of marketing communication.
If you have previously given consent to our processing your data, you can freely withdraw such consent at any time. You can do this by emailing us at firstname.lastname@example.org or by selecting “unsubscribe” from the relevant marketing communication. If you withdraw your consent, and if Aristotle does not have another legal basis for processing your personal information, then Aristotle will stop processing the data. If Aristotle does have another legal basis for processing your information, then Aristotle may continue to do so subject to your legal rights. You may also object to processing of your data if processing is based on a legitimate interest.
- The right to remove or erase personal data or contact information (“right to be forgotten”). You can do this by asking Aristotle to erase any personal data Aristotle holds about you, if it is no longer necessary for Aristotle to hold the data for purposes of your use of the website.
- The right of data portability where we process your personal information based on your consent. You may ask Aristotle to transfer your personal data to you or another third party upon request by contacting us at email@example.com.
- The right to correct any inaccurate personal information about you that is incorrect or incomplete. You also have the right to restrict or suspend processing of your personal data or correct. You can complete any or all the above by sending a request to firstname.lastname@example.org.
- The right to submit a complaint. If you have questions or complaints regarding Aristotle’s Policy or privacy practices, please contact Aristotle at email@example.com. While Aristotle would appreciate the opportunity to address your concerns, you may also submit complaints to relevant supervisory authorities.
- California Privacy Rights Under California Civil Code Section 1798.83 (the “Shine the Light”), California residents may request and obtain a list of personal data we disclose to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made once a year per person to the email address below and are free of charge. Aristotle does not disclose personal data protected under the “Shine the Light” law to third parties for their own direct marketing purposes.
Links to Third-Party Sites
Children’s Privacy Protection
This website is not directed towards children under 13 years of age, and Aristotle does not knowingly collect any information from children under 13 years of age through this website. If you are under 13 years of age, you are not permitted to submit any information to Aristotle through this website or any other means.
No Rights of Third Parties
This Policy does not create rights enforceable by third parties.
Changes to this policy
Aristotle reserves the sole discretion to change this policy by updating this page. We will use reasonable efforts to notify you of any material changes to this policy, such as by sending you the revised policy by email or posting a notice on our website. This policy is effective from May 25, 2018.
Contact Us with Any Questions or Concerns
Please contact firstname.lastname@example.org if you have any questions or concerns regarding our collection, use or disclosure of your personal information.
Aristotle Capital Management, LLC
Attn: Information Security Officer
11100 Santa Monica Blvd., Suite 1700
Los Angeles, CA 90025