First Pacific Advisors, LP
Privacy Policy

 

In accordance with the Securities and Exchange Commission regulations and certain other state laws, we are providing the following privacy notice of First Pacific Advisors, LP (“FPA”) and the funds it manages (collectively, the “FPA Funds” or “we”). A complete list of funds is provided below.

FPA and the FPA Funds take privacy seriously and consider privacy to be a fundamental aspect of its relationships with its former, prospective and current investors and clients. FPA is committed to maintaining the confidentiality, integrity and security of its former, current, and prospective clients’ and/or investors’ non-public personal information and other personal information.  This privacy policy describes our privacy practices surrounding the collection and sharing of non-public personal information and other personal information of current, former and prospective investors and clients and visitors to this website. For purposes of California residents only, pursuant to the California Consumer Privacy Act (“CCPA”), personal information includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California resident or a household. “Personal data” for the purposes of this policy includes nonpublic personal information and personal information as defined under the CCPA with regard to California residents.

Obtaining Personal Data. While providing clients, investors and/or prospective clients or investors  (collectively, “clients and/or investors”, as applicable) with products and services, FPA, the FPA Funds, and certain service providers, such as the FPA Fund’s Transfer Agents and/or Administrators, may obtain personal data about such clients and/or investors, which may come directly from the client, investor or their intermediaries from sources such as: (i) account applications, subscription agreements and other forms, (ii) written, electronic or verbal correspondence, (iii) client and/or investor transactions, (iv) a client and/or investor’s brokerage or financial advisory firm, financial advisor or consultant, and/or (v) from information captured on applicable websites, including information you may voluntarily provide when you subscribe to receive FPA’s quarterly updates or request us to mail you information about the FPA Funds. In addition, FPA and the FPA Funds may collect additional personal data from different sources, such as affiliates or their service providers; public websites or other publicly available sources such as government records; or from credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud.

The personal data collected about a client and/or investor may include: (i) identifiers and similar information such as the client and/or investor’s name, address, tax identification number, birth date, driver’s license number, and potentially email address and phone number (if provided); (ii) certain information protected under other federal or state law, like a client and/or investor’s signature or bank account information; (iii) characteristics of protected classifications under federal or state law, like gender or marital status; (iv) commercial information like an investment selection, beneficiary information, or transaction and account history with FPA and the FPA Funds; (v) internet or other electronic network activity like interactions with the FPA website; (vi) professional or employment-related information like a client and/or investor’s occupation and job title; and (vii) inferences drawn from the other categories to build a profile on a client and/or investor to, for example, gauge a client and/or investor’s potential interest in investing in new funds or products.

Respecting Your Privacy. FPA and the FPA Funds do not disclose any personal data provided by clients and/or investors or gathered by FPA and the FPA Funds to third parties, except as required or permitted by law or as necessary for such third parties to perform their agreements with respect to FPA and the FPA Funds. Non-affiliated companies may from time to time be used to provide certain services, such as maintaining client and/or investor accounts, preparing and mailing prospectuses, reports, account statements and other information, and gathering shareholder proxies. In many instances, the client and/or investor will be clients of a third party, but FPA and the FPA Funds may also provide a client’s and/or investor’s personal data and account information to the client’s and/or investor’s respective custodian, brokerage or financial advisory firm and/or financial advisor or consultant.

Sharing Information with Third Parties. FPA and the FPA Funds reserve the right to report or disclose personal data or account information to third parties in circumstances where FPA and the FPA Funds believe in good faith that disclosure is required or permitted under law, to cooperate with regulators or law enforcement authorities, to protect their rights or property, or upon reasonable request by FPA and the FPA Funds in which a client and/or investor has invested. In addition, FPA and the FPA Funds may disclose information about a client and/or investor or a client’s and/or investor’s accounts to a third party at the client and/or investor’s request or direction or with the consent of the client and/or investor.

Procedures to Safeguard Private Information. FPA and the FPA Funds will take reasonable steps and use security measures appropriate to the nature of the information and that comply with applicable laws to protect client and/or investors’ personal data against unauthorized access and exfiltration, acquisition, theft, or disclosure. In addition to this policy, FPA and the FPA Funds have implemented internal procedures that are designed to help guard clients’ and/or investors’ personal data. Given the nature of information security, there is no guarantee that such safeguards will always be successful. 

Information Collected Automatically from Websites. When you visit a website maintained by FPA or the FPA Funds, those sites may collect certain information about that visit through automated tools, including cookies. Cookies are bits of data that a website sends to a web browser on a visitor's computer. Websites maintained by FPA and the FPA Funds use cookies and other tools to operate the websites and collect analytics information about your visit to our websites, including the number of visitors to a website and the webpages visited. These tools may be provided by third party analytics providers. The analytics information collected does not identify a particular individual visitor or user. You can change your cookie preferences by changing the setting on your web browser to delete or reject cookies. If you delete or reject cookies, some website pages may not function properly. FPA and the FPA Funds websites do not respond to “do not track” signals.

Links to Other Websites. This privacy policy only addresses the use and disclosure of personal data in conjunction with your use of websites maintained by FPA or the FPA Funds. These websites may contain links to other websites. If we create such a link, we will let you know when you are leaving the FPA website. These third-party websites may collect information, including personal data, from you. Please be aware that we are not responsible for the privacy practices or the content of third-party websites. We disclaim liability for any information, materials, products or services offered at any of the third-party sites linked to websites maintained by FPA or the FPA Funds. The availability of a link to another party’s website is provided as a convenience, but it does not constitute an endorsement or sponsorship of any third party or their products, and does not create an affiliation or partnership between FPA and any third party. You should also be aware that third parties have different privacy policies than FPA and may have different information security practices. We encourage you to read the privacy statements provided by other websites before you provide personal data to them.

Rights Applicable to California Residents. For purposes of the CCPA, FPA and the FPA Funds are a business. Certain California residents as defined under the CCPA may have certain rights concerning their personal information, subject to applicable exemptions and limitations, such as the right to: (i) be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used; (ii) not be discriminated against because they exercised any of their rights under the CCPA; (iii) request that FPA and the FPA Funds delete any personal information about them that FPA and the FPA Funds have collected or maintained, subject to certain exceptions (“request to delete”); and (iv) request that FPA and the FPA Funds, as a business that collects personal information about them and that discloses their personal information for a business purpose, disclose to them (“request to know”): (a) the categories of personal information FPA and the FPA Funds have collected about them; (b) the categories of sources from which FPA and the FPA Funds have collected the personal information; (c) the business or commercial purpose for collecting or selling the personal information; (d) the categories of third parties with whom FPA and the FPA Funds share personal information; (e) the specific pieces of personal information FPA and the FPA Funds have collected about them; and (f) the categories of personal information FPA and the FPA Funds have disclosed about them for a business purpose. 

For purposes of this CCPA section only, references to personal information relate to the definition of that term under the CCPA.  Personal information does not include deidentified information, aggregate consumer information or publicly available information (as defined in the CCPA).

We may disclose for a business purpose all or just a few of the categories of personal information collected from California residents identified in the section “Obtaining Personal Data” to our service providers or other entities listed in the paragraph labelled “Sharing Information with Third Parties” that have agreed to limitations on the use of your personal information or that fit within other exemptions or exceptions in or are otherwise permitted by the CCPA or other applicable laws. 

We also may collect and use personal information from California residents for the following business or commercial purposes: (i) performing services on behalf of FPA, including, for example, maintaining or servicing accounts, providing customer service, processing transactions, verifying information, processing payments, or providing similar services; (ii) performing our contractual obligations, including processing initial subscriptions and providing updates on our performance and other operational matters; (iii) detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, including, preventing fraud and conducting “Know Your Client,” anti-money laundering, terrorist financing, and conflict checks; or (iv) enabling or effecting commercial transactions, including, using bank account details to remit funds and process distributions.

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information, including, generally, personal information collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act and its implementing regulations. We also reserve the right to retain, and not to delete, certain personal information after receipt of a request to delete from a California resident where permitted by the CCPA or another law or regulation. We do not sell California resident personal information except as permitted by the CCPA.

California residents may contact us in order to exercise any of your rights under CCPA, to the extent any are applicable, by calling this toll-free number, 1-800-982-4372, Option 3, by emailing us at dataprotection@fpa.com. This toll-free number and email address can be found on our website at https://fpa.com/privacy-policy.

FPA and the FPA Funds are required to provide certain information or to delete personal information only in response to verifiable requests made by a California resident or the legally authorized agent of a California resident. Any information gathered as part of the verification process will be used for verification purposes only.

Changes to the Privacy Policy. From time to time, FPA and the FPA Funds may update or revise this privacy policy. If there are changes to the terms of this privacy policy, documents containing the revised policy on the relevant website will be updated.

Funds Managed by FPA. FPA Capital Fund, Inc., FPA Crescent Fund, FPA International Value Fund, FPA New Income, Inc., FPA Flexible Fixed Income Fund, FPA Paramount Fund, Inc., FPA U.S. Value Fund, Inc., Source Capital, Inc. and certain private vehicles managed under the Contrarian Value, Multi-Advisor and International Value Strategies.

 

Revised: January 2020