Brandywine Asset Management, Inc. Privacy Policy

Brandywine Asset Management, Inc.’s (“Brandywine”) commitment to you:  We will never sell or rent your private information to anyone.

Collection of Information

Brandywine collects contact information and other relevant data from prospective clients so that we can provide them with the information they’ve requested.

All personal information submitted to us will be held confidential in accordance with our privacy policy.

Privacy Policy Background

Pursuant to Regulation S-P issued by the Securities and Exchange Commission and adopted by the National Futures Association (“NFA”), Brandywine has instituted a Privacy Policy to protect nonpublic personal information (“NPI”) about our clients under Section 504 of the Gramm-Leach-Bliley Act. Requirements under the Act include but are not limited to:

  • Providing our clients with annual notices detailing our use of their NPI and offering them the option of “opting-out” of any disclosure of their NPI to affiliated or non-affiliated persons/firms.
  • Providing prospective clients with an initial notice detailing our use of their NPI and offering them the option of “opting-out” of any disclosure of their NPI to affiliated or non-affiliated persons/firms.
  • Protecting personal information about our current and past clients by not disseminating information to any outside parties except as required/permitted by law or requested by the client.
  • Protecting personal information about our current and past clients from accidental dissemination / theft by maintaining adequate security of information, be it in paper or electronic format.

The Privacy Policy will be updated annually or as necessary by Brandywine.

Privacy Policy

We respect your right to keep your personal information confidential. The following information is intended to provide you with a better understanding of our privacy policy with respect to your personal information:

Information We Have About You

We receive information about you that is not available publicly in order to help us serve your financial needs, offer you investment advisory services and to fulfill contractual, legal and regulatory requirements. This information is received from a variety of sources, including:

  • Information you provide directly to us, such as your name, address, social security number, assets, liabilities and income.
  • Information about your relationship with us, such as account information and payment history.
  • Information we receive with your authorization from third parties, such as financial institutions, companies, and other individuals.
  • Information from consumer reporting agencies, such as credit relationships and history.

Protection and Use of Information

We use the information acquired only for the purpose of providing professional investment advisory services to you. We take reasonable steps to keep confidential the information acquired. Where appropriate, information provided by us to employees, affiliates and nonaffiliated third parties who perform services for us, is subject to contractual agreement which prohibit these parties from disclosing or using the information other than for the purposes for which the information was disclosed. We also maintain reasonable physical, electronic, and procedural safeguards in compliance with applicable laws and regulations to protect your nonpublic personal information.

Employees of Brandywine are forbidden from disclosing NPI about any of our clients, except as required by law, unless directed to do so by that client. Brandywine has appropriate security measures in place at its physical facilities to protect against the loss, misuse or alteration of private information collected from users.

Parties to Whom We Disclose Information

We do not disclose any nonpublic personal information about our clients or former clients to our affiliates or to nonaffiliated third parties except as permitted by law. Nonpublic personal information about current and former clients may be disclosed to our affiliates and to nonaffiliated third parties as permitted by law, as follows:

  • as necessary to effect, administer or enforce a transaction requested or authorized by the client;
  • as necessary to properly maintain and service such client’s account;
  • providing information to affiliates and nonaffiliated third parties, such as attorneys, accountants and auditors who perform services or functions for us pursuant to a contractual agreement which prohibits the affiliate or the nonaffiliated third party from disclosing or using the information other than for the purposes for which the information was disclosed;
  • in complying with Federal, state or local laws, rules and other applicable legal requirements;
  • in complying with a properly authorized civil, criminal, or regulatory investigation or subpoena or summons by Federal, state, or local authorities; or
  • in responding to judicial process or government regulatory authorities having jurisdiction over us for examination, compliance and other purposes as authorized by law.

Online Advertising

Brandywine’s online advertising is in full compliance with Internet, advertising and finance industry standards and regulations. Our advertising content is integrated and delivered with online publisher’s primary content in a variety of different formats; some in graphical format (e.g. banner) and others in text format.

The delivery of our online advertisements (and frequency thereof) is ultimately controlled by the respective online publisher. Unfortunately, we are unable to suppress or restrict the delivery of our online advertisements to individual users. Many publishers offer “frequency capping” to limit the number of advertisements a user will receive on a periodic basis. However, this functionality will NOT work if you have disabled “cookies” in your browser. For example, if you are experiencing a high volume of online advertisements in general (like pop-up ads), then it might be an issue with your Internet browser’s ability to accept “cookies”. It is important that you have “cookies” enabled in your browser settings. For further information about cookies, see the “Clickstream Data and Cookies” section.

Clickstream Data and Cookies

Brandywine may collect information regarding the behavior of users visiting our website, such as clickstream data and IP address. Brandywine may collect this information for reasons such as legal compliance, security protection and to improve Brandywine’s services and your experience with the website. If you visit another website via a link on the Brandywine website, the service provider or media owner of such other website may also collect similar information.

What is a “cookie”? A cookie is a small data file containing information, such as a link that a user clicked on, which is written to the user’s hard drive by a web server and used to track the pages visited. With cookies, the information is anonymous and not personally identifiable. It does not contain personal information such as name, address, telephone number or email address. It also does not contain user passwords. The individual information gathered in this manner is used for internal purposes only, such as looking at unique page views and customizing content. We also use the information on an aggregate basis, to track the usage of our website and to analyze traffic patterns.

You can control your browser’s settings regarding cookies by selecting “Internet Options” or “Preferences” in the menu bar of your browser. This will allow you to prevent your browser from accepting new cookies, have your browser notify you when you receive a new cookie, or disable cookies altogether. However, because our website requires cookies for certain functions, we recommend you leave them enabled.

Correcting Personal Information

Upon request, we will provide site visitors with access to respective contact information (e.g., name, address, phone number) that is maintained about them. To access this information, please email privacy@brandywine.com. Upon request, we will also offer visitors the ability to have inaccuracies corrected in the database. Users can have this information corrected by sending email to privacy@brandywine.com.

Unsubscribing from Future Marketing

If contact information is willingly provided to us by mail, phone, email, online or otherwise, in response to our marketing activities, individuals may receive subsequent periodic information from Brandywine on new products and services or upcoming events. If individuals don’t wish to receive such information, please let us know by sending an email to privacy@brandywine.com, or by writing to the following address:

Brandywine Asset Management
ATTN: Marketing Department
381 Brinton Lake Road
Thornton, PA 19373

Please provide Brandywine with the exact name and address as it was originally provided. We will be happy to remove your name from our database and will do everything possible to honor your request for removal.

To unsubscribe from Brandywine’s email communications, send an email to unsubscribe@brandywine.com. Please put “UNSUBSCRIBE” in the subject field and include the email address where you received the content, along with any additional email addresses you would like suppressed. We will do our best to prevent you from receiving our email content in the future.