Janus Henderson Investors (also referred to throughout this policy as ‘Janus Henderson’, ‘we’, ‘us’, or ‘our’), is committed to protecting the privacy of current and prospective clients. After all your relationship with us is built on trust and our goal is to preserve that trust. We safeguard personal information by taking measures to maintain its confidentiality integrity, and security. This policy sets out the basis on which your information is collected, stored and used by us when you engage and interact with us.
If you choose to use this mobile app service, then you agree to the collection and use of information in relation to this Policy. The Personal Information that we collect is used for providing and improving the service. We will not use or share your information with anyone except as described in this Policy.
Janus Henderson Investors
Data Privacy Office
151 Detroit Street
Denver, CO 80206
In this policy, “personal information” means all of the non-public personal and financial information about you that we collect, use, share and store. Most of the information collected by us is information which you have provided to us directly, whether this is from you signing up online to receive information from us or by your providing information to us when becoming a client of ours.
Information we collect from you when you visit and/or request to receive information from our website:
Information that we collect or generate about you includes:
If you are looking to become a client of ours, or are already a client of ours, in addition to the above, we may also collect or generate additional information about you. This includes:
There may be some instances where we receive information about you from a third party. This includes:
Janus Henderson may use information that cannot be linked to or identify a particular individual such as anonymized or aggregated information. This information is not considered personal information, and therefore, is not subject to this policy. This information is used to produce statistical research, reports, and other information that serves to enhance the products and services provided by us.
We process your information to the extent necessary for us to carry out investment activities, communicate with you, meet our regulatory obligations and for other legitimate business purposes permitted by applicable law. Your information may be stored and processed by us in the following ways and for the following purposes:
Whenever we use information, we make sure that the usage complies with all applicable laws.
We may share your information within Janus Henderson (both in the US and internationally) for the purposes described above. All of our employees and contractors are required to follow our data privacy and security policies when handling personal information.
We may also share your personal information outside of Janus Henderson, only for the purposes described above and under the following circumstances.
Legal obligations: we share information (i) to the extent that we are required to do so by applicable law, by a governmental body or by a law enforcement agency, or for crime prevention purposes (including fraud protection); (ii) in connection with any legal proceedings (including prospective legal proceedings); or (iii) in order to establish or defend our legal rights.
The mobile app service does use third party services that may collect information used to identify you. Links to the privacy policies of the service providers used by the mobile app service are:
Consent: when you request that we share your information with someone else (for example if you engage the services of a professional advisor after you have become a client of ours and request that we provide information about your account to that professional advisor) or when we have otherwise obtained your consent. If we share information other than as permitted or described above, we will provide you with a choice to opt in to such sharing and you may choose to instruct us not to share the information.
Business sale: if we sell some or all of our business or assets we may need to disclose your information to a prospective buyer for due diligence purposes. If we are acquired by a third party, the information held by us about you will be disclosed to the third-party buyer.
We do not disclose, and do not intend to disclose, non-public personal or financial information to non-affiliated third parties with respect to persons who no longer maintain a relationship with Janus Henderson.
We do not sell your non-public personal or financial information without your consent.
Janus Henderson is not in the practice of selling or distributing nonpublic information to third parties. If, in the future, our business directs us to do this, you will be notified and given the opportunity to opt out of having this information shared.
You may submit a written request to us to correct or amend any information in our records. If you have shares held directly with Janus Henderson, you can correct, update or confirm your personal information anytime on janushenderson.com by going to “My Account” and select “Account Profile”. Or, you can call a Janus Henderson Representative at (800) 525-3713.
The mobile app service is not intended for children under 18 years of age, and we do not knowingly collect personal information from children under 18. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at the details listed above.
The mobile app service is not intended for use by non-US residents, and we do not knowingly collect personal information from non-US residents. If we learn we have collected or received personal information from non-US residents, we will delete that information. If you believe we might have any information from or about non-US residents please contact us at the details listed above.
Whenever you use the mobile app service, in a case of an error in the app we collect data and information (through third party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the mobile app when utilizing the service, the time and date of your use of the service, and other statistics.
The mobile app service does not use these “cookies” explicitly. However, the app may use third party code and libraries that use “cookies” to collect information and improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of this service.
Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the web sites you visit indicating that you do not wish to be tracked. Janus Henderson does not respond to Do Not Track signals and will continue to track your Internet Protocol (IP) address for our internal reporting purposes.
As a condition of employment, Janus Henderson employees are required to follow all applicable laws and regulations, including data protection laws. Access to non-public information is limited to those employees who need it to perform their roles. Unauthorised use or disclosure of confidential client information by a Janus Henderson employee is prohibited and may result in disciplinary measures.
We restrict access to personal information to those who require it to develop, support, offer and deliver products and services to you.
This additional information is being provided as required by the California Consumer Privacy Act of 2018 (the “CCPA”) and the California Privacy Rights Act of 2020 (the “CPRA”). California residents are offered specific privacy rights, including the right to:
As a California resident, you or an authorized agent acting on your behalf, may exercise your rights by submitting a verifiable request using one of our two options:
Please note that we may need to verify your identity before we can fulfil your request. We will respond to your request within 45 days from the date of our receipt of your verifiable request. We will notify you if additional time is necessary to complete your request. If you are exercising access or deletion rights on behalf of another person, please either confirm that the person has authorized you to act as an agent with us or be prepared to provide proof that you have been designated as an authorized agent.
Last updated: September, 2022