Privacy Policy

Conditions of Use

By using this site, you signify your assent to the following conditions of use without limitation or qualification. Please read these conditions carefully before using this site. The TCW Group may at any time revise these conditions by updating this posting. You are bound by any such revisions and should therefore periodically visit this page to review the then current terms and conditions to which you are bound. References to the TCW Group shall be deemed to include The TCW Group, Inc., TCW Asset Management Company and TCW Investment Management Company. Nothing contained in this site constitutes investment advice or a recommendation to buy or sell any security, management product or service.

Limitation of Liability
While the TCW Group uses reasonable efforts to include accurate and up to date information on this web site, errors or omissions sometimes occur. This site is for informational purposes only and TCW Group makes no warranties or representations as to the accuracy of this web site or of any linked site. Under no circumstances shall TCW Group nor any party involved in creating, producing, or delivering the web site be liable for any direct, incidental, consequential, indirect, or punitive damages that result from the use of, or the inability to use, the materials on this web site, even if a TCW Group authorized representative has been advised of the possibility of such damages. Applicable law may not allow the limitation or exclusion of liability or incidental or consequential damages, so the above limitation or exclusion may not apply to you.

A word of warning-past performance is not necessarily a guide to the future. The value of investments and the income from them can go down as well as up and an investor may not get back the amount invested. Exchange rates may vary causing the value of oversees investments to go up or down.

TCW Group also assumes no responsibility, and shall not be liable for, any damages to, or viruses that may infect your computer equipment or other property on account of your access to, use of, or browsing in the web site or your downloading of any materials, data, text, images, video, or audio from this web site.

Any links to other Internet sites are included as a convenience and TCW assumes no liability for the content or the presentation of linked sites. Third party links to this site are permitted only with TCW’s prior written consent. No representations or warranties are made for any software that may be downloaded from this site.

Restrictions on use of Materials
Except as otherwise permitted by TCW Group, no materials from www.tcw.com or any web site owned, operated, licensed or controlled by TCW Group may be copied, reproduced, republished, uploaded, posted, transmitted or distributed in any way. You may download material displayed on this web site for non-commercial, personal use only, provided you also retain all copyright and other proprietary notices contained on the materials. You may not distribute, modify, transmit, reuse, report or use the content of this web site for public or commercial purposes, including the text, images, audio and video, without TCW Group’s prior written permission.

Cookies
The TCW websites use cookies. Cookies are used to enhance the visitor experience and help us to provide customized services and information. To find out more about cookies on the TCW websites and how to delete cookies, see our cookie policy.

Jurisdictional Issues
The information contained on this web site is not an offer to sell or solicitation to buy any security or product. No
security or product is offered or will be sold in any jurisdiction in which such offer or solicitation, purchase or sale
would be unlawful under the securities, insurance or other laws of such jurisdiction.

Privacy Policy

TCW takes your privacy seriously. This notice contains information on the (among other things):
  • types of personal information we collect (see section 1);
  • purposes for which we use this information (see section 3);
  • parties with whom we share this information (see section 4); and
  • rights you have as a data subject (see section 7).

1. The types of personal information we collect


This notice applies to each member of the TCW group of companies (“the TCW Group”) and the entities we own or control (TCW”, “we”, “our”, or “us”). For more details on the companies in the TCW Group (including our names, the address of our registered offices and our contact details), please visit https://www.tcw.com/en/About_TCW.

We will collect and process personal information about you in the course of providing products or services to you or our client, when performing due diligence checks in connection with those products or services, and when we discuss the possible products or services we might provide.

Depending on the product or service we provide to you or our client, we will collect:

  • if your employer is our client, your basic contact information such as your title, name, phone number, email address, office address and job title;
  • if you are our client, including where you receive our product or service through an intermediary, your contact and client information such as your title, name, identification number, date of birth, phone number, email address, physical addresses, job title, residency status, family circumstances (such as your marital status), national ID card and passport number, financial and tax related information (for example, your income, assets and tax residency), identifiers we assign to you (such as your account number), and details of how you use the product or service we provide;
  • when you access our website, any data transmitted by your browser will be automatically recorded by our server, including date and time of the access, name of the accessed file as well as the transmitted data volume and the performance of the access, your web browser, browser language and requesting domain and IP address. Our website also contains additional information about how we use your information online; and
  • in some cases, special categories of personal information, such as information relating to your dietary requirements (for example where you indicate the type of food you would like during a meeting), your health (for example, so that we can make reasonable accommodations for you in our building), your sexual orientation (for example, if you provide us with details of your spouse or partner) and information on criminal convictions or offences (for example, if this information is collected as part of ‘know your client’ and anti-money laundering checks that we conduct).

We typically collect your personal information when you give it to us (for example, using a form on our website or providing account information and related documentation), or when other people give the information to us (for example, from third party service providers like those who help us meet our legal requirements in respect of ‘know your client’ and anti-money laundering checks). Where applicable to the product or service you receive, we will collect your personal information from our partners, brokers and intermediaries.


2. Legal basis for using your information


We use your personal information under applicable data protection laws because it is:

2.1   necessary for our legitimate interests (where our use does not unduly affect your interests or fundamental rights and freedoms). Examples of these interests include when we benefit from cost-efficient services from our service providers such as IT platform providers, take steps to prevent fraud, criminal activity and misuse of our products and services and IT systems, exercise our rights under Articles 16 and 17 of the Charter of Fundamental Rights including our freedom to conduct a business and right to property, and meet our accountability and regulatory requirements around the world;

2.2   required to meet our legal or regulatory responsibilities, including when we conduct the anti-money laundering checks referred to in section 3.2 below and when we are obliged to make disclosures to authorities, regulators and government bodies;

2.3   necessary for taking steps to enter into or executing a contract with you, or for carrying out our obligations under such a contract;

2.4   necessary for the performance of a task carried out in the public interest;

2.5   when we use special categories of personal information necessary for establishing, exercising or defending legal claims or where the processing relates to personal information manifestly in the public domain; or

2.6   processed with your consent which we obtain from you from time to time in limited circumstances, or processed with your explicit consent in the case of special categories of personal information.

Where the personal information we collect from you is needed to meet our legal or regulatory obligations or enter into a contract with you, if we cannot collect this personal information there is a possibility we may be unable to on-board you as a client or provide you with products or services (in which case we will inform you accordingly).


3. Using your personal information for certain purposes


We use your personal information to:

3.1   provide you or our client with selected products or services, including corresponding with you or our client, our service providers, other members of the TCW Group or public or judicial authorities with the necessary authorisation, in relation to those products or services;

3.2   carry out or to facilitate the carrying out with respect to clients and prospective clients of due diligence checks (including credit, anti-money laundering, and conflict checks) for the purposes of fraud, anti-money laundering, financial crime prevention and tax identification laws (including FATCA and any other Information Reporting Regime and applicable anti-money laundering and counter-terrorist financing laws), and to process an application from you or a prospective client to receive products or services from us, and comply with our respective legal obligations arising in connection therewith;

3.3   facilitate the provision to us of services by our third-party service providers, and our ongoing evaluation of those services;

3.4   comply with legal and regulatory requests made to us anywhere in the world, and assist with any litigation, disputes or contentious matter in which we are involved;

3.5   carry out satisfaction surveys and other client surveys;

3.6   take steps to improve our products and services, and our use of technology, including by testing our systems and processes and upgrading them;

3.7   take steps to ensure the safety of our clients, employees and other stakeholders;

3.8   carry out internal audits (including for security reasons), statistical analysis, and record keeping activities;

3.9   enable a transfer to a potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger of part or all of TCW’s business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it (and when we disclose your information to potential purchasers, they will be required to keep the information confidential);

3.10   (to the extent applicable) assist with direct marketing; and

3.11   any other purposes we notify to you from time to time.


4. Sharing your personal information


4.1   Within the TCW Group
We share personal information with other members of the TCW Group, in connection with the provision of products or services to you or our client. These members of the TCW Group provide us with various IT and marketing services supporting our business. This allows us to provide a high standard of service across the TCW Group. More information about the members of the TCW Group who receive your personal information can be found in section 6.

4.2   Third-party service providers
We also share personal information with other third parties who assist us in providing products and services to you. These parties include, where applicable to the products or services we provide to you or our client:

  • hosting and other IT service providers;
  • financial advisors and consultants (including lawyers and accountants); and
  • other goods and service providers such as providers of marketing services.

4.3   Our partners and intermediaries
Where applicable to the product or service we provide to you or our client, we share personal information with intermediaries, brokers and other individuals and entities that partner with us.

4.4   Public bodies and regulators
We disclose personal information, where appropriate, to fraud prevention and law enforcement agencies to prevent crime, and to other public authorities, regulators or governmental bodies, including when required by legislation or by agreement with the relevant authority, under a code of practice or conduct, or when the authority or body require us to do so.

4.5   Other disclosures
We disclose personal information in the context of corporate activities, including if there is a change in ownership of our business or if our business is re-organised, so that you can continue to receive products or services from us. We may also disclose personal information to a potential purchaser who is evaluating whether to purchase our business (in which case we will take steps to ensure that the potential purchaser keeps information confidential).

If you exercise your right to data portability, we may (depending on your request) disclose your personal information to an intermediary that facilitates data portability.
We share personal information where required to exercise or protect legal rights, including ours and those of our employees or other stakeholders, or in response to requests from individuals who seek to protect their legal rights or legal rights of others.


5. Storing your personal information


We determine the period for retaining your personal information with regard to the period for which storage is necessary to achieve the purpose for collecting the information, and our operational and legal requirements (which includes responding to legal claims or regulatory requests).

For example, although there may be some limited exceptions, in general we will retain your personal information for approximately 7 years after you have terminated your relationship with the TCW Group and its affiliates, or 7 years from when you last visited our Website (if you or your employer do not receive any products or services from us). Subject to legal and regulatory requirements, this data is then retained in accordance with TCW’s backup retention policy and will be deleted within 12 years after this same date. Where there are technical limitations that prevent deletion or anonymization in backup, we safeguard personal data through access control measures to limit the active use of it.


6. Transferring your personal information internationally


Data protection laws in the European Economic Area (EEA) require additional compliance steps for sending personal information abroad. These compliance steps help ensure that the same level of protection is applied to personal information once it leaves the EEA.

Some of the recipients of your personal information will be based in countries outside the EEA, such as the United States.

If your personal data is transferred outside the EEA, we will put in place suitable safeguards to ensure that such transfer is carried out in compliance with applicable data protection rules. To ensure this level of protection for your personal information, TCW uses a data transfer agreement with the third party recipient based on standard contractual clauses approved by the European Commission or ensure that the transfer is to a jurisdiction that is the subject of an adequacy decision by the European Commission or to the US under the EU-US Privacy Shield Framework. You may request additional information in this respect and obtain a copy of the relevant safeguard by exercising your rights as set out below.


7. Your data protection rights


Depending on your location, you have the data protection rights listed below. TCW will consider requests to exercise these rights under applicable data protection laws, but these rights are not absolute: they do not always apply and exemptions may be engaged.

  • You have a right to ask us to delete your personal information, rectify inaccurate personal information we collect and process, and request restriction of your personal information pending such a request being considered.
  • Where your personal information is processed on the basis of your consent, you have the right to withdraw that consent at any time. 
  • You have the right to object to the processing of your information.
  • If we use your information to market directly to you, your right to object extends to that direct marketing, including profiling to the extent it is related to such marketing.
  • Where we rely on your consent for using personal information, or where our use of personal information is necessary to enter into or perform under a contract with you, you may have the right to request your personal information be ported to you or to another data controller. 
  • You have the right to ask us for a copy of your personal information. 

You can exercise the rights set out above using the details in section 8 of this notice.


8. Exercising your data protection rights; complaints


If you would like to speak to us about how we use your personal information, you can do this by contacting us at the details at the end of this notice.
If you are not satisfied with our response, you have the right to complain to the data protection authority in the jurisdiction where you live or work, or in the place where you think an issue in relation to your data has arisen. In the UK, the data protection authority is the Information Commissioner’s Office. Their details are available at www.ico.org.uk.


9. Status of this privacy notice


This is a notice explaining what TCW does with personal information. It does not contractually bind TCW or any other party. It was last updated in May 2018.

We reserve the right to update it from time to time. If we update the notice, we will take steps to inform you of the update by appropriate means. These means will depend on how we normally communicate with you.


10. Contact information


How to contact us:

Call:
1+213-244-0000
Write to us:
Data Protection
The TCW Group, Inc.
865 South Figueroa Ave.
Suite 1800
Los Angeles, CA 90017
Email us:
privacy@tcw.com

REMINDER ABOUT TCW'S FINANCIAL PRODUCTS


Financial products offered by The TCW Group, Inc. and its subsidiaries, the TCW Funds, Inc., TCW Strategic Income Fund, Inc., the Metropolitan West Funds, TCW Alternative Funds, Sepulveda Management LLC and TCW Direct Lending.

  • Are not guaranteed by a bank;
  • Are not obligations of The TCW Group, Inc. or of its subsidiaries;
  • Are not insured by the Federal Deposit Insurance Corporation; and
  • Are subject to investment risks, including possible loss of the principal amount committed or invested, and earnings thereon.
 

THE TCW GROUP, INC.

TCW FUNDS, INC.

TCW STRATEGIC INCOME FUND, INC.

METROPOLITAN WEST FUNDS

 

TCW ALTERNATIVE FUNDS

SEPULVEDA MANAGEMENT LLC

TCW DIRECT LENDING LLC

TCW DIRECT LENDING VII LLC

Attention: Privacy Officer | 865 South Figueroa St. Suite 1800 | Los Angeles, CA 90017 | email: privacy@tcw.com