California Privacy Disclosure: Employees, Contractors and Prospective Employees
Your privacy is important to us. This California Privacy Disclosure explains how Dimensional Fund Advisors LP and its US affiliates (collectively, “Dimensional,“ “we,“ “our,“ “us“) collect, use, and disclose personal information relating to Dimensional’s California-resident employees, contractors, and prospective employees that is subject to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (as amended, the “CCPA”).
What is Personal Information?
Under the CCPA, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. In general, this does not include Personal Information that has been deidentified or aggregated.
The CCPA does not apply to certain Personal Information. Of particular importance to our business, the CCPA does not apply to information subject to the federal Gramm-Leach-Bliley Act (“GLBA”), the federal law that governs the privacy practices of financial institutions. As a result, this Disclosure does not apply with respect to the information that we handle that is subject to the GLBA, such as information that we collect about California residents who request or obtain financial products or services from us for personal, family, or household purposes, or who invest directly in our advised funds. For more information about how we collect, disclose, and secure information in connection with our financial activities subject to the GLBA, please refer to the privacy policy
here.
Our Collection, Use, Disclosure, and “Sharing” of Personal Information
The following chart describes which categories of Personal Information we collect and process. This chart also describes which categories of Personal Information we disclose to third parties for our operational business purposes and which categories that we “share” for purposes of cross-context behavioral advertising, including within the 12 months preceding the date this Disclosure was last updated.
We may also disclose Personal Information: (i) as requested by any legal or regulatory authority or proceeding (including auditors); (ii) to a third party in the event of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings); or (iii) with your consent.
We do not sell Personal Information. In addition, we do not knowingly “share” (for purposes of cross-context behavioral advertising, as defined by the CCPA) Personal Information, including Sensitive Personal Information, relating to minors under 16 years of age.
Sources of Personal Information
We collect Personal Information relating to California residents in a variety of contexts. For example, we collect personal information relating to California residents who apply for employment with us, or are our employees, vendors, contractors, service providers, or have similar relationships with us.
We collect Personal Information directly from California residents and from sources such as public sources, applications, forms, communications, service providers, other third parties such as financial advisers, and information captured on our websites (including any information captured through the use of “cookies”).
Purposes for the Collection, Use, and “Sharing” of Personal Information
We collect, use, and “share” Personal Information for the purposes of operating, managing, and maintaining our business, managing our workforce and other employment purposes, managing our vendor relationships, providing our products and services, and accomplishing our business purposes and objectives, including to:
- Develop, improve, repair, and maintain our services;
- Fulfill requests and process transactions;
- Perform identity verification;
- Personalize, advertise, and market our and our affiliates’ services;
- Manage and administer our and our affiliates’ businesses;
- Conduct research, analytics, and data analysis;
- Maintain our property, facilities, and records, and undertake quality and safety assurance measures;
- Plan and manage workforce activities and personnel, including for recruitment, performance management, training and career development, payroll, expenses, work-related and emergency-related communications, payments and benefits administration, leaves and promotions;
- Process job applications, manage the applicant selection process, and conduct background checks, consistent with applicable law;
- Operate and manage IT and communications systems and facilities, allocate assets and human resources, and undertake strategic planning and project management;
- Conduct risk and security control and monitoring, and detect and prevent fraud;
- Conduct accounting, audit, and other internal functions, such as internal investigations and recordkeeping;
- Carry out corporate transactions, such as mergers, joint ventures, or acquisitions; and
- Comply with law, legal or regulatory process or proceedings, and internal policies, and exercise and defend legal claims.
Purposes for the Collection and Use of Sensitive Personal Information
We may use Sensitive Personal Information for purposes of performing services for our business, providing our products and services, and ensuring the security and integrity of our business, infrastructure, and the individuals we interact with. This includes short-term transient use, such as displaying first-party, non-personalized advertising, order processing and fulfillment, servicing accounts, establishing and maintaining employment relationships, providing customer service, verifying customer information, processing payments, providing financing, and activities relating to quality and safety control or product improvement.
Retention Period
We retain Personal Information, including Sensitive Personal Information, for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria that we use to determine our retention periods include:
- The length of time we have an ongoing relationship with you and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;
- For employees, the duration of your employment and the length of time we have an ongoing relationship with you or your dependents/beneficiaries;
- For job applicants, the duration of the job application process, whether your job application is approved, and whether you want to be notified of future job opportunities;
- Whether there is a legal or regulatory obligation to which we are subject (for example, certain laws require us to keep records of transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Requests Under the CCPA
If you are a California resident, you may, subject to applicable law, make the following requests:
(1) You may request that we disclose to you the following information:
a. the categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
b. the business or commercial purpose for collecting or disclosing Personal Information about you;
c. the specific pieces of Personal Information we collected about you, including a copy of the Personal Information in a portable format;
d. the categories of Personal Information about you that we “shared” (for cross-context behavioral advertising, as defined by the CCPA) and the categories of third parties with which we “shared” such Personal Information; and
e. the categories of Personal Information about you that we disclosed to third parties for a business purpose and the categories of third parties to which we disclosed such Personal Information.
(2) You may request to correct inaccuracies in Personal Information that we maintain about you.
(3) You may request to have Personal Information that we maintain about you deleted.
(4) You may request to opt out of any future “sharing” of your Personal Information for purposes of cross-context behavioral advertising.
You have the right to be free from unlawful discrimination or retaliation for exercising your rights under the CCPA.
How to Make Requests
If you are a California resident, you may make a request for the disclosures described above or make a request to correct or delete your Personal Information by contacting us at:
(1) 1-866-560-9063; or
(2) by providing information through our request form available here.
To request to opt out of any future “sharing” of your Personal Information for purposes of cross-context behavioral advertising, click here.
If you would like an agent to make a request on your behalf where permitted by applicable law, the agent may use the submission methods noted above in this section. As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Requests Under the CCPA” or confirm that you provided the agent permission to submit the request.
Deidentified Information
Where we maintain or use deidentified information, we will continue to maintain and use the deidentified information only in a deidentified fashion and will not attempt to re-identify the information.
Changes to this California Privacy Disclosure
We may change or update this Disclosure from time to time. When we do, we will post the revised Disclosure on this page with a new “Last Updated” date.
Contact Us
For questions concerning this Notice, please contact us by writing to: Privacy Policy c\o Compliance, Dimensional Fund Advisors, 6300 Bee Cave Road, Building One, Austin, TX 78746 or at 1-866-560-9063.
LAST REVIEWED: December 26, 2024