Privacy Policy

Privacy Notice: Your privacy is protected.

This Privacy Policy applies to Ariel Investments, LLC, Ariel Alternatives LLC, Ariel Distributors, LLC, Ariel Investment Trust, Project Black LP, and Ariel International DM/EM LLC, and their affiliates (collectively “Ariel”). Privacy Notices are separately provided to:

• Clients via Ariel Investments’ Privacy Notice (see: Client Privacy Notice in Form ADV, Part 2)
• Subscribers to the Ariel International DM/EM LLC (see Privacy Notice of Ariel International DM/EM LLC)
• Subscribers to Ariel Project Black LP (see Privacy Notice of Project Black LP)
• Employees, applicants, and contractors (see Ariel Investment, LLC’s Privacy Notice for Ariel Employees, Applicants, and Contractors).

Ariel is committed to maintaining the confidentiality of your personal information (“PI”). We do not sell your PI to third parties not associated with our services or business operations and we do not disclose such information except as permitted or required by law, or as described below. Ariel and its service providers and contractors maintain physical, electronic and procedural safeguards to guard your personal information.

Personal Information

We collect PI about: visitors to this site, clients, investors, employees and their families, applicants, service providers, contractors, and third parties.

This PI is collected from: you, your authorized representatives, fiduciaries, subscription agreements, custodian banks, fund administrators, transfer agents, broker/dealers, financial institutions, service providers, contractors, government entities, other third parties, and this website.

The PI collected may be on paper or electronic and may include your name and address, Social Security number or tax identification number, bank information, date of birth, investment activity and goals, account balances, transaction history, phone number, e-mail address, income, assets, citizenship status, and other confidential information.

This information is used by Ariel and third parties associated with our services or authorized by you, or the service providers and contractors we engage to assist us in our operations and service delivery. This may include processing transactions, servicing and maintaining your account, responding to inquiries, developing, evaluating and marketing products and services to you, or fulfilling legal and regulatory requirements. For example, we provide your personal information to the transfer agent that maintains your account records, or to companies for the purposes of printing and mailing your account statements, shareholder reports, and other information about our products and services. We may also disclose information about you at your request (i.e., sending duplicate account statements to someone you designate).

In certain circumstances, we may need to disclose personal information: (i) at your direction; (ii) to provide a client with service that was requested by the client or information about Ariel’s services; (iii) to maintain Ariel’s high standards of performance and compliance, such as by sharing information with our outside professionals; (iv) to ensure the security and integrity of our services and operations or to verify or maintain the quality or safety of our services, (v) to provide advertising and marketing services to our clients and investors, (vi) to debug to identify and repair errors that impair functionality; (vii) to undertake internal research, (viii) to transfer data in the possible event of the merger, sale, reorganization or other transaction involving all or part of Ariel’s business, or associated diligence, (ix) to respond to the requests of government agencies, other regulatory bodies and law enforcement officials, or (x) otherwise as required by law.

Cookies

In order to improve functionality, performance, security, our services, and content delivery, Ariel may gather web-specific information from this site to better serve you. Some cookies, such as security and video cookies, are “third party cookies” from our vendors and are used to make our site more secure and deliver content better to the user. To help us evaluate and develop new online materials or firm services, we may disclose this information to our service providers. Cookies do not identify you by name, account number, or IP address.

Cookies on our website are generally divided into the following categories:

Strictly Necessary Cookies.

These cookies are necessary for the website to function and cannot be refused without impacting the functionality of the website. They are usually generated in response to actions you request. These cookies do not store any personally identifiable information.

Performance Cookies.

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They tell us which pages are visited the most and how visitors use our site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, your visit to the site will not be known or factored into site performance.

Functional Cookies.

These cookies enable the website to provide enhanced or personalized functionality. These cookies may be set by us or by our website providers. If you do not allow these cookies then some or all of the site’s services may not function properly or in a personalized manner.

Analytics and Customization Cookies.

These cookies collect information that is used to help us understand how our services are being used or how effective our marketing campaigns are, or to help us customize our services for you in order to enhance your experience. If you do not allow these cookies, your use of our site will not be included in our analysis and new features.

Targeting Cookies.

These record your visit to our website, the pages you have visited and the links you have followed to recognize you as a previous visitor and to track your activity. If you accept these cookies, they remain on your device for us to use during a next visit to our Sites. You can delete these Cookies via your browser settings.

You can review your Internet browser settings, typically under the sections “Help” or “Internet Options,” to exercise your options for certain Cookies.

A cookie banner will provide you notice of our cookies when you first visit our site. You can Accept All cookies or you can Reject All cookies on the cookie banner.

Children’s Personal Information

Our website is not directed to children under the age of thirteen, and we do not knowingly collect personal information from children under the age of thirteen. If we discover that we inadvertently collected information from a child under the age of thirteen, we will promptly delete it. Ariel and at times collects information on children under the age of thirteen that is provided by their parents, guardians, or other representatives or fiduciaries and associated with a specific account. Ariel does not use any personal information on minors under the age of thirteen for any purpose other than maintaining and servicing the account it is associated with.

Data Subject Rights

If you live in the European Economic Area (“EEA”), or other jurisdictions, including Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, South Korea, Switzerland, and certain other jurisdictions, you may have certain data subject rights. These rights vary, but they may include the right to:

• Request access to, correction of, and deletion of your personal data that we hold;
• Restrict or object to certain processing of your data by us;
• Obtain a copy of their personal data in a portable format and/or request transfer of their personal data to a third party;
• Request the information on the recipients or categories of recipients with whom we share your personal data; and
• Lodge a complaint about the processing of personal data with a data protection authority or agency.

You can make a request to exercise these rights by contacting us by email at [email protected] or by calling +1-800-725-0140. We will review your requests and respond in a timely manner. The rights described herein are not absolute.

You will not have to pay a fee for the disclosure of your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for disclosure is manifestly unfounded or excessive. We will not provide disclosure of your personal data more than twice in any 12-month period.

Individuals who submit requests for access, correction, or erasure of personal information will be required to verify their identity by answering certain questions. We will not take action on a request until such individual’s identity is verified.

You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request. Agents who make requests on behalf of individuals will be required to verify the request by submitting written authorization from the individual. We will not honor any requests from agents until authorization is verified.

California Privacy Rights

Ariel complies with the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”) (“CCPA/CPRA”). If you are a California resident and you are not a current client of Ariel Investments, you can make certain requests regarding your personal information (“PI”). We respond to these requests as required by California law. (Data about current clients is covered under the Gramm-Leach-Bliley Act and SEC Regulation S-P and exempt from the CCPA/CRPA).

For purposes of clarity, under the CPRA, “sell,” “selling,” “sale,” or “sold,” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, an individual’s personal information by the business to a third party for monetary or other valuable consideration. This can include Ariel making your PI available to Ariel affiliates for the purposes of (a) providing the services required for your subscription or requested by you, (b) providing marketing or advertising to you, or (c) ensuring the security, integrity, and safety of our services.

Under the CPRA, “share,” “shared,” or “sharing” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, an individual’s PI by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged. Ariel does not share your data with third parties for cross-context behavioral advertising.

Service providers, contractors, and the Ariel business with whom you intentionally interact that collects PI are not considered to be “third parties” under the CPRA.

Rights Under California Law

You have the right to notice and disclosure at or before the point of collection of (a) the categories of PI and sensitive personal information (“SPI”) collected, (b) the purposes for the collection, (c) whether the PI/SPI is sold or shared, and (d) the length of time it will be retained, or the criteria used to determine the retention period, but Ariel will not retain PI/SPI longer than reasonably necessary for the disclosed purpose. Ariel will not collect additional categories of PI/SPI or use the collected PI/SPI for any purpose incompatible with the purpose for which it was collected, without providing you notice.

You have the right to request that Ariel delete any PI about you which has been collected from you, subject to certain exceptions.

You have the right to request that Ariel correct any inaccurate PI it has about you.

You have the right to request that Ariel disclose to you:

• The categories of PI it has collected about you
• The categories of sources from which the PI was collected
• The business purpose for collecting, selling, or sharing your PI
• The categories of third parties to whom Ariel discloses your PI
• The specific pieces of PI that Ariel has collected about you.

You have the right to know what PI is sold or shared and to whom. You have the right to request that Ariel disclose to you:

• The categories of PI that it has collected about you
• The categories of PI that Ariel has sold or shared about you and the categories of third parties to whom the PI was sold or shared, by category of PI for each category of third party
• The categories of your PI that Ariel disclosed for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

You have the right to opt-out of the sale or sharing of your PI to third parties by directing Ariel not to sell or share your PI.

You have the right to direct Ariel to limit their use of your SPI to (a) that which is necessary to perform the services you requested, (b) that which is necessary to perform an allowed business purpose, or (c) as authorized by regulations. If Ariel uses or discloses your SPI for purposes other than these, we will provide you notice that your SPI may be used or disclosed to a service provider or contractor for additional purposes and you have the right to direct us to limit such use or disclosure of your SPI.

You have the right to exercise these rights without any retaliation or discrimination, such as denying you services, charging you different rates for services, providing a different level of service, or suggesting you will receive a different price or rate for services or different quality of service. This includes an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for exercising CCPA/CPRA rights.

How To Exercise These Rights

You can make requests pursuant to these rights by calling the following toll-free number: +1-800-725-0140 or by submitting a request to Chief Privacy Officer, Ariel Investments LLC, 200 East Randolph Street Suite 2900. Chicago, IL 60601. The interactive form for such requests is at the bottom of this home page for this website. The form also may be emailed to [email protected]. California residents may also designate an authorized agent to make a request for access on their behalf by emailing [email protected].

When California residents exercise these rights and submit a request, Ariel will verify their identity against information we have about you. We may also ask you for certain information (such as name, address, telephone, or email) or to confirm certain information we have about you, such as your account number. Ariel will endeavor to honor individual requests within thirty (30) days, but will notify you if more time is needed. Please note that some requests may conflict with certain lawful exemptions under the CPRA, in which case you will be notified of such. Ariel is only required to honor such requests twice in a twelve (12) month period.

Exercise of these rights will have no adverse effect on the price and quality of Ariel’s services.

Categories of PI Collected

In the past twelve months, Ariel has collected the following categories of PI:

• Identifiers, such as name, postal address, email address, social security number, driver’s license number or similar identifier, account name, unique personal identifier, etc.
• Associated identifiers, such as telephone numbers, signature, bank account number or other financial information, etc., as set forth in CA Civ. Code §1798.81.5.
• Protected classifications of data, such as race, sex/gender, marital status, national origin, age, familial status, etc.
• Commercial information, including records associated with personal property, services or securities purchased/sold, obtained, or considered, or other purchasing or investing histories or tendencies.
• Biometric information.
• Digital identifiers, such as Internet or other electronic network activity information, such as cookies when you access our website.
• Geolocation data.
• Sensory information such as audio, electronic, visual, or similar information.
• Professional or employment-related information.
• Education information which is personal information that is not publicly available.
• Sensitive personal information, such as social security number, driver’s license number, passport number, race or ethnic origin, biometric information, etc.

Categories of Sources from Which PI was Collected

PI was collected from visitors to the Ariel website, clients, investors, employees, subscription agreements, custodian banks, fund administrators, transfer agents, broker/dealers, service providers, contractors, personal representatives, fiduciaries, financial institutions, or other third parties you have authorized to provide us with your PI.

Business Purpose for Collecting and Processing the PI

The business or commercial purposes for the collection, processing, sale, and disclosure of PI are:

• Helping to ensure security and integrity of our services and operations
• Debugging to identify and repair errors that impair the existing intended functionality
• Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, or providing similar services on behalf of the business.
• Providing advertising and marketing services
• Undertaking internal research for technological development or demonstration
• Undertaking activities to verify or maintain the quality or safety of our services and to improve, upgrade, or enhance the service provided or controlled by the business.

Categories of PI Sold or Shared To Third Parties

The following categories of PI may be sold to the following categories of third parties: Ariel affiliates, Ariel Investment Trust, fund administrators, placement agents, transfer agents, custodian banks, broker/dealers, other third parties to whom you have authorized us to provide information, legal representatives of Ariel, marketing and investor relations companies, and regulators or law enforcement as required.

Ariel does not share any PI for cross-context behavioral advertising.

In the preceding twelve months, Ariel has “sold” the following categories of PI to the categories of third parties set forth in the table below.

Categories of Third Parties and the Categories of Personal Information Sold to Each

Categories of PI Sold or Disclosed to a Third Party for a Business Purpose

In the preceding twelve months, Ariel has disclosed for a business purpose the following categories of PI to the categories of third parties set forth in the table below.  Ariel does not sell the personal information of persons under 16 years of age, EXCEPT when such information is disclosed (“sold”) to an Ariel affiliate for purposes of servicing the account or providing client services.

Use and Disclosure of Sensitive Personal Information

Ariel uses and discloses sensitive personal information (SPI) for only the following purposes and such use is reasonably necessary and proportionate for those purposes.

1. To perform the services or provide the goods reasonably expected by an average consumer who requests our services and/or goods. For example, we may use your account information to make an investment for you, settle a trade on your account, or perform other investment advisory services,
2. To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity or confidentiality of stored or transmitted personal information. For example, we may disclose your log-in information to our security experts or forensic investigators to investigate or remediate an incident.
3. To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions. For example, we may use information about you for Anti-Money Laundering (AML) and Know Your Customer (KYC) purposes.
4. To ensure the physical safety of natural persons. For example, we may disclose geolocation information to law enforcement to protect consumers and staff at a particular location that has received a threat.
5. For short-term, transient use, including but not limited to, non-personalized advertising shown as part of your interaction with the business. This information will not be disclosed to another third party and will not be used to build a profile about you or otherwise alter your experience outside the current interaction with Ariel. For example, we might send you a fund report or securities analysis based on your interactions with Ariel.
6. To perform services on behalf of the business. For example, we may use account information to maintain or service accounts, provide customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, or providing similar services on behalf of Ariel Investments and/or its affiliates.
7. To verify or maintain the quality or safety of a product or service that is produced or controlled by the business and to improve, upgrade, or enhance the service or product. For example, we may use your account data to perform research on investments or analysis of performance of assets.
8. To collect or process sensitive personal information where such collection or processing is not for the purpose of interring characteristics about a client. For example, we may use the contents of an email from you to process a data subject request or to gather aggregated statistics on the frequency of a particular request or issue.

Since Ariel’s use of SPI is limited to the above uses and disclosures, Ariel is not required to post a Notice of Right to Limit or provide a method for submitting a request to limit the use of SPI.

Shine the Light

If you are a California resident, as defined in Section 17014 of Title 18 of the California Code of Regulations, the following additional disclosures apply to any personal data that we process subject to the CCPA/CPRA.

California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year.

Contact Us

If you have any questions, comments, requests or concerns about this Privacy Notice or other privacy-related matters, please contact us at:

Ariel Investments
Attention: Legal & Compliance
200 East Randolph Street
Suite 2900
Chicago, IL 60601

Main Phone: 312-726-0140
Toll Free: 800-725-0140

[email protected]

Updates to the Privacy Notice

Although most changes are likely to be minor, this Privacy Notice may be changed to keep it aligned with business operations.

This Privacy Notice was last updated December 31, 2022.