Victory Capital recognizes the importance of protecting your personal and financial information. In the course of doing business with Victory Capital, you share personal and financial information with us. We treat this information as confidential and recognize the importance of protecting unauthorized access to it. We do not share personal information about you with unaffiliated third parties for their use in marketing their products and services. In addition, we do not sell personal information about you and have not done so at any time during the preceding 12-months. Please read Victory Capital’s Privacy Policy for more details around data sharing for everyday business purposes and your ability to limit data sharing.

The CCPA gives certain rights to California residents and imposes certain obligations on those businesses that are subject to the CCPA. Depending on the Victory Capital entity in which you have a relationship, some or all of the personal information that the firm collects or maintains is covered by one or more of the exemptions described below. As a result, in most cases, Victory Capital may have no obligation under the CCPA to accept any CCPA requests, and in other cases, it may have no obligation to honor a particular CCPA request, because of the nature of the personal information that Victory Capital collects or maintains. To submit a verifiable Delete, Copy or Right to Know request, please email us at privacy@vcm.com, or call +1 (877) 660-4400 (toll free).

Please note that certain types of personal information collected or maintained by a covered business, such as Victory Capital, are exempt from the CCPA. For example, a covered business has limited obligations, or in some cases no obligations, under the CCPA with regard to the following types of personal information:

• Personal information collected, processed, sold, or disclosed pursuant to the federal Gramm–Leach–Bliley Act (GLBA) and implementing regulations, or pursuant to the California Financial Information Privacy Act;
• Medical information governed by the Confidentiality of Medical Information Act or protected health information that is collected by a covered entity or business associate governed by the privacy, security, and breach notification rules issued by the United States Department of Health and Human Services, established pursuant to the Health Insurance Portability and Accountability Act of 1996 and the Health Information Technology for Economic and Clinical Health Act;
• Personal information collected from a job applicant, employee, owner, director, staff member, officer, or contractor of a covered business when the information is used by the covered business within the person’s role as a job applicant, employee, owner, director, staff member, officer, or contractor of the covered business; or
• Personal information about an employee, owner, director, officer, or contractor of another business that is collected by the covered business in connection with due diligence activities regarding the other business, or in connection with the covered business providing a product or service to or receiving a product or service from the other business.

In addition, under the CCPA, there are a number of situations where a covered business may refuse to honor a CCPA request to delete a consumer’s personal information and is allowed to continue to maintain the consumer’s personal information. Some examples include situations where retention of the personal information is necessary to:

• Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer or reasonably anticipated within the context of the covered business’s ongoing business relationship with the consumer, or otherwise perform a contract between the covered business and the consumer;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;
• Exercise free speech or another right provided for by law;
• Enable internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the covered business;
• Comply with a legal obligation; or
• Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

Furthermore, since Victory Capital does not sell personal information, we do not have any obligation under the CCPA to accept CCPA requests requesting that the company not sell a consumer’s personal information.

If you have additional questions around data privacy, please contact Victory Capital at privacy@vcm.com and provide your contact information and we will get back to you as soon as possible. If you have other account-related questions, please select the appropriate account type below: