Winslow Capital Management, LLC Notice of Privacy Practices

Winslow Capital Management, LLC respects your right to privacy. We also know that you expect us to conduct and process your business in an accurate and efficient manner. In the course of doing so, we must collect and maintain certain personal information about you.

Where we get the information.

The information we collect about you comes primarily from the applications and other forms that we ask you to complete and the transactions that you make with us and others. This includes, but is not limited to, your personal information such as:

  • Identifiers (e.g., name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
  • Categories of Personal Information in California Civil Code Section 1798.80;
  • Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
  • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement);
  • Geolocation data;
  • Professional or employment-related information (e.g., job application or resume information, past and current job history, and job performance information);
  • Inferences drawn from Personal Information (e.g., consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes).

We also may receive information about you from other companies who provide services to you.
We and other third parties may collect personally identifiable information about your online activities over time and across different websites when you use our website or services.

To whom we disclose the information.

We do not sell or disclose any nonpublic personal information about you or any of our former clients to any third parties, except as required or permitted by law. We may, however, disclose information about you and former clients to other companies where it is necessary to effect transactions or provide other services to you, or where you request or authorize that we do so. If you decide at some point to close your account(s), we will continue to adhere to the privacy policies and practices described in this notice.

Protecting the information.

To protect information about you, we restrict access to nonpublic personal information to those employees and authorized agents who need to know the information in order to provide services to you. Be assured that we maintain physical, electronic and procedural safeguards to maintain the confidentiality of the nonpublic personal information that we have.

Do Not Track Signals.

Our website responds to browser “Do Not Track” signals.

Changes to the Notice.

We reserve the right to change this Notice at any time without notice to you. Unless otherwise stated, any modifications to this Notice will go into immediate effect after they have been posted, as indicated by the “Last Updated” date located at the end of this Notice. Your continued use of this website indicates your consent to the Notice posted at the time of use.


If you have any questions about how we protect and safeguard nonpublic personal information, please call our Managing Director, CCO and Chief Legal Officer at (612) 376-9100.

For residents of California, please visit the following link:

For residents of EU / UK, please visit the following link:

For individuals located in Brazil, please visit the following link:

For information on our use of data in accordance with the Data Protection Law of the Cayman Islands, please visit the following link for more information:

Last Updated: March 23, 2022