Dodge & Cox Privacy Policy

Dodge & Cox is an investment manager for individuals and institutions. This Privacy Policy describes how Dodge & Cox collects, uses, discloses, and otherwise processes personal information from individuals who visit our websites or otherwise interact with us, both online and offline.

Additional Privacy Notices We Provide

• Financial Privacy Notice, which describes how we handle the personal information of individuals who engage in their personal or household capacity with Dodge & Cox to obtain financial products or services.
• Notice for California Residents, which describes how we handle the personal information of California residents who are employees or other representatives of institutional investors, clients, or prospective institutional investors or clients.

To the extent there are any inconsistencies between this Privacy Policy, the Financial Privacy Notice, and the Notice for California Residents, the Financial Privacy Notice and the Notice for California Residents will prevail with respect to the personal information of individuals to whom those notices apply.

Personal Information We Collect

Personal information you provide:

• Contact and account details such as your first and last name, organization name (if applicable), address, email, and phone number.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with those communications.
• Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.

Information we obtain from other sources: We may maintain pages on social media platforms, such as LinkedIn. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.

Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our website, our communications and other online services, such as:

• Device data, such as your computer’s or mobile device’s operating system, manufacturer and model, browser type, IP address, unique identifiers, language settings, mobile device carrier, and general location information such as city, state, or geographic area.
• Online activity and usage data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our marketing emails or clicked links within them.

We use the following technologies for automatic data collection:

• Cookies are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns.
• Local storage technologies, like HTML5, provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

Third party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Social media companies such as LinkedIn when you interact with our profiles on those services.
• Other sources, such as financial advisers, consumer reporting agencies, consultants, and custodians. 

How We Use Personal Information

To provide our services. This includes:

• Administering your account;
• Hosting, and operating our website and our services;
• Communicating with you and responding to any inquiries you may have; and
• Analyzing your use of our services to allow us to evaluate and improve the services.

For research, development, benchmarking, and improving our services. We may use personal information to analyze and improve the services, identify trends, and operate and expand our business activities. We may also create aggregated, anonymized, or other de-identified statistics, which we may use for lawful business purposes, including for analytics, forecasting, and strategic planning.

For marketing. We may send you direct marketing communications, including, but not limited to, sending newsletters or publications, and notifying you of promotions, offers and events via postal mail, email, telephone, text message, and other means.

For compliance and protection, including to enforce any applicable terms and conditions, comply with legal obligations, defend against legal claims or disputes, protect the security and integrity of our services, and identify and investigate fraudulent, harmful, unauthorized, unethical or illegal activity.

How We Disclose Personal Information

We do not “sell” or “share” personal information as defined by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CCPA”).

We may disclose personal information to:

• Dodge & Cox affiliates, for purposes consistent with this Privacy Notice.
• Third party service providers, that provide services on our behalf or help us operate our website (such as customer support, transfer agents, custodians, email delivery, marketing, identity verification, fraud detection, and database management).
• Professional advisors, such as lawyers, bankers, accountants, auditors, and insurers, where necessary in the course of the professional services that they render to us.
• Law enforcement, government authorities, and private parties, as required by law, legal process, or for compliance and protection purposes described above.
• Other third parties to which you or your agents authorize or require us to disclose your information.

We may also disclose personal information in connection with any divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or bankruptcy or dissolution in relation to our business. 

Your Rights and Choices

Unsubscribe from direct marketing communications. You may opt out of marketing-related communications by following the opt out or unsubscribe instructions contained in the marketing communication we send you or by contacting us using the details in the Contact us section below.

Personal information requests. Depending on your location and the personal information processed, you may make certain requests in relation to the personal information that we control. Please note that this section does not apply to Nonpublic Personal Information (“NPI”), the processing of which is governed by the Gramm-Leach-Bliley Act.

If required under applicable law, you may request the following in relation to your personal information:

• Information about how we have collected and used your personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
• Access to a copy of the personal information that we have hold about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
• Correction of personal information that is inaccurate or out of date.
• Deletion of personal information that we no longer need to provide our online services or for other lawful purposes.
• Additional rights, such as to object to and request that we restrict our use of your personal information, and where applicable, you may withdraw your consent.

To make a request, please email us at privacy@dodgeandcox.com. We may ask for specific information from you to help us confirm your identity. Depending on your jurisdiction, you may be entitled to empower an “authorized agent” to submit requests on their behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

Limits on your choices. Your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided above.

Complaints. If you are based in certain jurisdictions, you may lodge a complaint about how we handle your personal information with a supervisory authority, including in your country of residence, place of work, or where you believe an incident took place.

Online tracking opt-out. You may also limit online tracking by:

• Blocking cookies in your browser. Most browsers let you remove or reject third-party cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
• Using privacy plug-ins or browsers. You can block our websites from setting third-party cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout. 

Note that because these opt out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Please note that some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit www.allaboutdnt.com.

Job Applicants

When you visit the Careers portion of the website, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use applicants’ personal information to facilitate our recruitment activities and process employment applications, such as evaluating a job candidate for an employment activity, monitoring recruitment statistics, and responding to surveys. We may also use this information to provide improved administration of the services, and as otherwise necessary (a) to comply with relevant laws or to respond to subpoenas or warrants served on us; (b) to protect and defend our or others’ rights or property; (c) in connection with a legal investigation; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms and Conditions of Use.

Retention of Personal Information

We retain personal information as necessary to fulfil the purposes for which it was collected and processed, in accordance with our policies and with applicable laws, based on factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, and the purposes for which we use personal information. 

Security Practices

We use reasonable organizational, technical, and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration, and destruction of personal information. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information. 

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Please review this Privacy Policy for any changes. Changes to this Privacy Policy are effective when they are posted on this page. 

Contact Us

If you have any questions, comments or complaints about this Privacy Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please contact us by email at privacy@dodgeandcox.com or write to us at:

Dodge & Cox
555 California Street
40^th Floor
San Francisco, California 94104