ALLIANZ GLOBAL INVESTORS
Amended and Restated Privacy Policy and Procedures
Fixed Income Shares
Allianz Global Investors Fund Management Sponsored Closed-End Funds
Premier VIT
Allianz Funds [1]
The Funds [2] consider customer privacy to be a fundamental aspect of their relationships with shareholders and are committed to maintaining the confidentiality, integrity and security of their current, prospective and former shareholders’ personal information. To ensure their shareholders’ privacy, the Funds have developed policies that are designed to protect this confidentiality, while allowing shareholder needs to be served.
Obtaining Personal Information
In the course of providing shareholders with products and services, the Funds and certain services providers to the Funds, such as the Funds’ investment advisers (“Advisers”), may obtain non-public personal information about shareholders, which may come from sources such as account applications and other forms, from other written, electronic or verbal correspondence, from shareholder transactions, from a shareholder’s brokerage or financial advisory firm, financial adviser or consultant, and/or from information captured on the Funds’ internet web sites.
Respecting Your Privacy
As a matter of policy, the Funds do not disclose any personal or account information provided by shareholders or gathered by the Funds to non-affiliated third parties, except as required or permitted by law or as necessary for such third parties to perform their agreements with respect to the Funds. As is common in the industry, non-affiliated companies may from time to time be used to provide certain services, such as preparing and mailing prospectuses, reports, account statements and other information, conducting research on shareholder satisfaction and gathering shareholder proxies. A Fund’s Distributor may also retain non-affiliated companies to market the Trust’s shares or products which use the Trust’s shares and enter into joint marketing agreements with other companies. These companies may have access to a shareholder’s personal and account information, but are permitted to use this information solely to provide the specific service or as otherwise permitted by law. In most cases, the shareholders will be clients of a third party, but the Funds may also provide a shareholder’s personal and account information to the shareholder’s respective brokerage or financial advisory firm.
Sharing Information with Third Parties
The Funds reserve the right to disclose or report personal information to non-affiliated third parties, in limited circumstances, where the Funds believe in good faith that disclosure is required under law to cooperate with regulators or law enforcement authorities, to protect their rights or property or upon reasonable request by any Fund in which a shareholder has chosen to invest. In addition, the Funds may disclose information about a shareholder’s accounts to a non-affiliated third party with the consent of the shareholder.
Sharing Information with Affiliates
The Funds may share shareholder information with their affiliates in connection with servicing their shareholders’ accounts or to provide shareholders with information about products and services that the Funds or their Advisers, principal underwriters or their affiliates (“Service Affiliates”) believe may be of interest to such shareholders. The information that the Funds share may include, for example, a shareholder’s participation in one of the Funds or in other investment programs sponsored by a Service Affiliate, a shareholder’s ownership of certain types of accounts (such as IRAs), or other data about a shareholder’s accounts. The Funds’ Service Affiliates, in turn, are not permitted to share shareholder information with non-affiliated entities, except as required or permitted by law.
Procedures to Safeguard Private Information
The Funds take seriously the obligation to safeguard shareholder non-public personal information. In addition to this policy, the Funds have also implemented procedures that are designed to restrict access to a shareholder’s non-public personal information only to internal personnel who need to know that information in order to provide products or services to such shareholders. In order to guard a shareholder’s non-public personal information, physical, electronic and procedural safeguards are in place.
Privacy Policy
PIMCO Funds
PIMCO Variable Insurance Trust ("PVIT")
PIMCO Commercial Mortgage Securities Trust, Inc. (“PCM”)
PIMCO Strategic Global Government Fund, Inc. (“RCS”)
(collectively, the “Funds”)
The Funds[1] consider customer privacy to be a fundamental aspect of their relationships with shareholders and are committed to maintaining the confidentiality, integrity and security of their current, prospective and former shareholders’ personal information. To ensure their shareholders’ privacy, the Funds have developed policies that are designed to protect this confidentiality, while allowing shareholder needs to be served.
Obtaining Personal Information
In the course of providing shareholders with products and services, the Funds and certain services providers to the Funds, such as the Funds’ investment advisers (“Advisers”), may obtain non-public personal information about shareholders, which may come from sources such as account applications and other forms, from other written, electronic or verbal correspondence, from shareholder transactions, from a shareholder’s brokerage or financial advisory firm, financial adviser or consultant, and/or from information captured on the Funds’ internet web sites.
Respecting Your Privacy
As a matter of policy, the Funds do not disclose any personal or account information provided by shareholders or gathered by the Funds to non-affiliated third parties, except as required or permitted by law or as necessary for such third parties to perform their agreements with respect to the Funds. As is common in the industry, non-affiliated companies may from time to time be used to provide certain services, such as preparing and mailing prospectuses, reports, account statements and other information, conducting research on shareholder satisfaction and gathering shareholder proxies. A Fund’s Distributor may also retain non-affiliated companies to market the Fund’s shares or products which use the Fund’s shares and enter into joint marketing agreements with other companies. These companies may have access to a shareholder’s personal and account information, but are permitted to use this information solely to provide the specific service or as otherwise permitted by law. In most cases, the shareholders will be clients of a third party, but the Funds may also provide a shareholder’s personal and account information to the shareholder’s respective brokerage or financial advisory firm.
Sharing Information with Third Parties
The Funds reserve the right to disclose or report personal information to non-affiliated third parties, in limited circumstances, where the Funds believe in good faith that disclosure is required under law to cooperate with regulators or law enforcement authorities, to protect their rights or property or upon reasonable request by any Fund in which a shareholder has chosen to invest. In addition, the Funds may disclose information about a shareholder’s accounts to a non-affiliated third party with the consent of the shareholder.
Sharing Information with Affiliates
The Funds may share shareholder information with their affiliates in connection with servicing their shareholders’ accounts or to provide shareholders with information about products and services that the Funds or their Advisers, principal underwriters or their affiliates (“Service Affiliates”) believe may be of interest to such shareholders. The information that the Funds share may include, for example, a shareholder’s participation in one of the Funds or in other investment programs sponsored by a Service Affiliate, a shareholder’s ownership of certain types of accounts (such as IRAs), or other data about a shareholder’s accounts. The Funds’ Service Affiliates, in turn, are not permitted to share shareholder information with non-affiliated entities, except as required or permitted by law.
Procedures to Safeguard Private Information
The Funds take seriously the obligation to safeguard shareholder non-public personal information. In addition to this policy, the Funds have also implemented procedures that are designed to restrict access to a shareholder’s non-public personal information only to internal personnel who need to know that information in order to provide products or services to such shareholders. In order to guard a shareholder’s non-public personal information, physical, electronic and procedural safeguards are in place.
History of Amendments
History of adoptions and amendments
Adopted: September 29, 2004
Effective: October 5, 2004
Amended: October 8, 2004 (immaterial change)
Amended: October 13, 2004 (immaterial change)
Amended: December 30, 2004 (immaterial change)
Amended: April 1, 2005 (immaterial change)
Amended: September 28, 2005 (ratification on November 8, 2005)
Allianz Global Investors Managed Accounts
Privacy Policy
Allianz Global Investors Managed Accounts considers customer privacy to be a fundamental aspect of its relationship with clients and is committed to maintaining the confidentiality, integrity and security of its current, prospective and former clients’ personal information. To ensure a client’s privacy, Allianz Global Investors Managed Accounts has developed policies that are designed to protect this confidentiality, while allowing client needs to be served.
Obtaining Personal Information
In the course of providing clients with products and services, Allianz Global Investors Managed Accounts may obtain non-public personal information about clients which may come from sources such as account applications and other forms, from other written, electronic or verbal correspondence, from client transactions, from a client’s brokerage or financial advisory firm, financial adviser or consultant, and/or from information captured on its internet web sites.
Respecting Your Privacy
As a matter of policy, Allianz Global Investors Managed Accounts does not disclose any personal or account information provided by clients or gathered by Allianz Global Investors Managed Accounts to non-affiliated third parties, except as required or permitted by law. As is common in the industry, non-affiliated companies may from time to time be used to provide certain services, such as preparing and mailing prospectuses, reports, account statements and other information, conducting research on client satisfaction and gathering shareholder proxies. Allianz Global Investors Managed Accounts may also retain non-affiliated companies to market its products and enter in joint marketing agreements with other companies. These companies may have access to a client’s personal and account information, but are solely permitted to use this information to provide the specific service or as otherwise permitted by law. Allianz Global Investors Managed Accounts may also provide a client’s personal and account information to a client’s respective brokerage or financial advisory firm, Custodian, and/or to a client’s financial adviser or consultant.
Sharing Information with Third Parties
Allianz Global Investors Managed Accounts reserves the right to disclose or report personal information to non-affiliated third parties, in limited circumstances, where it believes in good faith that disclosure is required under law to cooperate with regulators or law enforcement authorities, to protect its rights or property or upon reasonable request by any mutual fund in which a client has chosen to invest. In addition, Allianz Global Investors Managed Accounts may disclose information about a client or a client’s accounts to a non-affiliated third party only if Allianz Global Investors Managed Accounts receives a client’s written request or consent.
Sharing Information with Affiliates
Allianz Global Investors Managed Accounts may share client information with its affiliates in connection with servicing a client’s account or to provide a client with information about products and services that Allianz Global Investors Managed Accounts believes may be of interest to them. The information Allianz Global Investors Managed Accounts shares may include, for example, a client’s participation in its mutual funds or other investment programs, a client’s ownership of certain types of accounts (such as IRAs), or other data about a client’s accounts. Allianz Global Investors Managed Accounts’ affiliates, in turn, are not permitted to share client information with non-affiliated entities, except as required or permitted by law.
Procedures to Safeguard Private Information
Allianz Global Investors Managed Accounts takes seriously its obligation to safeguard client non-public personal information. In addition to this policy, Allianz Global Investors Managed Accounts has also implemented procedures that are designed to restrict access to a client’s non-public personal information only to internal personnel who need to know that information in order to provide products or services to such clients. In addition, Allianz Global Investors Managed Accounts has physical, electronic, and procedural safeguards in place to guard a client’s non-public personal information.
Disposal of Confidential Records
Allianz Global Investors Managed Accounts will dispose of records that are knowingly derived from a consumer reporting agency regarding a client that is an individual in a manner that ensures the confidentiality of the data is maintained. Such records include, among other things, copies of consumer reports and notes of conversations with individuals at consumer reporting agencies.
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