myDigital Workplace Privacy Notice

Last Modified: August 12, 2024

T. Rowe Price Associates, Inc., T. Rowe Price Australia Limited, T. Rowe Price Hong Kong Limited, T. Rowe Price Investment Consulting (Shanghai) Co., Ltd., T. Rowe Price Japan, Inc., T. Rowe Price Singapore Private Ltd.,   T. Rowe Price International Ltd, and T. Rowe Price (Luxembourg) Management Sàrl,(“Company,” or “we” or “us”) respects the privacy of our employees, contractors, consultants, interns, and other workers (collectively, “workers”). This Data Privacy Notice (“Notice”) applies to those individuals whose personal information we may collect and process during and following the individual’s use of the myDigital Workplace Application (the “Application”)^[1]. If you do not agree with our policies and practices as described herein, do not download, or use the Application.

The Application may contain links to other websites/applications and other websites/applications may reference or link to the Application. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own discretion.

Personal Information We May Collect About You

Through your use of the Application, we may collect the following personal information from or about you:

• Identifying information, such as your first name, last name, login and authentication details, and employee ID;
• Contact information, such as your email address, if you have shared it through your Workday preferences;
• Communications with us, such as questions relating to your use of the Application;
• Device information, such as IP address, device ID, and other similar identifiers;
• Online and technical information such as the number of logins, crash analytics;
• Location, if you have enabled it through your mobile device settings; 
• Employment details, such as primary work location (city of office), division, building location (e.g. OM Corporate Campus 3), floor of building location.

Our Use of Your Personal Information

We may use your personal information to:

• Provide core functionality for the Application, including:
  • Allowing colleagues to search for and view your professional profile;
  • Enabling colleagues to contact you via company-approved communications channels such Teams chat; 
  • Displaying news, events, announcements and program information most relevant to your work location and role to support you on your employee journey;
• Support application functionality, including review of application crash data and logs;
• Comply with legal and regulatory obligations, including all uses, disclosures, and retention of personal information that are required or permitted by law or reasonably needed for compliance with company policies and procedures.
• Understand usage of the Application by capturing and analyzing analytical data including number of downloads usage by device type (Android vs iOS), space types booking statistics, app pages utilization, average time session per user and active users

Our Sharing of Your Personal Information

We may share your personal information as set forth below:

• T. Rowe Price’s family of companies. As the T. Rowe Price entity that you work for is part of a wider group of companies with headquarters in the U.S. and offices located across the globe (which all partially share management, IT, human resources, legal, compliance, finance and audit responsibility), we may share your personal data among our family of companies, including our subsidiaries and affiliates, in order to process your application and conduct the other activities described in this Notice.
• Other parties permitted by law. In certain circumstances, we may be required to disclose your personal information to comply with a legal or regulatory obligation (for example, we may be required to disclose personal information to the police, regulators, government agencies, or judicial or administrative authorities). We may also disclose your personal information to other parties where disclosure is both legally permissible and necessary to protect or defend our rights, matters of national security, law enforcement, or to enforce our agreements or protect your rights or those of the public.
• APIs. We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of the Application. 

Children's Data

The Application is not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at .

Data Security

We use reasonable administrative, technical and physical security to protect the personal information we retain and to help ensure that it is used in accordance with this Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure. 

Data Retention

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Notice unless longer retention is required by law, for auditing purposes, or for litigation purposes.

Updating Your Personal Information

We strive to keep information contained in our records accurate and up to date. If your personal information changes during your employment, please keep us informed of such changes by updating your Workday Profile.

Where We Store Your Personal Data 

The personal data that we collect from you may be transferred to, and stored at, a destination outside the jurisdiction in which you are located. If you are located in the European Economic Area (“EEA”) or the UK, this means that the personal data may be transferred to, stored at and accessed from a destination outside where you are located, including to  T. Rowe Price Associates, Inc., in the United States (U.S.). It may also be processed by staff operating outside where you are located and who work for us, an affiliate or for one of our Service Providers. If you are located outside the EEA or UK, then in addition to the above, this means that personal data may be transferred to, and stored at, a destination in the EEA or UK. 

For transfers to T. Rowe Price entities outside the EEA or UK, T. Rowe Price will be bound by the EU Standard Data Protection Clauses (pursuant to Article 46(2)(c) General Data Protection Regulation or “GDPR”), which the European Commission has assessed as providing an adequate level of protection for personal data, or other appropriate safeguards, to ensure that your data is protected adequately. (The EU Standard Data Protection Clauses are recognized under applicable UK law as appropriate to safeguard transfers of personal data to T. Rowe Price entities outside of the UK or EEA.) You can ask for a copy of our appropriate safeguards by contacting us. 

Supplemental Notice for Residents Outside the United States

You have various rights in connection with our processing of your personal data, each of which is explained below. If you wish to exercise one or more of the below rights, please contacting us, and include your name, email and postal address as well as your specific request and any other information we may need in order to provide or otherwise process your request. 

• Access. You may have the right to confirm with us whether your personal data are processed and, if they are, to request access to that personal data, including the categories of personal data processed, the purpose of the processing and the recipients or categories of recipients. We do have to take into account the interests of others, though, so this is not an absolute right, and if you want to request more than one copy, we may charge a fee. 
• Rectification. You may have the right to rectify inaccurate or incomplete personal data concerning you. In addition, where you have used an online portal to load your personal data, and where there is functionality that allows you to do so, you may access, review and update your personal data directly. 
• Deletion. You may have the right to ask us to erase personal data concerning you, except that we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims. 
• Restriction. In limited circumstances, you may have the right to request that we restrict processing of your personal data. This may apply where you believe such data to be inaccurate, that our processing is unlawful or that we no longer need to process such data for a particular purpose (but where we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it). In such case, we would mark stored personal data with the aim of limiting particular processing for particular purposes in accordance with your request or otherwise restrict its processing. 
• Portability. You may have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, and you may have the right to transmit that data to another entity. 
• Objection. Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling (profiling is not a standard practice, so when applicable), by us, and we can be required to no longer process your personal data. This may include requesting human intervention in relation to an automated decision (when applicable) so that you can express your view and contest the decision. 
• Make a Complaint. You also have the right to lodge a complaint with the competent data protection supervisory authority, which in Luxembourg is the Commission Nationale pour la Protection des Données (the “CNPD”) or in the UK is the Information Commissioner's Office (the “ICO”). If you are based in, or the issue you would like to complain about relates to, any other location, please contact us.

 

Supplemental Notice for California Residents

Individual rights requests

What they are:

• Right to know and access personal information we have about you. You may have the right to confirm with us whether your personal information is processed and, if it is, to request access to that personal information, including the categories of personal information processed, the purpose of the processing, and the recipients or categories of recipients. We do have to consider the interests of others though, so this is not an absolute right and there are additional exceptions under the CCPA. Also, we are not obligated to respond to more than two access requests for the same individual’s personal information within a 12-month period.
• Right to request deletion of personal information we have about you. You may have the right to ask us to erase personal information concerning you, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise, or defend legal claims or under other exceptions under the CCPA.
• Right to correct personal information we have about you. You may have the right to ask us to correct inaccurate personal information that we maintain about you. If you are a current T. Rowe Price employee, you can always access and update key aspects of your personal information by using the tools available on Workday.

How to make your own privacy rights request: To exercise one or more of these rights, please contact us as explained below. Please note that we may need to verify your identity before we can fulfill your request.

• Use the online form at troweprice.com/CCPA
• Call us at 1-877 HR SERVE (1-877-477-3783)
• Email us at benefits@troweprice.com

How your authorized agent can make a request for you: A request also may be made by someone else you authorize specifically to make such a request under the CCPA or by someone you have named as your agent under a power of attorney that is valid under the California Probate Code. Click here for authorized agent instructions and appropriate forms.

How we handle requests we receive: If we need additional information to verify your identity, we will let you know. We will endeavor to respond to a verified request no later than 45 days after receipt, unless there are grounds for extending our response time frame by up to an additional 45 days. In the event of an extension, we will explain to you why the extension is necessary. In some cases, your ability to know/access, delete, or correct your personal information will be limited, as required or permitted by applicable law, even when the CCPA applies to the personal information we have for you. If we cannot fulfill your request because we cannot verify your identity or due to exceptions under the CCPA (or when the CCPA does not apply to the personal information), we’ll let you know in our response.

Sale/share of personal information: We do not sell or share personal information collected in the Application. 

Changes to this Notice

We may revise this Notice from time to time in our sole discretion. If there are any material changes to this Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Notice if you continue to use our Services after the new Notice takes effect.

Contact Us

If you have questions regarding this Notice or our data privacy practices, please contact us by emailing us at Global.Privacy@troweprice.com. 

^[1] As an employee, contractor, consultant, intern, or other worker, you may be subject to other Privacy Notices that more broadly govern what types of personal information we collect, how we use it, who we share it with, and how we protect it outside the scope of the MyDigital Workplace Application.