Last Updated: 06/06/2022
- Scope and Key Terms
- The Types and Categories of Personal Information We Collect
|Personal Identifiers||Contact data, such as your name, residential/postal address, email address, telephone number, fax number.|
|Registration Data||Information provided when you register for an account to use the Site or Services, including usernames and passwords.|
|Protected Data||Information that is sensitive or otherwise protected by federal or state law, including your nationality, place and date of birth, social security number, and passport number.|
|Online Identifiers (see “Technical Data” below)||Persistent identifiers that can be used to recognize a device accessing our Site over time and across different Services, including a device identifier, an Internet Protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifiers, and similar technology.|
|Commercial Information||Records of the Services you purchased, obtained, or considered, or your other purchasing or consuming histories or tendencies with respect to our Services.|
|Business Contact Data||Information related to employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we conduct, or possibly conduct, business activities.|
|Corporate Information||Information about your organization, including tax information, bank account details, source of funds, and details related to your investment activities.|
|Marketing and Communications Data||Information with respect to your marketing preferences and your subscriptions to our publications, blogs, demos, and alerts.|
|Internet and Electronic Network Data||Data pertaining to your access to or use of the Site, including browsing history, search history, and information regarding your interaction with the Site or advertisements embedded on the Site or other third-party websites.|
|Feedback||Information and communications you provide about our Site, Services or business, which may include data gathered from the surveys or reviews you submit to us.|
|Geolocation Data||Information about the general city, state, or region in which a user of the Site is located.|
|Employment Data (see “Talent Management” below)||If you apply for a job with Company, we collect information set forth in a résumé, curriculum vitae, cover letter, and similar documentation, including contact details, employment history, skills, or qualifications, education level, job compensation and benefit preferences, criminal record, credit history and similar data, and information provided about or by your references.|
|Inferences||Inferences drawn from some of the personal information categories identified herein and used to create a consumer profile reflecting your purchasing and marketing preferences, characteristics, and behavior.|
- Technical Data
When you access the Site, we collect certain data automatically, using technical means and tools. This data relates to your device and your experience on the Site and other websites, including the following:
Usage and Device Data. When you access and use the Site, we automatically collect details of your access to and use of the Site, including traffic data, usage logs and other communication data, and the resources that you access and use on or through the Site (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. The Site may collect “diagnostic” data related to your use of the Site, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.
- Sources of Information
We collect the personal information identified herein directly from you when you use our Services, through automated means when you are using the Site, and from third parties. Specifically, we collect personal information from the following sources:
First Party / Direct Collection. We collect personal information directly from you when you use our Services (e.g., account registration, completing application forms, signing-up to receive marketing), or whenever you directly engage with us, such as when you visit our offices or premises, call us directly or otherwise contact us.
Automated Collection. As described above, we may collect information and data, such as usage data and cookies, through automated means when you use the Site (see “Technical Data” above).
Third-Party Sources. We collect personal information from third parties, such as publicly available databases, social networking providers, advertising companies, our service providers, and third-party references. Investment professionals provide us personal information on their clients, investors, and similar individuals.
- How We Use your Information / Purpose of Collection
We may use the personal information we collect about you in order to perform our Services, comply with our legal obligations, and promote our business interests, including to (i) provide, operate, maintain, improve, and promote our Sites and Services, (ii) enable you to access and use our Site and Services, (iii) process and complete transactions, and send you related information, including invoices, (iv) send transactional messages and provide customer support, (v) furnish technical notices, updates, security alerts, and support and administrative messages to you, (vi) provide you promotional and marketing communications (e.g., information about our Services, features, surveys, newsletters), (vii) monitor and analyze trends, usage, and activities in connection with our Services to promote our business interests (e.g., marketing), (viii) investigate and prevent fraudulent transactions, unauthorized access to or use of our Services, and other illegal activities, and (ix) personalize our Services, including providing features or advertisements that match your interests and preferences. Notwithstanding the foregoing, we may collect and use your personal information for any other purpose for which we obtain your consent.
- Sharing Information / Third-Party Disclosures
We may share your personal information with certain organizations and third parties in accordance with applicable law, including as set out below:
Intra-Group Sharing. We may, from time to time, share personal information with our affiliates and subsidiaries in order to provide or improve our Services, or support our business operations (e.g., in a role of a service provider).
Mutual Business Partners. As part of our Services, we share personal information with third-party organizations that are providing a common or related financial service directly to you.
Service Providers. In order to provide our Services, we share personal information with companies that provide services on our behalf, such as hosting and analyzing the Site, conducting surveys and marketing on our behalf, processing transactions (including financial transactions), tracking and responding to questions or complaints, and performing analyses to improve the quality of our Services.
Business Restructuring. Circumstances may arise where, for strategic or other business reasons, Company decides to sell, buy, divest, merge or otherwise reorganize our businesses. We may disclose your personal information to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of Company’s assets.
Legal and Compliance. We may disclose personal information (i) if required by law or a government order, or to comply with a legal process, (ii) to protect and defend our rights or property, or (iii) in urgent circumstances, to protect the health and personal safety of any individual. In addition, we may disclose your personal information with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, or business interests. We may also disclose your information upon your express consent.
In the event that you facilitate a transaction with Company, or request information from or otherwise engage with us, and such activities require Company to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct Company to intentionally disclose your personal information to the service provider or third party.
- Social Media
Like many organizations, Company has a presence on various social media platforms (e.g., Facebook, Twitter, Pinterest, Instagram). If you contact us on a social media platform using a direct message tool therein, we may respond to you in the same manner. Any use of a social media platform is also subject to the policies and terms of the relevant social media platform. Certain social media platforms may also automatically provide us with personal information, and the information we receive will depend on the terms that govern your use of the social media platform and any applicable privacy settings. The Site may include social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button) or interactive mini-programs that run on the Site. These features may collect IP addresses and which Site webpage you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly by us on the Site.
- Links to Other Websites; Your Direct Third-Party Disclosures
- Data Transfers and Standard Contractual Clauses
Company is based in the United States, and the Site and Services may only be used by individuals who are located in the United States. Please be aware that your personal information may be accessible by, or otherwise made available to, local government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations. By continuing to provide us such information, you hereby acknowledge and agree that such personal information shall be transferred to, and stored in, the United States and such other third countries.
We seek to protect the security of your personal information and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE, AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO THE SITE AND/OR THE SERVICES OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT COMPROMISES THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION THAT IS CAUSED BY A THIRD PARTY. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access our Services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately if you have reason to believe that your username or password to access our Services has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.
- No Data Collected from Children
The Site and Services are not directed at, nor intended for use by, children. As a result, if you are under the age of eighteen (18), you are prohibited from accessing or using the Site and Services or from providing us with your personal information.
- Your Responsibilities
You are permitted, and hereby agree, to only provide personal information to Company if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or privileges. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO COMPANY, YOU EXPRESSLY REPRESENT AND WARRANT TO COMPANY THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE COMPANY WITH SUCH PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT COMPANY’S USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS SET FORTH HEREIN WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY AND HOLD HARMLESS COMPANY FOR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO COMPANY.
- Updating Your Information
It is important that the personal information that you provide to us is accurate and reliable. You must promptly notify Company of any changes or updates to your personal information in accordance with the “Contact Us” section listed below.
- Email Marketing and Your Rights
You have the right to opt out of receiving email marketing communications from us. Generally, the email marketing communications that you receive from us will provide you an option to “unsubscribe” from receiving future email marketing communications from us. You may also unsubscribe from such email marketing by contacting us in accordance with the “Contact Us” section listed below. You hereby agree to immediately notify Company, in writing, in the event you no longer own, license, or use an email address to which you subscribed to receive email marketing from us.
- California Privacy Rights
Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), California residents have additional data privacy rights:
- Access: The right to access general categories and/or the specific pieces of personal information we have collected, used, disclosed, or sold about you over the past twelve (12) months, including the sources from which the personal information was collected; the business or commercial purpose for which your personal information was collected, used, disclosed, or sold; and the third parties with whom we have shared your personal information.
- Deletion/Erasure: The right to request that we delete/erase your personal information under certain circumstances.
- Data Portability: The right to request that Company transfers, to the extent technically feasible, personal information in certain forms and formats.
- Nondiscrimination: The right not to be subject to discrimination for asserting your rights under the CCPA.
To exercise any of the CCPA’s data privacy rights set forth herein, please contact us in accordance with the “Contact Us” section listed below. If you would prefer, you may designate an authorized agent to submit a CCPA privacy request on your behalf. An authorized agent must be registered with the California Secretary of State to conduct business in California.
Privacy Request Verification Process. If you (or your authorized agent) makes any request related to your personal information under the CCPA, Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. Company will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email or other means and match at least two or three pieces of personal information we have previously collected from you before granting you access to, or erasing, specific pieces or categories of personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein, unless you have provided the authorized agent with power of attorney pursuant to California Probate Code §§ 4121 to 4130. None of the CCPA’s rights are absolute, and they are subject to legal and regulatory exceptions and exemptions. For more information about the CCPA, please see https://oag.ca.gov/privacy/ccpa.
Opt-Out Rights / Do Not Sell My Personal Information. California residents have the right to opt out of the sale of their personal information. Company does not sell personal information to third parties for profit or monetary or other valuable consideration, as such terms are defined in the CCPA.
- Nevada Privacy Rights
Company does not currently conduct “sales” of personal information for purposes of Nevada law. Notwithstanding the foregoing, Nevada residents may submit a request directing us to not sell personal information we maintain about them to third parties who will sell or license their information to others. If you would like to exercise this right, please contact us in accordance with the “Contact Us” section listed below.
- Do-Not-Track Signals
Some web browsers and devices may transmit “do-not-track” signals to the website with which they communicate. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.
- Persons with Disabilities
- Talent Management
- Events; Video Teleconferencing; Telephone Monitoring
Company hosts and uses video teleconferencing platforms to facilitate conferences, meetings, training events, and other programs. We often use online platforms that are owned and administered by a third-party service provider (e.g., Google, Zoom, WebEx, Microsoft Teams, Skype for Business). Please be aware that our video teleconferencing may record the content, conversations, and discussions thereon, and such records may be stored or retained by our third-party service providers. By participating in our events and video teleconferencing, you hereby consent to the collection and retention of any information provided therein, and you hereby consent to the recording of such activities. Where permitted by law, we may monitor and record telephone calls and other communications between you and Company. In the event you or your employees or agents call or otherwise contact us, you hereby acknowledge and agree that such communications may be monitored and recorded to ensure quality of service and to create an accurate record of the communication, and the communication content may be disclosed to third parties and is not considered confidential information.
- Changes to the Policy
- Contact Us
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