Please read this Policy carefully. By visiting or using our Sites, you acknowledge the practices described in this Policy. Your use of our services, including our Sites, and any dispute over privacy, is subject to this Policy and our Client Terms (available at www.ETFEurope.net), including applicable limitations on damages and the resolution of disputes.
The information that we collect is controlled by ETFEurope, which is headquartered in the United Kingdom at Level 1, Devonshire House, One Mayfair Place, London, W1J 8AJ. As discussed below in the section titled Cross-border transfer of information, information that we collect may be transferred to and processed in the United States or another jurisdiction outside your country of residence, which may have less stringent data protection laws than in your country of residence. ## Information collection ETFEurope collects and processes both Personal Data and Other Data. For purposes of this Policy, “Personal Data” is any information that alone or together with other information in ETFEurope’s possession relates to an identified or identifiable natural person, such as name, phone number, email address. “Other Data” is any additional information that is not Personal Data. In this section, we describe our information-collection practices, including the types of Personal and Other Data that we collect. In subsequent sections of this Policy, we describe how we use and disclose Personal and Other Data
We may combine the Personal and Other Data we collect directly from you with information collected from or about you in other contexts, such as on the Sites. This may include information collected online, such as through our email exchanges with you; or from offline sources, such as information that we collect when you establish your account with us or call customer service. We will treat such combined information in accordance with this Policy. If you do not wish to provide information to ETFEurope, we may be unable to provide certain services to you, and if we or a fraud prevention agency determine that you pose a fraud or money laundering risk, we may refuse to provide or stop providing the services you have requested.
What Personal Data do we collect?
ETFEurope may collect the following Personal Data from or about you:
Personal Data we collect directly from you, such as when you request information from us: ETFEurope collects and maintains Personal Data about you, and about any person or entity on whose behalf you are acting, that you provide to us, such as when you obtain service from ETFEurope, request information or materials from us, register to use the Sites, or otherwise interact with us or our Sites. The types of Personal Data we collect vary based on your particular interaction with us, but could include:
- Your name;
- Home address;
- Telephone numbers;
- Email address;
- Account number and other account information;
- User name, password, and other security credentials; and
- Other information you provide to us directly online, such as information collected for identification or authentication purposes.
Information from telephone, email, online chat, or text message communications with ETFEurope: If you communicate with ETFEurope by telephone, email, online chat, or text message, ETFEurope may keep a record of that communication. In accordance with applicable law, ETFEurope also may record and monitor telephone calls for training, quality assurance, security, and customer service purposes.
Information contained in surveys: ETFEurope may ask you to complete surveys for research and client satisfaction assessment or similar client service-related purposes. You are not required to respond to those surveys, and any information collected by ETFEurope or on ETFEurope’s behalf that you provide in response to those surveys is at your discretion.
What Other Data do we collect automatically?
Cookies: A cookie is a small file of letters and numbers that is stored on your computer, tablet, mobile phone, or other device when you visit a website. Cookies contain information that is transferred to or read on your device and allow websites to recognise devices and store certain information, such as user preferences. Cookies are used to distinguish you from other users of our Sites. This helps us to provide you with a useful experience when you browse our Sites and also allows us to improve our Sites. We and our third-party service providers use session cookies, which link your actions during a particular browser session and expire at the end of that session, as well as persistent cookies, which remain on your device and allow us to remember your actions or preferences across multiple browser sessions.
Web beacons: The Sites or the emails that you receive from ETFEurope use an application known as a “web beacon” (also known as a “pixel tag” or “clear gif”). A web beacon is an electronic file that usually consists of a single-pixel image. We and our service providers may use web beacons and cookies to determine whether and when you receive and open our emails; these beacons and cookies may also capture information such as the type of device, operating system, email program, and web browser used to view the email, the IP address from which you opened the email, and whether you click on any links in the email. These technologies enable us to gauge the effectiveness, relevance, and value of our email communications, as well as to target relevant advertising to you and to measure the impact of that advertising on your ETFEurope relationships.
We may combine Other Data with additional information that we have collected about you, including, where applicable, your name and other Personal Data. When we combine Other Data with Personal Data, we treat all of the combined information as Personal Data. If you have registered for secure access on our Sites, we are able to combine the information we collect about your usage of our Sites during a secure (logged-on) session with other information we know about you, such as any searches you conduct or information you request during your web session. We can also identify your computer or device on each visit to our Sites, even if you do not log on, and link information about that visit, as well as about ETFEurope ads that you may have viewed on other websites, to you. We may use this combined information to assess the appeal and usefulness of the information and tools offered on our Sites and the effectiveness of our online advertising, as well as to identify ETFEurope services that may be of interest to you. For more information about how we and our service providers use information for analytics and advertising purposes, please see the section below titled Website analytics and Interest-Based Advertising.
Use, legal basis, and disclosure
How do we use Personal and Other Data?
We use the Personal and Other Data that we collect for the purposes described in this Policy, for the purposes for which it was provided to us, as required by law, and for our business purposes, including:
To establish and administer accounts and your relationship with us, to fulfil the terms of any agreement you have with us, and to otherwise provide ETFEurope’s services to you;
To communicate with you, notify you about important updates or changes to ETFEurope’s and services, and address relevant inquiries or complaints;
To comply with our legal obligations and protect our legal rights, including, without limitation, to comply with record-keeping, reporting, and tax obligations under applicable law (such as corporations);
To prevent fraud and to verify your identity; in this regard, we and fraud prevention agencies may also enable law enforcement agencies to process your Personal Data to prevent, detect, and investigate crime;
For marketing and promotional purposes, in accordance with applicable law. For example, if you consent, we will use your Personal Data, such as your email address, to send you news and newsletters, or to otherwise contact you about ETFEurope’s information we think may be of interest to you. Although we hope you will find our promotional communications of interest, you may opt out of receiving them by following the “unsubscribe” instructions at the bottom of each communication;
To create new services or improve our existing services;
To tailor the content, information, and advertising that we may send or display to you, including as discussed in the section below titled Website analytics and Interest-Based Advertising, to offer location customisation and personalised help and instructions, and to otherwise personalise your experiences with ETFEurope and while using the Sites;
To count and recognise visitors to the Sites and various Site features and better understand how users access and use our Sites and ETFEurope services;
To support Site performance, perform Site analytics, enhance Site navigation, and improve our web design and functionality; and
For other research and analytical purposes. ## Legal bases for using Personal Data We will only collect, use, and share your Personal Data where we are satisfied that we have an appropriate legal basis to do this. This may be because:
Our use of your Personal Data is necessary to perform a contract or take steps to enter into a contract with you (for example where we use your contact, demographic, and banking information required to establish and fund your account in the performance of our services);
Our use of your Personal Data is necessary to comply with a relevant legal or regulatory obligation that we have (for example, where we are required to undertake vetting to comply with anti-money laundering legislation or where we are required to disclose Personal Data to a court or tax authority);
You have provided your consent to us using the Personal Data (for example in relation to our use of targeting cookies on the Sites); and/or
Our use of your Personal Data is in our legitimate interest as a commercial organisation (for example in order to verify your identity and prevent fraud, to make improvements to our services and to provide you with information you request); in these cases we will process your Personal Data at all times in a way that is proportionate and respects your privacy rights, and you have a right to object to this processing as explained in the section below titled Your legal rights.
If you would like to find out more about the legal bases on which we process Personal Data, please contact us using the details below.
To whom do we disclose Personal and Other Data?
We may disclose Personal and Other Data to third parties for the following purposes, as permitted by law. You have certain rights to object to the processing of your Personal Data as described below.
Legal purposes: We may use and disclose information about you as we believe reasonably necessary to protect the rights and property of ETFEurope, including to establish legal claims or defences, to obtain legal advice, to defend our legal rights, to protect our rights or property, to protect against fraud and abuse, to protect other users of our services and our Sites, and to protect the life, body, or property of others (individuals or entities). We also may disclose information about you in order to comply with the law, judicial proceeding, court order, or other legal process, such as in response to a court order or direction. We use and disclose Personal Data to undertake checks for purposes of preventing fraud and to verify your identity. We and fraud prevention agencies may also enable law enforcement agencies to process your Personal Data to detect, investigate, and prevent crime. Additional information concerning how the information held by fraud prevention agencies may be used will be provided in writing upon request.
Market research: We provide information to market research companies for the purpose of assessing information about our business or client base. We may provide our clients’ or prospective clients’ contact details to market research companies to undertake research on behalf of ETFEurope, in accordance with applicable law. For example, we may run client satisfaction surveys or run focus groups on proposed services.
Direct sharing through third-party websites and services: The Sites may enable you to share information directly with websites or online services operated by third parties. For example, the Sites contain features that allow you to share articles or content through Google Plus, Twitter, LinkedIn, Medium and other services, and to view content through video players and other services (such as the YouTube video player). If you choose to use these features, you may disclose information to those websites or services and their users, and to the public more generally. These websites and services may also set and/or access a cookie on your device. Because these third-party websites and services are not operated by ETFEurope, we are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of information through these websites and services will be subject to the privacy policies of the third-party websites or services, and not this Policy.
Competitions, contests, and promotions: ETFEurope may use an agency to run competitions, contests, or promotions on the Sites or elsewhere, and if you choose to participate, we or third parties may request your name, address, telephone number, email address, and other information where it is necessary to ensure your eligibility and to comply with lottery and gaming regulations. In compliance with the relevant regulations, it may also be necessary to publish details of the winners of competitions in appropriate news media.
Website analytics and Interest-Based Advertising
We partner with third parties to collect the Other Data discussed above to engage in Site analysis, auditing, research, and reporting. When you visit our Sites, these third parties may set and access cookies on your computer or other device and may use web beacons to collect information about your activity on the Sites. We use these cookies to identify you as having confirmed your eligibility to enter and use our Sites, and to make sure you connect to the right service on our Sites when we make any changes to the way the Sites work. These cookies are also used to help us improve how our Sites work and understand what interests our users, and for error management, to help us improve our Sites by measuring any errors that occur. In particular, the Sites use Google Analytics to help collect and analyse certain information for the purposes discussed above. The information generated about your use of the Sites may be transmitted to and stored by Adobe Analytics on servers outside your country of residence.
For more information about Interest-Based Advertising and how to opt out, please visit the European Interactive Digital Advertising Alliance opt-out page (available in 27 languages).
Although our Sites currently do not respond to “do not track” browser headers, you can limit tracking by taking the steps discussed above. The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy.
Cross-border transfer of information
ETFEurope generally maintains centralised servers and systems in the United Kingdom and may maintain servers and systems elsewhere. ETFEurope also may subcontract the processing of your information to, or otherwise share your information with, other third parties in the United States or countries other than your country of residence. As a result, where the Personal and Other Data that we collect is transferred to and processed in the United States or anywhere else outside the European Economic Area (EEA) for the purposes described above, we will take steps to ensure that the information receives the same level of protection as if it remained within the EEA, including entering into data transfer agreements, using the EU Commission approved Standard Contractual Clauses, or relying on certification schemes such as the EU-US Privacy Shield. You may have a right to details of the mechanisms under which your data is transferred outside the EEA.
Personal Data quality
ETFEurope relies on the accuracy of the information provided by its clients and others. We take reasonable efforts to ensure that Personal Data collected by us or on our behalf is accurate, up to date, and complete, in accordance with applicable law. If any information about you changes or you have any concerns regarding the accuracy of information about you held by ETFEurope, you should contact us at the address provided in the Contact us section below.
Information security and retention
We use commercially reasonable physical, electronic, and procedural safeguards to protect your Personal Data from loss, misuse, and unauthorised access, disclosure, alteration, and destruction in accordance with applicable law. Please be aware that despite our best efforts, no data security measures can guarantee 100% security all of the time. If you have online account access, we recommend that you take steps to protect against unauthorised access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your user name and password private. For additional information, see our Online Security Policy.
If you have any questions relating to this Policy, or concerns about the way in which we have handled information about you, please do not hesitate to send us an email at privacy@ETFEurope.net. You may also contact us by sending a message to:
ETFEurope Limited Level 1, Devonshire House, One Mayfair Place London, W1J 8AJ, United Kingdom
If you raise concerns about how we have handled your Personal Data, we may request additional details from you regarding your concerns, and may engage or consult with other parties in order to investigate and resolve your issue. We will keep records of your request and any resolution of your issue.
We will post changes to this Policy on our Personal Investor Site along with the effective date of the changed policy. We recommend that you review this Policy periodically. If we make a material change to this Policy, you will be provided with appropriate notice.
Issued by ETFEurope Limited
© 2019 ETFEurope Limited