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2. Privacy Policy and Disclaimer
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PRIVACY POLICY AND DISCLAIMER
OUR SITE
etf.com ("the Site") is an independent resource for index investing in all its
forms. All content is produced independently of any advertising relationships.
Where sponsor-created content is published, it is clearly marked as such.
etf.com and its affiliates (collectively, "etf.com," “we,” “us,” or “our”) have
created this Privacy Notice and Policy in order to demonstrate our firm
commitment to the privacy of a) users of a etf.com World Wide Website ("etf.com
Website"); b) etf.com customers and prospective customers; c) etf.com
participants, members, users and such persons’ associated persons and
representatives; and d) any other individuals from whom etf.com collects
personal data during the course of its business activities. This Privacy Notice
and Policy describes the personal data we collect, how etf.com uses your
personal data, with whom we may share such data and how you can contact etf.com,
access your personal data and exercise your rights regarding etf.com’s use of
your personal data. By using or accessing a etf.com Website, you signify your
acknowledgment and assent to this Privacy Notice and Policy.
Data Collection and Dissemination
Except as otherwise provided in this Privacy Notice and Policy, the following
discloses our data gathering and dissemination practices.
etf.com values your privacy and processes your personal data, as a data
controller, in accordance with applicable data protection laws, including the EU
General Data Protection Regulation (“GDPR”). Processing means any operation or
set of operations which is performed on personal data or on sets of personal
data, whether or not by automated means, such as collection, recording,
organization, structuring, storage, adaptation or alteration, retrieval,
consultation, use, disclosure by transmission, dissemination or otherwise making
available, alignment or combination, restriction, erasure, or destruction.
etf.com processes your personal data for certain legitimate business
purposes/interests which may include some or all of the following:
To administer and manage our relationship with you
To evaluate, review, approve, or enter into potential contractual arrangements
To enable us to enhance, modify, personalize or otherwise improve our
services/communications for the benefit of users
To keep you informed about our activities, products and services that we think
may be of interest to you, as permitted by applicable law
To enhance the security of our network and information systems
To better understand how people interact with etf.com Websites
To comply with certain obligations under applicable law, industry guidelines and
internal policies
To manage, administer and assign transactions that are effected on etf.com
facilities
To determine the effectiveness of promotional campaigns and advertising
Use of a etf.com Website may involve the collection of personal data by etf.com.
There are also cases where users may be asked for personal data on a etf.com
Website. For example, online surveys are occasionally conducted to better
understand the needs and profiles of etf.com Website users. Our online surveys
typically ask users for demographic and profile data such as ZIP code, age, and
income level. In addition, personal data is requested if you voluntarily
register to receive additional information about etf.com, sign up for etf.com
products and services, or if you want to purchase a product directly from an
etf.com Website. Voluntary etf.com Website registration forms may request user
personal data such as name, mailing address and/or email address. Registered
users of ETFc.om Websites may have certain "opt-out" choices which are described
in the choice/opt-out section below.
What Data We Share
etf.com will only grant access to personal data on a need-to-know basis, and
such access will be limited to the personal data that is necessary to perform
the business function for which such access is granted. No authorization will be
extended to access personal data on a personal basis.
From time to time, your personal data may be processed on our behalf by, or
shared with, etf.com affiliates and other unaffiliated parties. (collectively
“third parties”). Third parties who process your data may include agents,
suppliers, vendors, business partners, and regulatory agencies that are located
in the United States and in other countries inside and outside the European
Economic Area (“EEA”) for the purposes outlined above. For data transfers
outside the EEA to third parties, etf.com relies on appropriate safeguards, as
defined in GDPR and as approved by the European Commission, to provide an
adequate level of protection.
Select third-party providers which may process your personal data may be found
in the “Service Providers” section below.
Security
etf.com shall exercise reasonable precautions to safeguard and secure personal
data. etf.com has security protections in place that help to protect against the
loss, misuse and alteration of the data under our control. Security protections
use technology consistent with current industry standards. etf.com periodically
tests the security protections of its information systems and monitors the
effectiveness of its information security controls, systems and procedures.
Although we take proper measures to safeguard against unauthorized disclosures
of data, no assurances can be provided that personal data that we collect will
never be disclosed in a manner that is inconsistent with this Privacy Notice and
Policy.
Data Retention
etf.com will retain your personal data for as long as your account, membership,
customer relationship or any other business relationship with etf.com, as
applicable, is active and as needed to provide you with products or services. In
addition, personal data may be retained for such additional time as may be
required under applicable law. If you wish to cancel your account or request
that we no longer use your personal data to provide you with products or
services, contact us using the contact information provided below.
Logged Files
etf.com Websites log IP addresses and browser types for administrative purposes,
including logging the IP addresses associated with each post to or use of a
etf.com Website. Such logs will be reviewed in order to improve the user
experience and to improve the materials and content available on a etf.com
Website. In addition, such information may be used for information
security-related activities in connection with performance monitoring,
investigations, questions, claims or complaints relating to use of a etf.com
Website.
Cookies
When you use a etf.com Website, etf.com and third-party service providers may
use “cookies.” Cookies involve placing small files/code on your device or
browser that serve a number of purposes, such as remembering your preferences
(e.g., language) and generally improving your experience on etf.com Websites.
Specifically, we may use such technology for purposes such as to:
Gather analytics about etf.com Websites, including demographic information in a
non-identifiable form, in order to improve etf.com Websites’ performance and
customize users’ experience;
Support security measures, such as requiring re-login into your account; and
more effectively market etf.com Websites and advertise other websites (including
those of our advertising partners) that may be of interest to you. You can set
your browser to notify you when you receive a cookie, giving you the opportunity
to decide whether to accept it. You may continue browsing a etf.com Website even
if you decide not to accept the cookie; however, certain capabilities of etf.com
Websites may be impaired. This Privacy Notice and Policy covers the use of
cookies by etf.com Websites and does not cover the use of cookies by any service
providers to etf.com Websites. [See also the "Select Service Providers" section
below.]
Policies for Children
etf.com does not intentionally collect or use any personal data from users under
16 years of age. No data should be submitted to etf.com Websites by users under
16 years of age.
Links to Third-Party Websites and Framing
For the user's convenience, etf.com Websites may provide links to other external
websites. The listing of a link by etf.com should not be construed as a
sponsorship, endorsement or approval of such websites, their content, or as an
indication of the value of any claims, recommendations or other information
contained therein. etf.com Website users should be aware that etf.com has no
control over any linked website and is not responsible for the contents or
privacy practices of any linked website or any link on a linked website. etf.com
urges our users to be aware of when they exit the etf.com Website and to
carefully read the privacy statements of each website that collects personal
data. This Privacy Notice and Policy is applicable only to data collected by a
etf.com Website.
Access to Personal Data
If you choose to update or delete personal data previously provided to etf.com,
to the extent allowed by law, etf.com will endeavour to correct, update or
remove the personal data being maintained by etf.com. You can do this by
contacting us via the “Contact etf.com” form located at
http://www.etf.com/contact-us.html or at the contact points specified below.
Choice/Opt-Out
etf.com Websites provide registered users the opportunity to opt out of
receiving communications from us at the point where we request data about the
user. If you opt in, etf.com may (1) share the data with those organizations
with which etf.com has a direct or indirect business relationship; (2) use the
data for its own internal purposes, or (3) contact you for market-related
research.
If you prefer not to receive traditional mail or other off-line promotions from
etf.com or from organizations with which etf.com has a direct or indirect
business relationship, send an email via the “Contact etf.com” form located at
http://www.etf.com/contact-us.html. Please include your full name and mailing
address.
To remove yourself from any etf.com email lists, please visit the etf.com
Website and click on “Email Alerts” from your personalized home page. Please
note: if you are not already signed in to your account, you will need to do so
using your user name and password. Alternatively, to remove yourself from any
etf.com email lists, you may send an email via the “Contact etf.com” form
located at http://www.etf.com/contact-us.html.
If you have any other questions about opting out of any communications from
etf.com, send an email via the "Contact etf.com" form located at
http://www.etf.com/contact-us.html.
Data Subjects Rights Under GDPR
To the extent provided for under GDPR, effective May 25, 2018, if you are a data
subject in the European Union, you are entitled to access your personal data;
obtain information on the processing of your personal data; have your personal
data rectified or erased or their processing restricted; or exercise your right
to data portability. You also are entitled to withdraw any consent that you
might have given to the processing of your personal data, including any consent
for any direct marketing purposes with future effect. These are known as “Data
Subjects Rights.”
If you would like to exercise your Data Subjects Rights or learn more about the
details of the processing of your personal data, please contact us using the
information provided below or please fill out a form provided here. etf.com will
respond to your request(s) as soon as reasonably practicable within the legally
required period of time. To help protect your privacy, etf.com takes reasonable
steps to verify your identity before granting access to your personal data or
responding to your requests.
If you are not satisfied with etf.com’ response or believe that we are not
processing your personal data in accordance with applicable law, please contact
etf.com’s using the contact information provided below. You also may contact or
register a complaint with the competent supervisory authority or seek other
remedies under applicable law.
Special Cases
etf.com reserves the right to disclose personal data in special cases, when we
have reason to believe that disclosing this information is necessary to
identify, contact, or bring legal action against someone who may be causing
injury or interference with (either intentionally or unintentionally) our rights
or property, other etf.com Website users, or anyone else who could be harmed by
such activities. We may also disclose personal data without notice to you in
response to a subpoena, or when requested from a governmental, regulatory body
or law enforcement agency or any other forum of competent jurisdiction when we
believe in good faith that such disclosure is required, or to respond to any
emergency situation.
Select Service Providers
etf.com has selected DoubleClick, Inc., a subsidiary of Google, Inc. ("Google"),
as an ad-serving/sales agent for etf.com Websites. Please review Google's
privacy policy for information about DoubleClick's data use policy and security
measures as they relate to advertising.
etf.com uses Google Analytics, a web analytics service provided by Google.
Google Analytics uses cookies or similar technologies to help etf.com Websites
analyze how users use etf.com Websites. Please review "How Google uses data when
you use our partners' sites or apps" for information about how Google uses
information collected through Google Analytics and how you may refuse the use of
cookies.
etf.com has selected PayPal Holdings, Inc. (“PayPal”) to provide certain web
services for online seminar registration, fulfillment, credit card transactions
and other services. Please review the PayPal Privacy Statement here for
information about PayPal's data use policy and security measures.
Interest-Based Advertising. etf.com uses third-party advertising companies to
provide you with etf.com advertisements that may be relevant to your interests,
as determined by your activity on etf.com Websites and other websites. This type
of ad-customization is known as "online behavioral" or "interest-based"
advertising. These advertising companies may use cookies or similar technologies
to understand your interests based on, for example, pages visited and browsing
patterns on etf.com Websites. The data collected when you interact with etf.com
Websites, content or services is used to display ads for etf.com products or
services on third-party websites. You can generally opt out of receiving
personalized ads from third-party advertisers and ad networks which are members
of the Network Advertising Initiative (NAI) or which follow the Digital
Advertising Alliance (DAA) Self-Regulatory Principles for Online Behavioral
Advertising by visiting the opt-out pages on the NAI website
(www.networkadvertising.org/choices) and the DAA website
(www.aboutads.info/choices). Some of the third-party advertising companies used
by etf.com may have adopted the use of the DAA's Advertising Options icon
(AdChoices) on these ads for the purpose of allowing users the ability to opt
out of this form of tracking. You may click on the AdChoices icon to opt out of
receiving interest-based ads that are served to you based on your activity on
etf.com websites and other websites. You can also elect to block all cookies by
using the cookie blocking options built into your browser software [see the
"Cookies" section above.]
Notice of Changes
etf.com reserves the right to update or change this Privacy Notice and Policy or
any part of it from time to time without prior notice. etf.com encourages you to
review this Privacy Notice and Policy periodically for changes. You may at any
time contact us to request a copy of this Privacy Notice and Policy.
Contact Information
If you have any questions regarding this Privacy Notice and Policy, please
contact us using the information provided.
Terms and Conditions
Welcome to etf.com. By browsing and using this website you are agreeing to
comply with and be bound by the following terms and conditions of use, which,
together with our privacy policy, govern etf.com's relationship with you in
relation to this website.
The term "etf.com" or "us" or "we" refers to the owner of the website. The term
"you" refers to the user or viewer of our website.
The use of this website is subject to the following terms of use:
The content of the pages of this website is for your general information and use
only. It is subject to change without notice.
Neither we nor any third parties provide any warranty or guarantee as to the
accuracy, timeliness, performance, completeness or suitability of the
information and materials found or offered on this website for any particular
purpose. You acknowledge that such information and materials may contain
inaccuracies or errors, and we expressly exclude liability for any such
inaccuracies or errors to the fullest extent permitted by law.
Your use of any information or materials on this website is entirely at your own
risk, for which we shall not be liable. It shall be your own responsibility to
ensure that any products, services or information available through this website
meet your specific requirements.
This website contains material which is owned by or licensed to us. This
material includes, but is not limited to, the content, design, layout, look,
appearance and graphics. Reproduction is prohibited other than in accordance
with the copyright notice, which forms part of these terms and conditions.
All trademarks reproduced in this website, which are not the property of, or
licensed to the operator, are acknowledged on the website.
Unauthorized use of this website may give to a claim for damages and/or be a
criminal offence.
From time to time, this website may also include links to other websites. These
links are provided for your convenience to provide further information. They do
not signify that we endorse the website(s). We have no responsibility for the
content of the linked website(s).
You may create a link to this website from another website or document without
etf.com's prior written consent. Links should be correctly attributed to etf.com
and may be accompanied by a short descriptive summary of the article.
You may not copy, reprint, redistribute in whole or in part any article without
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Your use of this website and any dispute arising out of such use of the website
is subject to the laws of New York.
The editors of etf.com reserve the right as they deem appropriate to exclude,
remove or block any postings or posters. As a moderated site, the editors will
act promptly on any posts and/or comments believed to be unduly divisive and/or
argumentative. Posts and comments considered uncivil and/or rude aren't allowed.
Personal attacks and baseless accusations with misleading and/or inaccurate
information are not permitted. Use of different aliases to get around the spirit
of these guidelines isn't allowed. These rules are subject to change by the
site's editors at any time.
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