Privacy policy | VettaFi

This Privacy Policy explains how VettaFi LLC (collectively, “VettaFi”, “we”, or “us”) collect, use, and disclose information about you. This Privacy Policy applies when you use our websites, including vettafi.com, advisorperspectives.com, etftrends.com, exchangeetf.com and etfdb.com (or any successor websites), and other online products and services that link to this Privacy Policy (collectively, our “Services”), contact our customer service team, engage with us on social media, or otherwise interact with us.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

If you are a California resident, please see our California Privacy Notice.

How We Collect Information

When you use our Services, we collect the below types of information from and about you. Some of this information may be considered personal information, meaning it identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Information You Provide Directly To Us

You can browse our Services without actively submitting any information about yourself, but you may choose to provide us with personal information through the Services. For example, you may provide identifiers, commercial information, payment information and other content and information, as further described below:

Identifiers: To register for a customer account with us, purchase products, sign up to receive email updates, attend one of our events, or otherwise use our Services, you may provide personal information such as name, physical address, telephone number, email address, the name of the business you represent, professional role, and similar information you choose to provide.
Commercial information: We may obtain commercial information, such as your purchase history, including records of our Services you have purchased or have considered.
Financial Information: We collect financial information to process your transactions through the Services such as your credit card information (although, note, that we do not store full credit card numbers as all payment transactions are processed by our third-party payment processors).
Other Content and Information You Share on the Services: You may submit information or content, such as by commenting on a social media post or participating in online forums or communities, when you interact with our Services.

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Note that by attending the Exchange conference or other in-person or online events, you grant VettaFi the right to record, film, photograph and/or capture your likeness. We reserve the right to distribute, broadcast, use or otherwise share those images, without any approval from or any payment to you.

Automatically Collected Information

We automatically collect personal information when you access and use our Services directly and when you engage with the websites of our partners and customers who deploy our cookies and pixels, including:

Identifiers: Identifiers such as your IP address, Internet service provider (ISP), mobile advertising ID, media access control (MAC) address, and identifiers associated with browser cookies, web beacons and similar technologies.
Device and Usage Information: We may collect information about the devices and computers you use to access our Services or the websites of our partners and customers, such as browser type, language, operating system, the referring web page, pages visited, and hyperlinks clicked. When you visit our Services or the websites of our partners and customers, we collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Services or other websites
Location information: We may collect your IP address and use it to estimate your approximate location.
Inferences: We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer that you are interested in certain financial products based on information we collect or receive about your browsing behavior and past purchases.

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Cookies and Other Tracking Technologies

We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. These technologies are placed on our websites as well as those we deploy for our partners and customers. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see the Your Choices section below.

Information from Outside Sources

We obtain information from third-party sources. For example, we may use information you provide us to collect additional information about you from identity verification services, advertising networks, marketing service providers, data analytics providers, webinar hosting providers, mailing list providers and other service providers.

How We Use Your Information

We use the information we collect or receive to administer your account, provide our Services and to customize your experience with us. We also use the information we collect from or about you to:

Provide, maintain, and improve our Services, as well as to develop new content and features;
Process transactions and send you related information, including confirmations, receipts, invoices, and customer experience surveys;
Personalize and improve your experience on our Services;
Notify you about our changes to our Services;
Create and manage your account;
Send you technical notices, security alerts, and support and administrative messages;
Send you marketing communications, including via e-mail and text
Provide our partners and customers with insights about how you use their websites, including through the use of our cookies and pixels.
Respond to your comments and questions and provide customer service and support (e.g., to resolve disputes, feedback, problems with your account or the Services);
Communicate with you about products, services, and events offered by VettaFi and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
Enable you to participate in public platforms or other interactive features of the Services (e.g., post comments in online forums);
Monitor and analyze trends, usage, and activities in connection with our Services;
Personalize the advertisements you see when you use our Services based on information provided by our advertising partners;
Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of VettaFi and others;
Debug to identify and repair errors in our Services;
Comply with our legal and financial obligations; and
Carry out any other purpose described to you at the time the information was collected.

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How We Share Your Information

We share your personal information with, and in certain instances sell your personal information to, third parties in the following circumstances or as otherwise described in this Privacy Policy:

Service Providers. We may disclose your information to service providers under contract who help with our business operations (such as fraud investigations, bill collection, payment processing, web hosting, product fulfillment, customer service, marketing and advertising, research, information technology, to process opt-out requests, to assist us in responding to consumer requests for access, deletion, or correction of information, direct mail and email distribution and site analytics and operations);
With Partners / Customers. We may disclose your information that we collect through certain of our Services with our partners and customers, such as information we may collect through our online technologies such as cookies and pixels.
Advertising Technology (“Ad Tech”) Vendors and Social Networks. On our Services, we may work with third parties to serve advertisements, provide us with data collection, reporting, and ad response measurement and assist with delivery of relevant marketing messages and advertisements. These third parties may view, set, or edit their own tracking technologies/cookies that are deployed when you visit our Services. The use of these technologies by these third parties is subject to their own privacy policies and we encourage you to review them. For more information about third party ad servers on our Services and your ability to opt-out of targeted advertising from such third parties, please visit the Advertising and Analytics section below;
Information You Post. If you post information or content, such as by commenting on a blog, or participating in online forums or communities, or when you interact with our Services through social media sites, plug-ins or other applications, depending upon your privacy settings, this information may become public on the Internet. We cannot prevent further use of this information. You can control what data you share through privacy settings available on some social media sites. Please refer to those third-party sites’ privacy policies and terms of use to learn more about their privacy practices, which we do not control;
Legal Obligations. If we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
Enforcement of Our Agreements or Rights. If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of VettaFi our users, the public, or others;
Lawyers and Professional Advisors. With our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests;
Corporate Transaction. In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
VettaFi Family. Between and among VettaFi and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
Commercial Partners and Clients. With sponsors of our virtual events and our other commercial partners and clients, who may contact you with their own materials.

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Advertising and Analytics

We allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by VettaFi and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit http://www.aboutads.info/choices, or for residents in the EAA, please visit http://www.youronlinechoices.eu/.

Do Not Track

Our Services may, from time to time, collect information about your online activities, over time and across different sites and applications. When you use our Services, third parties may also collect information about your online activities, over time and across different websites, online or cloud computing services, online applications, or mobile applications. Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Our Services currently do not change the way they operate based upon a “Do Not Track” signal unless required by law.

Additional Disclosures for Individuals in Europe

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data. If you are located in the above areas, this section applies to you.

Lawful Basis for Processing Personal Data

We will process your Personal Data if and to the extent applicable law provides a lawful basis for us to do so. We will therefore process your Personal Data only:

To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and services you requested);
When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you);
To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications); and
When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.

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Personal Data Retention

We will only retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements, or other legitimate business purposes.

We will also retain Personal Data for internal analysis purposes. Personal Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Once the appropriate retention period has expired, we will delete your Personal Data in accordance with applicable law.

Your Rights in Relation to Your Personal Data

You can always choose not to give us your Personal Data. However, certain Personal Data is necessary for you to engage with us as a customer, vendor, or visitor, and we may not be able to provide all or some of our services, to enter into a contract with you, or to send you requested marketing information.

If you are a resident of the European Economic Area (EEA), have certain data protection rights as a data subject (subject to certain limitations), including the rights to:

Request access to your Personal Data (commonly known as a “data subject access request”), and request certain information in relation to its processing;
Request rectification of your Personal Data;
Request the erasure of your Personal Data;
Request the restriction of processing of your Personal Data;
Object to the processing of your Personal Data; and
Request the transfer of your Personal Data to another party.

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If you want to exercise any of these rights, please contact us at privacy@etfflows.com.

Please note that we may ask you to verify your identity before responding to such requests.

Under certain circumstances, you may exercise your rights through a legal representative or agent you have authorized by a power of attorney to exercise rights on your behalf.

Cross-Border Data Transfers

Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers. By using our websites and services you understand that your information will be transferred to countries outside of your

country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data. We comply with all data protection and privacy laws whenever Personal Data is transferred across borders by using standard contract clauses or other data transfer agreements to protect your Personal Data. If you require further information about our data transfers or would like to receive a copy of the safeguards in place, you can request it from privacy@etfflows.com.

Additional Information and Concerns

If you have any further questions or concerns regarding data we collect, or how we use it, then please contact us at privacy@etfflows.com.

Individuals in the EU and other countries outside of the U.S. may contact their local supervisory authority to ask questions or express concerns regarding our Privacy Policy.

Your choices

Account Information

You may update and correct certain account information at any time by logging into your account, emailing us at privacy@etfflows.com, or via mail (see physical contact information below). If you wish to delete your account, please email us at privacy@etfflows.com and indicate in the subject line and body of your email your desire to have your account deleted. Please take note that we may retain certain information as required by law or for our legitimate business purposes.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

Communications Preferences

You may opt out of receiving promotional emails or text messages from VettaFi by following the instructions in those communications or by contacting us. If you opt out, we may still send you non-promotional emails and text messages, such as those about your account or our ongoing business relations.

By opting in to SMS related to Exchange Conference, you agree to receive SMS messages from VettaFi, including regarding conference developments, housekeeping reminders, and promotional offers. Message frequency varies, and message and data rates may apply. We also share your Personal Data with sponsors of the Exchange ETF Conference who may contact you with their own materials.

Mobile Push Notifications

With your consent, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

CCPA and Other U.S. State Law

The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.

Notice of Collection

In the preceding 12 months, we have collected the following categories of personal information from California residents: identifiers, characteristics of protected classifications under State or federal law, commercial information, payment information; Internet or other electronic network activity information, geolocation data, professional or employment-related information, and inferences.

We collect and disclose these categories of personal information for the business and commercial purposes described above.

Notice of Disclosure for a Business Purpose

We disclose the following categories of personal information to the following categories of service providers and third parties.

Category of Personal Information

Categories of Recipients

Identifiers

(e.g. name, address, email address)