PRIVACY POLICY FOR NON-REGISTERED FUNDINFO.COM AND ETFINFO.COM USERS

 1.   Introduction

This Privacy Policy describes how fundinfo AG (“fundinfo”) collects, uses and handles personal information. It further describes why we collect personal information, how we use cookies, when and how we share personal information with third parties and how we keep your personal information secure.

The terms “we” “us” and “our” refer to fundinfo AG Switzerland, fundinfo (UK) Ltd, fundinfo (Germany) GmbH, fundinfo Asia Limited, fundinfo Spain S.L., Madrid, fundinfo (Singapore) Pte Ltd and fundinfo (France) SAS.

“fundinfo website” or “fundinfo” refers to both fundinfo.com and etfinfo.com.

 2. The EU Representative

As fundinfo AG is registered in Switzerland and offers services to investors in the European Union, it has appointed fundinfo (Germany) GmbH as its EU Representative.

The contact details of fundinfo (Germany) GmbH are as follows:

Rheinstraße 13

60325 Frankfurt am Main

Germany Phone: +49 69 750 859 790

Email: info@fundinfo.com

 3. The Data Protection Officer

Mr Daniel Walter, fundinfo Chief Operating Officer, has been appointed as Data Protection Officer. Mr Walter can be contacted at dpo@fundinfo.com or fundinfo AG, Staffelstrasse 12, 8045 Zürich, Switzerland.

 4.   What personal information do we collect?

If you do not create an account with fundinfo the personal information we collect is limited to the country where you reside, the language through which you choose to access the fundinfo website and whether you are a private or an institutional investor.

 5.   Why do we collect personal information and how do we use it?

fundinfo may collect personal information through use of cookies to enable us to provide information and documents to you, as well as to provide information to our members, who are the fund managers and companies listed in the members section of the fundinfo website. Specifically, the following data are collected from you by fundinfo:

The above listed data are considered “non-personal” data if they cannot be used to identify a specific user. However, those data, if collected or read together with unique identifiers such as cookies (if accepted by the user) or an IP address, may lead to the identification of a user. In this case, the data will be deemed as “personal data” and treated as such.

We also use your personal information to perform marketing and research related activities and to supply other administrative services. In addition, we may from time to time review your usage of the site in order to assess how we can improve our services.

 6. Lawful basis for processing your personal data

fundinfo will process your data in a lawful, fair and transparent manner.

Your personal data is processed because you have consented to the processing of your personal data for the purpose of using the services provided by fundinfo.

 7. How long do we hold your information for?

The information with which you provide us before accessing the full fundinfo website (i.e. your investor profile, your country of domicile, your chosen language and your acceptance of our Disclaimer and Terms & Conditions of Use) are stored as a cookie on your browser for one month and by us internally for one month.

 8. How do we collect personal information?

We collect personal information when you specify your country of residence and investor profile (whether you are a private investor or an institutional investor) through the use of cookies.

 9.   Cookies

In general

A cookie is a small file which a website puts on a computer or other device so that the website can remember something about you at a later time. When you visit the fundinfo website for the first time, you will be asked to specify your country of residence and investor profile (whether you are a private investor or an institutional investor).  The fundinfo website will place a cookie on your computer or device so that when you visit the website again you will not be again requested to specify your country of residence or investor profile. fundinfo requires to use cookies to enhance its website functionalities by tailoring its services for you based, for example, on your investor profile and domicile.

The following are the cookie types we use:

-          User preferences;

-          Authentication;

-          Security;

-          Application visibility reporting;

-          Session persistence;

-          Usage statistics.

These cookies will not be used for any purposes other than the ones stated above. The cookies we used are “essential”: this means that our cookies are strictly necessary for us to provide you with the service that you have consented to when accessing our website. As such, we do not provide for a mechanism of “opting-out”. If you do not accept our cookies you will not be able to avail of the services offered by fundinfo.com.

List of cookies used by fundinfo

Cookie Name

Default Expiration Time

Description

_utma

2 years from set/update

Used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google Analytics

_utmt

10 minutes

Used to throttle request rate

_utmb

30 mins from set/update

Used to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google Analytics.

_utmc

End of browser session

Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.

_utmz

6 months from set/update

Stores the traffic source or campaign that explains how the user reached your site. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics

PHPSESSID

End of browser session

ID of the user session

PreferredLanguage

1 Month

User language

BIGipServer*

End of browser session

“Persistence Cookie”, ID user session

TSxxxxxxxx

End of browser session

Main ASM Cookie

f5_cspm

End of browser session

Session Cookie created for application visibility reporting. Client Side Performance Monitoring (CSPM) feature

f5avrbbbbbbbbbbbbbbbb

End of browser session

Session Cookie created for application visibility reporting.

f5avrxxxxxxxxxxaaaaaaaaaaaaaaaa

End of browser session

Session Cookie created for application visibility reporting.

 

Specific to gateway.fundinfo.com

On gateway.fundinfo.com we use the following cookies:

Cookie Name

Default Expiration Time

Description

TSxxxxxxxx

End of browser session

Main ASM Cookie

f5_cspm

End of browser session

Session Cookie created for application visibility reporting. Client Side Performance Monitoring (CSPM) feature

f5avrbbbbbbbbbbbbbbbb

End of browser session

Session Cookie created for application visibility reporting.

f5avrxxxxxxxxxxaaaaaaaaaaaaaaaa

End of browser session

Session Cookie created for application visibility reporting.

 

The following cookies are set by Google Analytics:

Cookie Name

Default Expiration Time

Description

_ga

2 years

Used to distinguish users

_gid

24 hours

Used to distinguish users

_gat

1 minute

Used to distinguish users

 10.   Sharing of personal information with third parties

If you do not create an account with fundinfo we will generally not make your personal information (as listed in point 1, above) available to any third party except our related companies, i.e. fundinfo (UK) Ltd, fundinfo (Germany) GmbH, fundinfo Asia Limited, fundinfo Spain S.L., Madrid, fundinfo (Singapore) Pte Ltd and fundinfo (France) SAS.

Under exceptional circumstances, we may make your data available to third-party service providers who help us 1) administer fundinfo.com or 2) process the data submitted to it. These providers will not use the data for their own purposes.

 11.   Links to other web-sites

fundinfo may provide links to one or more other third party websites. We encourage you to read their individual privacy policies before providing any of your personal information to them.

fundinfo is not responsible for the privacy policy adopted by third party web-sites.

 12. Children’s data

fundinfo is intended for use by persons aged 18 and over. fundinfo does not knowingly collect or solicit any information from anyone under the age of 18. The services offered by fundinfo and its content are not directed at children under the age of 18. In the event that we learn that we have collected personal information from a child under age 18, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.

 13.   Your rights under Privacy Law

Your rights include:

        I.            The right to be informed of the processing operation and purpose

You have the right to be informed of the source of the personal information, of the purposes and methods of the processing, of the identification information concerning the entity responsible for collecting and processing your personal information, of the entities or categories of entity to whom or which your personal information may be communicated and who or which may get to know said information, etc.

      II.            The right of access

You have the right to obtain confirmation from fundinfo on whether or not your personal data is being processed and if so, to request further information on the processing.

    III.            The right to rectification

You have the right to rectify any inaccurate personal data, without delay.

    IV.            The right to erasure (“to be forgotten”)

You have the right to obtain erasure of your personal data without delay, where certain grounds apply.

      V.            The right of restriction to data processing

You have the right to obtain restriction to the processing of your data by fundinfo, where certain grounds apply.

    VI.            The right to withdraw consent

You have the right to withdraw consent at any time without charge.

  VII.            The right to lodge a complaint with a supervisory authority

 The right to data portability

You have the right to receive the data you have provided to fundinfo in a structured, commonly used, machine-readable format and to send this data onto another data controller.

For the purpose of exercising the rights described above, you may contact the Data Protection Officer email: dpo@fundinfo.com or write to fundinfo AG, Staffelstrasse 12, 8045 Zürich, Switzerland.

 14.   Transfers to third country jurisdictions

The fundinfo group is headquartered in Switzerland, with subsidiaries located outside the European Economic Area (EEA), in Singapore and Hong Kong. The European Commission has recognised Switzerland as providing an adequate level of protection of personal data. Your personal data may be transferred across international borders. It may be transferred to countries that have different levels of data protection laws to the country from where you submitted your personal data. fundinfo has put in place security measures for the export of personal data from its jurisdiction and has made arrangements with entities receiving your personal data such as, that they shall ensure that security measures are in place, and that your personal data is processed only in accordance with EU Data Protection laws.

If data is transferred from within the EEA to a jurisdiction outside the EEA, it is done so under our binding cooperate rules, which contain a high standard of data protection rules and provide safeguards for personal information that is transferred outside of the EEA.

 15.   Security of your personal information

fundinfo takes reasonable measures to ensure the security of your personal information. In particular, we take steps to protect against unauthorised access to disclosure of or alteration of your personal information. The steps we take to protect the security of your personal information include the putting in place of industry standard firewalls and password protection systems. 

 16. Consent to this Privacy Policy

By ticking the box at the end of the Disclaimer and Terms & Conditions of Use, you consent to the collection and use of your data, as described in this Privacy Policy.

 1st May 2018