PRIVACY POLICY

Introduction

Our website www.wisdomtree.eu (referred to as the “Site”) is owned by the WisdomTree group which includes WisdomTree UK Limited and WisdomTree Ireland Limited (collectively “WisdomTree”). WisdomTree provides services to professional and, where applicable, retail investors, subject to applicable laws and regulations. By accessing and using the Site you agree to be bound by all terms and conditions which are set out on the Site from time to time, which govern such access and use (the "Terms and Conditions").

This privacy policy (the “Privacy Policy”) (together with our Terms and Conditions and separate Cookies Policy) discloses our information gathering and dissemination practices for the Site and it explains how we collect, use, store, and protect your personal data. For any questions, you may contact us (see 'Contact Information' section). We reserve the right to modify this Privacy Policy and the Terms and Conditions at any time.

WisdomTree is committed to protecting and respecting your privacy. We will use your personal data only for the purposes and in the manner set forth in this Privacy Policy which describes the steps taken to ensure our processing of your personal data is in compliance with the General Data Protection Regulation 2016/679 which came into force on the 25th May 2018 (EU), the Data Protection Act 2018 (UK), and other relevant data protection legislation (together “GDPR”). 

Confidentiality

We will keep your information confidential and only use it within our group (which means our affiliated companies, successors and assigns), and only transfer it to third parties in the manner described in the below section labelled “Use of third parties”, unless we are under a duty to disclose or share your personal data in order to comply with a court order or other legal or regulatory requirement.

How and why we collect personal data

Through our Site you may have an opportunity to send us information, such as through the "contact us" pages or any other area where you may send e-mails, request brochures or provide feedback. By choosing to participate in these activities, you might provide us with some personal information.

We may also obtain personal information about you from third parties or through other business activities, such as attending conferences or exchanging business cards. We will in all cases endeavor to ensure you have the opportunity to read this Privacy Policy when processing your personal data.

The personal information we may collect includes, but is not limited to: your name, address, location, email address, company details, job title and any other relevant information that may be included within correspondence. We also collect information to classify you as a certain investor type (e.g., professional or retail) and your location, which is necessary for legal and regulatory reasons to grant you access to our Site. When you subscribe to our services or fill out registration forms, we collect the information you provide. In addition, details of your visits to our Site including (but not limited to) IP address, cookies, traffic data, location data, weblogs and other information related to what pages are accessed and when may be collected.  

If you are accessing sections of our Site that are password protected or have entered the Site through a link in an email, our Site will identify you as an individual and may collect data including information about the pages you visit, the documents you download or other information to enhance your future interaction with our Site.

Any information collected about you may be associated with other identifying information we hold. Certain online analytical data may be collected by using cookies in accordance with our Cookie Policy.

WisdomTree will retain and process your personal data only when this is necessary to achieve our commercial or business objectives and to comply with our regulatory obligations. After careful consideration, WisdomTree has concluded the processing of personal data for the reasons mentioned below shall be considered necessary, as there would not be another way of achieving the identified interest of the firm.

WisdomTree will always ensure its business interest does not override your rights and freedoms as an individual. We may also retain your information to comply with any applicable laws or regulations. We are legally required to hold some types of information to fulfil our statutory and regulatory obligations. These obligations include regulations made by the Financial Conduct Authority (“FCA”), by whom WisdomTree UK Limited is authorised and regulated by in the UK (reference number: 538634) and those made by the Central Bank of Ireland (“CBI”), by whom WisdomTree Ireland Limited is authorized and regulated by in Ireland (reference number C178702).

We may, for example, use your information to: respond to queries from you or provide information that you request from us; ensure that content from our Site is presented in the most effective manner for you and for your computer; provide you with information about our products and services; send you promotional materials, newsletters and other communications; provide you with invitations to events, promotions, surveys and market research or other marketing correspondence; respond to your inquiries; verify your information; perform data analysis (such us demographic analysis and consumer research); operate, evaluate and improve our business (developing our products and services, improving our communications, performing auditing or accounting functions); protect against any unlawful activity and prevent fraud; carry out our obligations arising from any contracts entered into between you and us; comply with any legal requirements and our Policies; allow you to participate in interactive features of our service when you choose to do so; notify you about changes to our business, products or services; or any other internal purposes that we believe to be necessary.

Legal basis for processing your personal data

We only collect and process your personal data where we have a lawful basis to do so under GDPR. The legal basis we rely on will depend on the services you use and how you use them. We rely on the following legal bases:

• Legitimate interests: We process your personal data for our legitimate interests, provided these interests are not overridden by your rights and freedoms. This includes activities such as improving our Site and services, conducting data analytics, marketing our products and services to business contacts, and for security purposes. Where we rely on legitimate interests, we have carried out a balancing test to ensure your rights are not overridden by our interests.
• Consent: We will ask for your consent to process your personal data in specific situations, for example, to send you marketing communications by email or to place non-essential cookies on your device. Where we rely on consent, you have the right to withdraw it at any time.
• Legal obligation: We may need to process your personal data to comply with our legal and regulatory obligations, such as those imposed by the FCA and the CBI, or to respond to lawful requests from public authorities.

As a principle, we will only retain your personal data for such period of time as is necessary to serve our business interest and will not process personal data beyond that point. At a maximum, we will retain your personal data for no longer than is necessary for the purposes for which it was collected, and in accordance with our legal obligations and legitimate business interests. We have established the following retention periods:

1. Client and prospective client data: 7 years
2. Marketing data preferences: until withdrawn or 3 years of inactivity
3. Website analytics: 26 months
4. Contact form submissions and general enquiries: 2 years after the query is resolved, unless it leads to a client relationship.

If you request data deletion, we may retain certain information for 5 years to meet regulatory obligations. During this period, you will not receive marketing communications.
 

Internet browsing, cookies, and Third-Party Advertising

The types of personal data that may be collected through our Site include IP address, name, address, email address, telephone number job title, company, investor type, country of location. Additionally, if you are accessing parts of this Site that are password protected, then once you submit your password and enter, this Site will recognize who you are and collect all information that you submit, including all electronic information (such as what you read or watch).

We will collect cookies in compliance with the GDPR. We will collect cookies within the following categories: 

• Necessary. We use necessary cookies to help make our website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies. You can set your browser to block or alert you about these cookies, but then some parts of the website will not work.
• Functional. We use functional cookies to provide a personalized experience to visitors to our website, including your preferred language or the region that you are in.
• Analytics. We use “analytics” cookies that allow us to recognize and count the number of visitors and to see how visitors move around the website when they are using it. This helps us to improve the way our website works, for example by making sure users are finding what they need easily. The collected data provides us only with anonymous traffic statistics (like number of page views, number of visitors, and time spent on each page). These cookies are only placed with your consent. Examples of the third-party analytics cookies we use include Hotjar, Lucky Orange and Google Analytics. Specifically, we use Google Analytics to collect information about how users use our services, which we then use to compile reports that disclose trends without identifying individual visitors and help us improve our services. For more information on Google Analytics, click here. For more information about Google’s privacy practices, click here. You can opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
• Advertising. We and our third-party advertising partners use these cookies to collect information about how you use our website and use that information to serve online ads that may be relevant to your interests. These cookies are only placed with your consent. We use Meta's advertising services (including Instagram and Facebook) to promote our products and services. To measure the effectiveness of our advertising we use Meta Pixel and Meta’s Conversions API, which track website conversion and send information about website conversions directly to Meta via both client-side tracking (Meta Pixel) and server-to-server integration. Meta Pixel is a piece of code that tracks user actions, page visits, traffic patterns, and conversion activities on our website, which we use to measure advertising effectiveness, optimize ad delivery, enable retargeting and show you relevant advertisements on Meta’s platforms. This involves the use of Meta's cookies for conversion and retargeting tracking purposes. For more information about how Meta processes your data and your rights in relation to opting out of such processing, please visit  Meta's Privacy Policy.

Cookie retention periods vary depending on the type of cookie. Session cookies are deleted when you close your browser. Persistent cookies remain on your device for a set period, as specified in our cookie consent platform, or until you delete them. 

We may also use web beacons in promotional emails and other communications with you, to allow us to count how many people read them and to verify any clicks through to links within an email. We (or our marketing service providers on our behalf) use this to help us understand how an email campaign performed, what types of emails and content our recipients find interesting, and what actions our recipients took, so we can improve our email campaigns in the future and make our emails more relevant to our recipients. If you do not wish the web beacon to be downloaded onto your device, you should select to receive emails from us in plain text rather than HTML.

How we store, transfer and process personal data

All information you provide to us is stored on secure servers. Information may be transferred, stored and processed by third parties (see below). It may also be processed by staff operating outside the United Kingdom and the European Economic Area (“EEA”) who work for us or for one of our suppliers of services, such as data processors or providers of back up services.

You should be aware that in territories outside the United Kingdom and the EEA, laws and practices relating to the protection of personal data are likely to be different and, in some cases, may be weaker than those within the United Kingdom and the EEA.  We will only transfer your personal data outside the United Kingdom and the EEA where we have a lawful basis to do so and where appropriate safeguards are in place to protect your data.

Such transfers outside the EEA will only take place where either (i) the European Commission has issued an 'adequacy decision' determining that such third country ensures an adequate level of protection; or (ii) we have provided appropriate safeguards, and on the condition that enforceable rights and effective legal remedies are available for you.

Such transfers outside the UK will only take place where either (i) the UK’s Information Commissioner’s Office has decided that such third country ensures an adequate level of protection; or (ii) we have provided appropriate safeguards, and on the condition that enforceable rights and effective legal remedies are available for you.

Inter-entity safeguards have been placed between WisdomTree and its parent company in the United States under the EU-U.S. Data Privacy Framework and the UK Extension to the EU-U.S. Data Privacy Framework, and/or by implementing Standard Contractual Clauses and the UK's International Data Transfer Agreement (IDTA) as appropriate to ensure all internal personal data transfers are compliant with the GDPR.

If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services. By submitting your personal data, you agree to the potential transfer, storing and other processing described above. We will take all steps reasonably necessary to ensure that your personal data are treated securely and in accordance with this Privacy Policy.

Use of third parties

Communicating via the internet and sending information to you by other means necessarily involves your personal information passing through or being handled by third parties, but we do not sell or distribute without your permission your personal information to third parties for purposes of allowing them to market products and services to you.

We conduct due diligence on all key third party service providers with whom EU and/or UK personal data is being processed to ensure they can provide sufficient guarantees to implement appropriate technical and organisational measures in a manner that processing will meet the requirements of the GDPR and ensure the protection of your rights.

What safeguards we have in place

WisdomTree has implemented appropriate technical and organisational security measures to protect the personal data under our control from loss, misuse, alteration, or unauthorised access. These measures include data encryption, pseudonymisation where appropriate, access controls to limit access to personal data to authorised personnel, and regular staff training on data protection. As no data transmission over the internet can be guaranteed as 100% secure, we cannot ensure or warrant the security of any information you transmit to us and you transfer the data at your own risk. We endeavor to use appropriate security measures, including security systems, backups, business recovery and breach notification procedures, and regular monitoring and testing of our security measures. In the event of a personal data breach, we have procedures in place to assess the risk and, where required, notify the relevant supervisory authority and affected individuals in accordance with our legal obligations.

Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Site and accordingly any transmission is at your own risk. However, once we have received your information, we will use all appropriate procedures and security measures to try to prevent unauthorised access to or disclosure of your personal data.
 
Data governance

We integrate 'data protection by design and by default' into our data processing activities. This means we consider data protection and privacy issues upfront in everything we do. For any new processing that is likely to result in a high risk to individuals' rights and freedoms, we carry out a Data Protection Impact Assessment (DPIA) to identify and mitigate risks. We also commit to adhering to approved codes of conduct and certification schemes where applicable to demonstrate our compliance with the GDPR.

What rights you have with regards to your personal data we process

Under the GDPR, you have several rights concerning your personal data. To exercise any of these rights, please contact WisdomTree using the details in the 'Contact Information' section. We may need to verify your identity before processing your request.

• Right to Access: You have the right to request a copy of the personal data we hold about you.
• Right to Rectification: You have the right to have any inaccurate or incomplete personal data we hold about you corrected.
• Right to Erasure ('Right to be Forgotten'): You can request the deletion of your personal data where there is no compelling reason for its continued processing. Please note that this right is not absolute and may be subject to legal and regulatory retention requirements.
• Right to Restrict Processing: You have the right to block or suppress the processing of your personal data in certain circumstances.
• Right to Data Portability: You have the right to obtain and reuse your personal data for your own purposes across different services.
• Right to Object: You have the right to object to processing based on legitimate interests or for direct marketing purposes. If you object to direct marketing, we will stop processing your data for this purpose immediately.
• Rights in relation to Automated Decision-Making and Profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects on you. We do not currently engage in such automated decision-making.

Your rights to access, rectify, erase or restrict your personal data stated above will be processed by WisdomTree usually within 30 days of receiving your request. However, WisdomTree may notify you within such timeframe of an increased time period to process your request and its reason. Where WisdomTree believes the request is unreasonable it shall notify you and refuse to process your request.

Our Site may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites may have their own privacy policies and that we do not accept any responsibility or liability for these policies or the treatment of your personal data by any third parties. Please check these policies before you submit any personal data to these websites.

Complaints

If you are not satisfied with our response to a request or believe your personal data has been processed by WisdomTree in a way that does not comply with the GDPR, you have the right to lodge a complaint with us directly or with a supervisory authority following our Complaints Procedure. 

If you believe WisdomTree did not take action on a request you have sent; or informed you without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy, you have the right to lodge a complaint with a supervisory authority.

The relevant supervisory authorities are:

• For the UK: The Information Commissioner’s Office (ICO). Details are available at www.ico.org.uk.
• For Ireland: The Data Protection Commission (DPC). Details are available at www.dataprotection.ie.

Governing law and jurisdiction

This legal notice and all issues regarding our Site are governed by English and Irish law (as applicable) and are exclusively subject to the English and Irish Courts (as applicable).

Contact information

If you have any questions regarding this Privacy Policy and our privacy practices you can contact us via email at [email protected] or by contacting us:

Contact details if you are based in the UK: 
WisdomTree UK Limited, 16 Dufour's Pl, London W1F 7SP, UK Tel: +44 20 7448 4330; Email: [email protected]

Contact details if you are based in the European Union:
Wisdomtree Ireland Limited, 16 Fitzwilliam Place, Dublin, D02 FF82, Ireland Tel: +353 1800 000 036; Email: [email protected]
 
Changes to this Privacy Policy

This Privacy Policy is dated as of October 2025. 

This Privacy Policy is reviewed annually to ensure accuracy and compliance with current regulations. We commit to updating this policy whenever there are material changes to our data processing practices.

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