PRIVACY POLICY
Introduction
Our corporate websites www.wisdomtree.eu and etfs.wisdomtree.eu (together referred to as the “Site”) are owned by the WisdomTree group which includes WisdomTree Europe Ltd, WisdomTree UK Limited and WisdomTree Ireland Limited (collectively “WisdomTree”). 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 Internet Browsing and Cookies Policy) discloses our information gathering and dissemination practices. We reserve the right to modify this Privacy Policy and the Terms and Conditions at any time.
WisdomTree 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 ((EU) 2016/679) ("GDPR") and any implementing legislation, including the Data Protection Act 2018 (UK) and the Data Protection Act 2018 (Ireland) ("Data Protection Legislation").
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, 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 endeavour to ensure you have the opportunity to read this Privacy Policy when processing your personal data.
The personal information we may collect might include your name, address, email address, company details and any other relevant information that may be included within correspondence. 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. Also, for legal reasons, in order to access our Site, details of your investor type, and location will be collected, with such collection being carried out in compliance with the Privacy and Electronic Communications Regulations (“PECR”). This data would be collected to customise our users’ visits to our Site.
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 and personalise 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 Internet Browsing and Cookies Policy [link].
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, 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.
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. If you ask for your personal data to be removed, we may still keep it in our records for 5 years to comply with regulatory requirements and will proceed to delete it afterwards provided there is no other reason which makes it necessary for us to keep the personal data (e.g. an investigation or pending Court case). You would not be contacted or receive any marketing materials during such period.
Internet browsing, cookies, and Google Analytics
The types of personal data that may be collected through our Site include: IP address, name, address, email address and telephone number. Additionally, if you are accessing parts of this Site that are password protected, then once you submit your password and enter, this Site will recognise 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 PECR and the Data Protection Legislation. We will collect cookies for compliance reasons (e.g. to know if you are a qualified investor or not, in which language you should see the Site, etc., “Necessary Cookies”); and may collect further cookies to enhance your Site and customer experience (for performance and targeting purposes, e.g. providing you with the most relevant content based on your activity, “Enhancement Cookies”). We will always ask for your consent for the use of Enhancement Cookies and give you an option to opt-out of such Enhancement Cookies if you would prefer these cookies not being collected. You can always change your approach at any time. More information about the cookies we collect and their purpose can be found on our Internet browsing and Cookies Policy mentioned above.
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 European Union (“EU”) 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 European Economic Area (“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 EEA. By submitting your personal data, you are agreeing to this transfer, storing or processing.
Such transfers outside the EU will only take place where either (i) the Commission 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 to ensure all internal personal data transfers are compliant with Data Protection Legislation.
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 have also reviewed all key third party agreements where EU personal data is being processed to ensure they are compliant with Data Protection Legislation and that your rights described herein are being protected.
What safeguards we have in place
WisdomTree has security measures in place to protect the loss, misuse and alteration of the information under our control. 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 endeavour to use appropriate security measures, including systems security, backups, business recovery and breach notification procedures, monitoring and testing procedures.
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.
What rights you have with regards to your personal data we process
You have the right to access your personal data and request a copy of the information held by us about you. You also have the right to ask for your information to be transferred to another organisation or to yourself. Where such requests are manifestly unfounded or excessive, we will inform you and we may charge a reasonable fee or refuse to respond to such a request.
You have the right to ask us not to process your personal data for marketing purposes. We will inform you if we intend to use your personal data for such purposes. You can exercise your right to prevent such processing by contacting us directly. You can also exercise the right and change your marketing preferences or restrict any specific uses of your personal data at any time by contacting us.
The accuracy of your information is important to us. We review information we hold to ensure it is up to date and accurate. You have the right to correct any inaccuracies in the details we hold about you – if you change your email address or notice any other information we hold is inaccurate or out of date, please contact us. You have the right to obtain without undue delay the rectification of any inaccurate personal data concerning you.
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 believe your personal data has been processed by WisdomTree in a way that does not comply with the Data Protection Legislation, you have the right to lodge a complaint with us directly or with a supervisory authority.
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.
Governing law and jurisdiction
This legal notice and all issues regarding our Site are governed by English law and are exclusively subject to the English courts.
Contact information
If you have any questions regarding this Privacy Policy and our privacy practices you can contact us via email at GDPR@wisdomtree.com or in writing to Compliance, WisdomTree UK, 3 Lombard Street, London, EC3V 9AA or Compliance, WisdomTree Ireland Limited, The Brickhouse, Block 1, Clanwilliam Court, Mount Street Lower, Dublin D02 CF97.