This Privacy Notice applies to the State Street Global Advisors’ (“SSGA”) websites and any mobile app (collectively, our “Sites”). This Privacy Notice applies to any personal information we may collect from you through our Sites, independent of the device (i.e. mobile, computer) used to access our Sites.
Privacy on SSGA’s Sites
SSGA operates their Sites to provide you with tools and resources to help you learn more about us. When you visit our Sites we want you to feel confident that we are committed to maintaining the privacy of your personal information. By visiting our Sites, and/or using the services offered on or through our Sites (“Services”), you agree to the terms of this Privacy Notice (“Privacy Notice”), as they may be amended from time to time, and to SSGA’s collection, use, processing, and disclosure of your information as described below. SSGA may change this Privacy Notice at any time without prior notice to you. Any changes or updates will be effective immediately upon posting to our Sites.
What information we collect
We collect and process the personal information you provide to us when you:
- Register to use or use our Services via our Sites and provide information required to use our Services.
- Fill out forms on our Sites.
- Register or subscribe to our newsletters or conferences.
- Ask us to authenticate you as an authorized user and ask us to facilitate communications between us that you request.
- Contact SSGA with a request.
- Complete surveys issued by SSGA (we will process information provided by you for research and monitoring purposes).
SSGA also may collect your IP address and information regarding the computer or mobile device (“Device”) used to access our Sites, such as its operating system, unique identifier, and model name, as well as its user configurations and settings. And as discussed in detail below, we may also collect information relating to your use of our Sites and our Services.
We may combine the information that we collect through our Sites or Services with personal or other information that we obtain from third parties (such as social media networks or marketing partners) or that we collect from you in other contexts (such as when you email us, call us, or attend one of our events). If the information collected is about you or relates to you, or is combined with such information, SSGA will treat it as personal information.
Sensitive personal information
SSGA recognizes that certain jurisdictions have enacted laws that require higher protection of certain sensitive personal information. "Sensitive personal information" includes categories of personal data identified by European and other data privacy laws as requiring special treatment. This may include personal identity numbers, racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union or profession or trade association, physical or mental health, biometric or genetic data, sexual life, or criminal record (including suspected criminal activities). As a general rule, SSGA does not require such sensitive personal information from you.
In the limited cases where we do seek to collect such information, we will seek to do so in accordance with applicable data privacy law requirements. If you choose to provide us with unsolicited sensitive personal information, you consent to us using the information, subject to applicable law as described in this Privacy Notice.
Cookies and online tracking
SSGA may periodically collect information from you through automated means. When you browse our Sites, use the Services, or read our emails or newsletters, we may use "cookies" or other online tracking mechanisms in order to provide better service, facilitate your use of our Sites or Services, store online preferences, track usage of our Sites or Services, tailor the marketing of business services to our institutional customers, or enhance security.
What are cookies?
Cookies are text files containing small amounts of information downloaded to your computer or device when you visit a site. Cookies are then sent back to the originating site on each subsequent visit, or to another site that recognizes that cookie. Cookies are useful because they allow a site to recognize a user’s device. You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu.
Cookies do a lot of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and they generally improve the user experience. They can also help to ensure that the advertisements you see online are more relevant to you and your interests.
The cookies used on our Sites have been categorized on the basis of the categories found in the International Chamber of Commerce UK Cookie guide issued in April 2012. A list of the types of cookies used by SSGA is set out below.
Some of our cookies are used for web analytics and intelligence about our Sites. This information may be combined with other information for the purposes described below, including marketing. We may also use web beacons or other technologies for similar purposes and we may include these in marketing e-mail messages or our newsletters in order to determine whether messages have been opened and links clicked on. Web beacons do not place information on your device, but may work in conjunction with cookies to monitor online activity.
What if I don’t want cookies or website tracking of my activities?
By using our Sites you agree that we can place cookies on your device and use other online tracking mechanisms as explained in this Privacy Notice. If you want to remove existing cookies from your device, you can do this using your browser options. If you want to block future cookies being placed on your device, you can change your browser settings to do this. For more information on managing cookies and other tracking devices see www.allaboutcookies.org/manage-cookies.
Deleting and blocking cookies will have an impact on your user experience, as parts of our Sites may no longer work. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon you visit our Sites, even if you have previously deleted our cookies.
What types of cookies are there and which ones do our Sites use?
There are four types of cookies explained below. We use three of them on our Sites: Strictly necessary cookies, Performance cookies, and Functionality cookies. We do not use Targeting cookies on our Sites; however while on our Sites you may visit other sites and encounter them there.
Strictly necessary cookies - These cookies are essential in order to enable you to move around our Sites and use its features, such as accessing secure areas of our Sites. Without these cookies, services you have asked for cannot be provided.
We categorize the following cookies as strictly necessary:
- Registered Visitor Cookie - A unique identifier given to each registered user, used to recognize them through their visit and when they return to our Sites. (see also Functionality cookies below).
Performance cookies - These cookies collect information about how visitors use our sites, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is anonymous and is only used to improve how a site works.
We categorize the following as performance cookies:
- Referrer URL (internal page) - Used to store the URL of the previous page visited. Allows us to track how visitors navigate through our Sites.
- Referrer URL - Used to store the URL which refers a visitor to our Sites so we may understand what URLs are referring visitors to our Sites.
- URL history - Used to store the page visited by a user before that user submits a form. Also, used to display recently viewed articles to each visitor.
- Unregistered Visitor Cookie - A unique identifier given to each visitor to allow analysis on how unregistered visitors use our Sites.
- Session management cookies — These cookies allow us to follow the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close their browser window. Our session management cookies are created temporarily. Once you close your browser, our session management cookies are deleted.
Functionality cookies - These cookies allow a site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a site may be able to provide you with local information by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. We may use information collected from our cookies to identify user behavior and to serve content and information on products and services based on your profile. We may pass or share this information within SSGA or with affiliates for marketing or analysis purposes. In most cases we will not be able to track individuals by name; only if you are a registered user we can associate the cookie information with your name.
These cookies cannot track your browsing activity on other websites. They don’t gather any information about you that could be used for online advertising on other sites or remembering where you’ve been on the internet outside our Sites.
We categorize the following as functionality cookies:
- Recently viewed pages - Stores pages visited by the user on our Sites and displays them in right hand navigation for easy reference.
- Search history - Stores searches on our Sites conducted by the user and displays them for the user in the right hand navigation for easy reference.
- Registered Visitor Cookie - A unique identifier given to each registered user to our Sites, or each user who voluntarily provides personal information on our Sites to request information from us, used to serve them content and offers based on their profiles. Also used for analysis and marketing purposes (see also Strictly necessary cookies above).
Targeting cookies - These cookies are used to deliver online advertisements on other websites that are more relevant to you and your interests. They are also used to limit the number of times you see such advertisements as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the site operator’s permission. They remember that you have visited a site and this information is shared with other organizations such as advertisers. Quite often they will be linked to site functionality provided by the other organization.
Third party tracking
‘Do not Track’ disclosure
Do Not Track (DNT) is a technology standard that is currently under development that will allow you to restrict tracking when browsing from site to site on the Web. When you choose to turn on the DNT setting in browsers that support this feature, the browser sends an automated browser signal to the web sites and other web services (such as analytics services, advertising networks, and social platforms) you encounter while browsing to prohibit tracking.
At this time, SSGA does not recognize automated browser signals regarding tracking mechanisms, such as “do not track” requests.
How we use and share personal information
The information that we collect enables SSGA to provide you with access to our Sites and the Services you request, process online job applications, tailor the marketing of business services to our institutional customers, and further other purposes which we describe to you at the point where the information is collected. The purposes for which your information may be processed include but are not limited to the following:
- To offer you an enhanced, personalized online experience by enabling us to better tailor and personalize our Services.
- To authenticate you as an authorized user and to facilitate communications between us that you request.
- To fulfill your requests, including sending you white papers, newsletters and other supplements.
- To contact you for marketing purposes in-line with the applicable laws. (See the section below entitled “Marketing communications and your choices.”)
- To operate our business in a prudent manner in accordance with industry standards and applicable law, which may include, in addition to supporting the Services; responding to inquiries and requests; preventing fraud; and monitoring and archiving communications.
SSGA may disclose or share personal information to its affiliates for various purposes, as permitted by law, including in order for its affiliates to provide services.
SSGA may also share personal information with government agencies, exchanges, or other self regulatory organizations and law enforcement authorities as required or permitted by law, rule, regulation or legal process, including, without limitation, for governmental reporting or to enforce any rights SSGA may have against you as necessary. Personal information about you that is collected on our Sites, or in the course of the provision of Services, including any of your financial information, can become subject to the legal systems and laws in force in each state or country (a) where it is held, received or stored by you or us, (b) from where it is accessed by you or us, or (c) through which it passes. In addition, if you have an account at SSGA, because your account(s) may include information about more than one individual and about your business relations with SSGA and its affiliates, statements released to comply with legal process may contain information regarding your relationship with these individuals and with us and our affiliates.
SSGA may disclose your personal information (i) at the request of a bank or other regulatory agency or in connection with an examination of us by bank or other examiners; (ii) to our internal or external auditors or attorneys; (iii) when SSGA believes disclosure is necessary or appropriate to prevent physical harm or financial loss in connection with an investigation of suspected or actual illegal activity, or (iv) if disclosure is necessary to protect the vital interests of a person.
SSGA may disclose or share personal information to nonaffiliated third parties with whom it has contracted to perform services on its behalf. SSGA requires its third-party servicers to agree to comply with appropriate privacy and security standards or to undertake to provide similar and appropriate levels of protection as SSGA when processing personal information. In addition, SSGA may share personal information and other information collected through our Sites and the Services with a successor entity in the event of a merger, acquisition or similar transaction.
Marketing communications and your choices
SSGA uses information collected on our Sites to market business services to our institutional customers. Specifically, we may collect, use, and/or share your information with our affiliates and service providers in order to provide specific information that you request, thought leadership materials, industry information, invitations to events and webinars, and other communications or solicitations that we believe will be of interest to you. We target and tailor such communications based on your interaction with SSGA’s websites, mobile apps, and emails; your inquiries; your participation in events or webinars; relevant social media activity; and other third-party data. No client proprietary information, and no information about any of the individuals or entities that your firm may service, will be collected, used, or shared for purposes of delivering these communications to you. By voluntarily submitting your contact information on our Sites, you consent to the use and sharing of your information for such purposes. You may, however, opt out of receiving such marketing communications by clicking here or by following the opt-out instructions contained in each communication.
How we transfer and store personal information
SSGA is a global organization; personal information we collect may be transferred internationally throughout the world to countries where SSGA does business, which may not have the same data protection laws as the country in which you reside. We have internal policies and procedures in place in an effort to achieve an equivalent level of protection across our organization. The transfer of personal information to other countries is based on a business need or to comply with applicable laws. Personal information stored or processed in a foreign jurisdiction may be accessed under a lawful order made in that jurisdiction.
By providing your information to SSGA in the course of your access and use of our Sites or the Services, you agree that your personal information, for the purposes explained in this Privacy Notice, may be transferred to and stored in other countries where SSGA does business, which may not have the same data protection laws as the country in which you reside.
How we protect your personal information
We use security measures, in compliance with applicable law, to protect personal information from unauthorized access or use. Yet you should understand that the open nature of the Internet is such that information and personal information may flow, without security measures, over networks connecting you to our systems and may be accessed and used by people other than those for whom the data is intended.
To safeguard against unauthorized access to personal information by third parties, all electronic personal information held by SSGA is maintained on systems protected by secure network architectures that contain firewalls and intrusion detection devices. The servers holding personal information are “backed up” (i.e., recorded) on a regular basis in an effort to avoid any inadvertent erasure or destruction of such personal information and are stored in facilities with appropriate security and fire detection and response system.
When you contact SSGA with questions about our Sites or the Services, we must confirm your identity on the phone before discussing your information. The questions and answers you select when logging into our Sites for the first time are used for this identification process.
Our Sites may, from time to time, contain links to and from the sites of third parties. If you follow a link to any of these sites, please note that these sites have their own privacy notices or practices and that we do not accept any responsibility or liability for these notices, practices or sites. Please check these policies before you submit any personal information to these sites.
As a person who provides SSGA with personal information, you may inquire as to the nature of the personal information stored at and/or processed by SSGA. You will be provided reasonable access to your personal information held by SSGA and, where appropriate, with the ability to review and correct inaccuracies. SSGA will cooperate in providing such access. All such requests for access may be made by sending a request in writing to: http://www.spdrs.com/contact/index.seam
To help protect your privacy and provide security, SSGA takes reasonable steps to verify your identity before granting access to information. SSGA shall respond to such reasonable request made by you within such time period as required under applicable law after your identity has been confirmed and you have clarified the specific personal information that you require. If you demonstrate that the purpose for which the personal information is being processed is no longer legal or appropriate, the personal information will be deleted, unless the law or applicable data retention requirements require otherwise.
How to contact us
If you have questions or comments about this Privacy Notice, or about how your data is processed, please contact https://www.spdrs.com/contact/index.seam
Effective date: November 26, 2014