Privacy policy

This Privacy Policy explains how VettaFi LLC and its affiliates (collectively, “VettaFi,” “we,” or “us”) collects, uses, and discloses information about you. This Privacy Policy applies when you use our websites including etftrends.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.

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, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

If you are located in the European Economic Area (“EEA”), the term “personal data” as used in this Privacy Policy means any information relating to you and by which you are identified or can be identified, such as your name, contact details, email address, log-in data, or bank account details.

We also collect, use, and disclose aggregated or deidentified data that does not identify you or your device and is not subject to this Privacy Policy.

Personal Information You Provide

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 products you have purchased, returned or are considering purchasing from us.

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.

Automatically Collected Information

We automatically collect personal information when you access and use our Services, 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 we deploy on our Services.

Device and Usage Information: We may collect information about the devices and computers you use to access our Services such as browser type, language, operating system, the referring web page, pages visited, and hyperlinks clicked. When you visit our Services, we collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Services and other information about your internet activity.

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 your browsing behavior and past purchases.

Cookies and Other Tracking Technologies

We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. 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 collect information about you from identity verification services, advertising networks, marketing service providers, data analytics providers, and mailing list providers.

How We Use Your Information

We use the information we collect to administer your account, to deliver the products and services you request, and to customize your experience with us. We also use the information we collect to:

• Provide, maintain, and improve our products and 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;
• We share your Personal Data with sponsors of our virtual events who may also contact you with their own materials;
• Send you technical notices, security alerts, and support and administrative messages;
• 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 LLC 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 LLC 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.

How We Share Your Information

We share personal information with 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);
• 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 LLC, 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 LLC Family. Between and among VettaFi LLC and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
• With your consent or at your direction.

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 LLC 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/.

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.

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.

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

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.

Your California Privacy Rights

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.

California Consumer Privacy Act

The CCPA affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you. In the preceding 12 months, we have collected the following categories of personal information: identifiers, characteristics of protected classifications under California or federal law, commercial information, payment information; Internet or other electronic network activity information, geolocation data, professional or employment-related information, and inferences. For examples of the precise data points we collect and the categories of sources of such information, please see Collection of Information above. We collect personal information for the business and commercial purposes described in Use of Information above. We do not share personal information with third parties who sell or use the information for their own purposes. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients.

VettaFi LLC does not sell your personal information. We do allow our advertising partners to collect certain device identifiers and electronic network activity via our Services to show ads that are targeted to your interests. To opt out of having your personal information used for targeted advertising purposes, please see the Advertising and Analytics  section above.

Choices for Access, Deletion, Opt-Out of Sale, and Right to Non-Discrimination

If you are a California resident, you have the right to know what personal information we collect, use, disclose and “sell” about you (as that term is used in the CCPA). Additionally, you have the right to access, delete and opt-out from the “sale” of your personal information.

Subject to certain limitations, you have the right to: (1) request to know more about the categories and specific pieces of personal information we collect, use, disclose and sell, (2) request deletion of your personal information, (3) opt out of any “sales” of your personal information that may be occurring, and (4) not to be discriminated against for exercising these rights. You may make these requests by emailing us at privacy@etfflows.com and indicate which type of request(s) you would like to make. We will not discriminate against you if you exercise your rights under the CCPA.

To exercise these privacy rights and choices, please follow the instructions below:

• How to Request Access to Personal Information: You can obtain the personal information we collect and disclose by submitting a verifiable written request to us via email at privacy@etfflows.com.
• How to Request Deletion of Personal Information: You can request us to delete your Personal Information by submitting a verifiable written request to us via email at privacy@etfflows.com. Prior to deleting your personal information, we will send you an email or call you to confirm that you want your personal information deleted. Note, we may need to retain certain personal information as permitted by law, such as to complete the transaction for which the personal information was collected, provide a requested good or service, detect security incidents, protect against malicious, deceptive, fraudulent or illegal activities, comply with legal obligations or to enable solely internal uses that are reasonably aligned with your expectations or lawful within the context in which you provided the information.

Authorized Agents

If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us at privacy@etfflows.com.

Verification

We will verify your request by asking you to provide information related to your recent interactions with us, such as your email address, telephone number, credit card security code used for a purchase with us, and information regarding your purchases or inquires.

Some requests, including a request for specific pieces of personal information, may require a signed declaration under penalty of perjury from you that you are who you say you are. If you are requesting to obtain specific pieces of personal information regarding your household, each member of your household must provide the verification information above in order for us to verify their identities.

If we are unable to verify your identity, or we are prohibited from granting your request by law, we will deny your request and inform you that we cannot verify your identify and explain why we have no reasonable method to identify you. We will also direct you to our Privacy Policy which describes our general business practices regarding the collection, use, disclosure and sale of personal information.

Children’s Privacy Rights

VettaFi LLC does not knowingly collect, use, disclose, or sell personal information from children under the age of 16. If we are made aware that we have collected personal information from a child under 16 years old, we will delete this information as soon as possible.

Contact Us

If you have questions or concerns regarding this Privacy Policy, please contact us at privacy@etfflows.com or by mail at:

VettaFi LLC
1330 Ave of the Americas
New York, NY 10019 USA