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eVestment Privacy Policy

Effective Date: May 25, 2018

eVestment, LLC and its affiliated entities (together, “eVestment”) are wholly-owned subsidiaries of Nasdaq, Inc.

As a global financial services and technology provider and self-regulatory organization, Nasdaq is committed to protecting Personal Information and complying with applicable privacy requirements in a trustworthy, transparent and responsible manner.

This Privacy Policy describes how eVestment and its subsidiaries and affiliates (collectively, “eVestment” “we,” “our” or “us”) collects, uses and discloses Personal Information about individuals (collectively, “users” or “you”) receiving our products and services, exploring or maintaining a business relationship with us (either directly or through an intermediary such as your employer) and/or using the eVestment websites, online features or mobile applications (each a “Site” or collectively, our “Sites”). As used in this Privacy Policy, Personal Information means any information relating to an identified or identifiable natural person; Personal Information is intended to cover all information subject to personal data processing and privacy laws applicable to our business.

The Privacy Policy also describes your rights, where applicable, and how to exercise them. You may contact us at any time with questions related to our Personal Information processing and privacy via email at privacy@evestment.com.

In some instances, we may post or provide materials that provide further description of Personal Information processing related to certain products and services. We may also post information about how we comply with specific Personal Information laws or regulations like European Union or United States privacy laws. Such materials are for informational purposes only and are not intended as an exhaustive listing of Personal Information processing related to the product and service. The materials should not be construed as modifying this Privacy Policy.

Brief Overview

Below is a summary overview of this Privacy Policy. This overview is not intended to be comprehensive; please review this entire Privacy Policy to understand how your Personal Information may be used by eVestment.

Information about how this policy applies to our global company

eVestment has endeavored to develop a Privacy Policy that can be applied consistently across its global organization; however, certain elements are limited to situations where applicable law requires them. With respect to your Personal Information, the data controller will be the eVestment entity delivering products and services or with whom you are interacting.

Situations where this Privacy Policy does not apply

This Privacy Policy does not apply to the extent that other Personal Information processing or privacy terms are set forth in the applicable contract for eVestment’s products or services, posted on a Site or in certain other situations.

Information we collect about you

We may collect Personal Information and Device Information (defined below) (collectively, “information”) about you in connection with: your (or your employer’s) receipt of products or services, including to fulfill our contractual obligations, or to establish or maintain a business relationship with you or your employer; your registration, use, purchase, or inquiries on or about our Sites that link to this Privacy Policy; the pursuit of our legitimate business interests; and/or to comply with applicable law.

How we use your information

We may use your information to: provide services; respond to inquiries and provide client support and technical assistance; communicate with you; improve, develop, provide content for, operate, deliver and market our products, service or Sites; implement social networking features; comply with our company policies and procedures and with applicable law; ensure proper and authorized use of the Sites; perform Site tracking and analysis; and as otherwise permitted by applicable law.

Automated decision-making

We do not process Personal Information for automated decision making in a manner that has legal or similarly significant effects on the individual.

How we share your information

We may share your information: with our business units, affiliates, subsidiaries, business partners, clients, service providers, and/or your representatives; when we believe necessary to protect or enforce our rights or the rights of another user; and as otherwise permitted by law. We do not sell or share information that you provide through our Site with non-affiliate third parties so that they can independently market their own products or services to you, unless we have explicitly given you the option to opt-in to such disclosures.

Your rights regarding your information

We provide you with the opportunity to be informed of whether we are processing your information and to access, correct, update, oppose, delete, block, limit or object, upon request and free of charge, to our use of your Personal Information to the extent required by applicable law.

Security of your information

We maintain commercially-reasonable technical, administrative and physical security measures to protect your information.

International transfers

We may transfer your information outside of your home country. To protect such information, any such international transfers will be made in accordance with applicable law.

Retention of your information

We retain your information to fulfill the purpose for which it was collected, comply with record retention requirements that apply to our business and where required to address legal or compliance matters affecting the information.

Cookies and similar technologies

We may use cookies and similar technologies to help deliver our products, services and Sites, offer you a more personalized user experience and market products and services to you.

Marketing communications

You can opt-out of receiving marketing communications from us.

Referrals

If you choose to refer an individual to learn about our products or services, to explore a business relationship with us or to use our Sites, we will ask you for the individual’s name and email address for us to send your friend a one-time email to invite him/her to access the specific Site.

Links to other websites

Our Sites may contain links to other websites or services that are not owned or controlled by eVestment or Nasdaq, including links to websites of our advertisers, sponsors and partners.

Use of Sites by children

Our Sites are not intended for use by children under the age of sixteen.

Changes to this Privacy Policy

You will be notified about any material changes to this Privacy Policy via a posting on our Sites, and as otherwise required by applicable law.

Contact us

If you have questions about this Privacy Policy, please contact us at privacy@evestment.com.



Information about How this Policy Applies to our Global Company

As a global organization, different eVestment entities, products/services and Sites may be subject to different privacy laws based on where our entity operates, where the products/services are delivered and/or where you are located. For example, the European Union General Data Protection Regulation imposes certain requirements on some eVestment entities or services that are not applicable to all of our entities or services. Where this Privacy Policy states that a provision applies “to the extent required by applicable law,” such provision will be applicable only to the extent that eVestment is subject to legal requirements imposing it.

For purposes of data protection laws, except where this Privacy Policy does not apply, as described below, the eVestment entity that will be the “controller” of your Personal Information will be the entity that delivers the products or services you (or the company for whom you are working or have a business relationship) are receiving or maintains the Site that you are using. You can identify the eVestment company that hosts a particular Site through the Site’s footer or “About” link. A list of eVestment’s different business locations is available at this site: www.evestment.com/contact/.

Although your data controller may be a specific eVestment entity, contact and other client relationship information that we collect may be held in a client relationship management or contact database which can be accessed by other eVestment or Nasdaq entities which may be located globally; further information about international transfers of information is provided below. To the extent required or permitted by applicable law, by visiting or using our Sites, you are consenting to us collecting and processing information about you in accordance with this Privacy Policy.



Situations where this Privacy Policy Does Not Apply

This Privacy Policy does not apply to Personal Information processed in connection with delivery of services to eVestment by suppliers or contractors; such relationships are governed solely by the Personal Information processing terms and conditions between eVestment and the supplier/contractor. It also does not apply to job applicants or employees, which are subject to relevant privacy notices.

This Privacy Policy also does not apply to the extent that:

  • eVestment’s contract for delivery of products or service prescribes different terms and conditions for the processing of your Personal Information;
  • eVestment is delivering products or services as a data processor, in which case the contractual terms and conditions between eVestment and the data controller/contracting party shall govern;
  • The Site for the products or services sets forth an additional or alternative Privacy Policy; or
  • Applicable law imposes different processing or privacy requirements on your Personal Information.



Information We Collect from You or Your Representative

We only collect information from you or your representative (such as your employer) or about you that is reasonably necessary for us to provide the relevant product or service, business relationship and/or communication, consistent with the nature of such product, service, relationship or communication. Based on the specific products, services, business relationship or Sites involved as well as requirements under applicable law, we may collect the following categories of personal information (“Personal Information”) from you or your representative:

  • Name;
  • Email address;
  • Social media username;
  • Telephone number;
  • Mailing address;
  • Company;
  • Title or Position;
  • Business contact information;
  • Employment Status;
  • Career or professional history, educational background and professional qualifications;
  • Your recorded voice (when you are advised in advance of the recording);
  • Photograph;
  • Username and password; and
  • Any other Personal Information you or your representative volunteers on or provides access to via any or our Sites and/or any eVestment or Nasdaq community forum, social media offering or blog.

We may also automatically collect the following categories of information from devices (e.g., mobile, computer, laptop, tablet) used to visit or use our Sites or that receive HTML-formatted email messages (“Device Information”):

  • IP address;
  • Device identifier;
  • Log files;
  • Cookies;
  • Clear gifs;
  • Pixel tags and similar technologies;
  • Flash LSOs; and
  • Other information as described in our Cookies Policy, available at www.evestment.com/cookie-policy/.

Certain Device Information may be deemed Personal Information in accordance with applicable law. Personal Information and Device Information are collectively referred to as “information.”

Information that We Collect About You

Based on the specific products, services, business relationship or Sites involved (as well as requirements under applicable law), we may collect the following categories of Personal Information on our own or from third parties about you:

  • Information about you available in news feeds, exchange data feeds and other public data sources (including the public internet);
  • Information provided by relevant regulators, government agencies and non-government credentialing or professional organizations;
  • Information related to your status under economic sanctions, anti-money laundering and similar laws or other information that may impact our ability to engage in business with you or a company at which you are an employee, officer or director, or significant shareholder;
  • Information that you, your employer or other representative make publicly available via your personal or company website or in social media profiles;
  • Information related to your professional activities (such as consulting to public retirement funds) that is contained in documents released by a governmental body under Freedom of Information Act, State open records laws, Open Government License or similar laws and regulations;
  • Information from event organizers for events that you have attended;
  • Information from companies providing professional contact information to their customers/subscribers; and
  • Other Personal Information to the extent permitted by applicable law and reasonably necessary for the performance of our business obligations, compliance with laws applicable to our business or pursuit of our legitimate business interests.



How We Use Your Information

The following is an overview of eVestment’s purposes for processing Personal Information. Often due to the nature of the product or service involved or the context in which the Personal Information is used, it will be apparent how we intend to use the information. Additional information about processing related to a particular product or service may be separately posted on the relevant Site or contained in the applicable terms and conditions.

We may use the information we collect for the purposes identified below. To the extent required by applicable law, each purpose for the processing of Personal Information is substantiated by one or more lawful bases for processing. Unless otherwise identified with respect to a particular product or service, our processing is done based on one or more of the following:

Purpose of ProcessingBases for Processing
Provide you (or your employer/represented company) with our services and products and communicate with you about your (or your employer’s/represented company’s) account or use of our products, services and/or Sites
  • Perform or enter into a contract
  • Legitimate business interests
  • Comply with a legal obligation
  • Consent
Monitor for security threats and fraud involving the use of our products, services, Sites or physical facilities
  • Legitimate business interests
  • Comply with a legal obligation
Register or establish an account for you (or your employer/represented company) as a client
  • Perform or enter into a contract
  • Legitimate business interests
  • Comply with a legal obligation
Register you (or your employer/represented company) to receive services or information through one or more of our Sites
  • Perform or enter into a contract
  • Consent
To the extent permitted by applicable law, identify you (or your employer/represented company) as a prospective client for products or services and provide you with relevant information and/or invitations to events
  • Legitimate business interest
  • Consent
Manage our relationship with you (or your employer/represented company) as a client, business prospect and/or information recipient
  • Perform or enter into a contract
  • Legitimate business interest
  • Consent
To pursue or enforce our legal rights related to our business, products, services or Sites and/or defend against claims made against us
  • Perform or enter into a contract
  • Legitimate business interest
Communicate with you (or your employer/represented company) about your (or your employer’s/represented company’s) account or use of our products, services or Sites
  • Perform or enter into a contract
  • Legitimate business interest
  • Consent
Create informational materials and statistical extracts for our products and services
  • Perform or enter into a contract
  • Legitimate business interest
  • Consent
Develop, provide content for, operate, deliver, and market our products, services and Sites
  • Perform or enter into a contract
  • Legitimate business interes
  • Consent
Improve the quality of our Sites and tailor them to your preferences
  • Legitimate business interest
  • Consent
Implement social networking features you have activated (e.g., Facebook “Like” button and LinkedIn integration)
  • Consent

With respect to situations where we process Personal Information based on our legitimate business interest, reflecting that we are generally a business-to-business product and service provider, we typically collect and process limited Personal Information about corporate client points of contact and individuals acting in their professional capacities as part of our overall effect to reduce the privacy impact on individuals. To the extent required by applicable law, you have the right to object to our processing of your Personal Information where the legal basis for our processing is a legitimate interest. Where our processing of your Personal Information is based on your consent, you have the right to withdraw your consent at any time. Click here to learn more.

We also use your information for compliance with our company policies and procedures, for accounting and financial purposes, and otherwise as required or permitted by applicable law. If you do not provide us with information as described above, we may not be able to fulfill the applicable purpose of collection, such as completing a contemplated transaction, responding to your queries or providing access to our Sites to you.



Automated Decision-Making

eVestment does not engage decision-making based solely on automated processing of Personal Information, including profiling, which produces legal effects concerning an individual or similarly significantly affects an individual.



How We Share Your Information

From time to time, to the extent permitted by applicable law and subject to any contractual limitations on sharing Personal Information set forth in a relevant contract for products and services, we may share your information with our affiliates, subsidiaries, business partners, clients (such as where we process your Personal Information in connection with your role with your employer), third party service providers and authorities in the following circumstances:

  • Affiliates, Subsidiaries, Business Partners and Clients. We may share your information with our affiliates (including other Nasdaq business units), subsidiaries, business partners, and clients in the US and worldwide for purposes identified above. A list of eVestment offices by country is posted at https://www.evestment.com/contact/. A list of Nasdaq’s offices by country is posted at http://business.nasdaq.com/discover/nasdaq-locations/index.html. To the extent required or permitted by applicable law, by visiting or using our Sites or otherwise providing us with your information, you consent to this sharing of your information. Where such consent exists, to opt-out of such sharing, please contact us via email at privacy@evestment.com or at the location in the Contact Us section below.
  • Service Providers. We may share your information with third parties who perform functions on our behalf (e.g., hosting or operating our services or Sites, sending email marketing communications, or data analysis). We do not authorize these third parties to use your information for purposes other than for which it has been provided, and we do not authorize these third parties to disclose that information to unauthorized parties. We require these third parties to maintain appropriate security to protect your information from unauthorized access or processing.
  • As Required or Appropriate by Law. We may disclose your information to regulatory authorities, courts, and government agencies where we believe that doing so would be in accordance with or permitted or required by any applicable law, regulation or legal process, to defend the interests, rights, and/or property of eVestment, Nasdaq or others, or to respond to emergencies.
  • Business Transfers. We may transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets. To the extent permitted by applicable law, we may share information with a prospective buyer or transferee of the business as part of the diligence process provided that we require any such third party to maintain the confidentiality of your information and protect it with appropriate technical and organizational security measures.

We may share your information with other third parties as directed by you or subject to your consent. We may also share and otherwise process aggregated information or de-identified information that does not identify you individually with other third parties. We also use this aggregated or de-identified information for eVestment’s and its affiliates’ various business purposes, including the creation and sale of other products and services to our clients and potential clients. This aggregate or de-identified information is not traceable to any particular client or user and will not be used by a third party to contact you.

We do not share, sell, rent or trade the personal information you provide through our Site to our service providers or business partners for their own direct marketing purposes, unless we have explicitly given you the option to opt-in or opt-out of such disclosures. The foregoing restriction does not apply to information provided by those firms voluntarily contributing data for inclusion in our databases and other data products. For more information on data contribution, please click here.



Marketing Communications

We process Personal Information within the scope of our marketing and market segmentation. With market segmentation, we mean that we categorize our client base based on professional affiliations and functions, alignment with our services and products and information gathered from public sources of information. For clients or users of our Sites, we may also use information gathered from your use of our products, services and/or Sites for marketing purposes.

You always have right to request that we stop using your Personal Information for direct marketing purposes. To the extent required by applicable law, you have the right to object to the processing of your Personal Information based on a legitimate interest as legal basis. You also always have the right to withdraw your consent at any time when we need your consent in order to process your Personal Information. If you withdraw your consent, you will no longer receive information and offers that are tailored for you. Click here to learn more.

If you no longer wish to receive marketing communications from eVestment, you may opt-out of receiving marketing-related emails by: (1) using the unsubscribe method provided in our communications; and (2) updating your preferences in the “Manage Preferences” section of our Sites (which is also included as a link in our communications). You also have the right to object our use of your personal information for direct marketing and in certain other situations (in accordance with applicable law) by contacting us at privacy@evestment.com. If you are having difficulty unsubscribing from our email marketing communications using the above methods, please contact us as at privacy@evestment.com.

We will try to comply with your request as soon as reasonably practicable as required by applicable law. Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law. In addition, please note that even if you opt-out of receiving marketing communications from one or all of our Sites, we may need to send you service-related communications.



Your Rights Regarding Your Personal Information

To the extent required by applicable law, in our capacity as the controller of your Personal Information, we will also provide you with the opportunity to be informed of whether we are processing your Personal Information and at any time to access, correct, update, oppose, delete, block, limit or object to our use of your Personal Information. The foregoing rights will be afforded to you free of charge (except to the extent that your requests are manifestly unfounded or excessive, in which case, we may charge an administrative fee or refuse to meet your request). Please note that legal obligations that apply to our business may prevent us from immediately deleting parts of your information. To exercise your rights, please contact us as detailed below.

To prevent fraudulent activity, we may require you to authenticate your identity when you contact us. We will try to comply with your request as soon as reasonably practicable and within timeframes required by applicable law. Please note that in some instances, due to the nature of the information that we receive, we may require you to provide additional information that will help us identify which information is yours. For requests subject to the European General Data Protection Regulation, we will respond to your request within one month of our receipt of it. We may extend this period by two further months taking into account the complexity of your request or the number of requests that we have received; we will inform you of any such extension within one month of receiving your request along with the reasons for the delay and information about your right to file a complaint with the supervisory authority.

The following sets out a summary of your rights to the extent that your Personal Information is processed subject to the European General Data Protection Regulation:

  • Right to access, rectification, erasure and restriction of processing. You have the right to request:
    • Access to your Personal Information. This means that you have the right to request information on our use of your Personal Information. You also have the right to request a copy of the Personal Information being processed at no cost. However, we may charge you a reasonable administrative fee to provide you with additional copies of the Personal Information. If you make your access request by electronic means such as email, we will provide you with the information in a commonly used electronic format.
    • Rectification of your Personal Information. We will at your request, or at our own initiative, rectify, anonymize, erase or complement Personal Information that you or we discover is inaccurate, incomplete or misleading. You also have the right to complete the Personal Information with additional data if relevant information is missing.
    • Erasure of your Personal Information. You have the right to request that we erase your Personal Information if we no longer have an acceptable reason for processing the data. Given this, erasure shall be made by us if:
      • the Personal Information is no longer necessary for the purposes for which it was collected;
      • we use your Personal Information with your consent and you withdraw your consent;
      • you object to the processing of your Personal Information based on our legitimate interest and there is no overriding legitimate ground for the processing;
      • the Personal Information has not been lawfully processed;
      • we are required to erase the Personal Information due to a legal obligation; or
      • you are a child and we have collected the Personal Information in relation to the offer of information society services.
        However, there might be requirements under applicable law, or other compelling reasons, that prevents us from immediately erasing your Personal Information. In such case, we will stop using your Personal Information for any other reasons than to comply with the applicable law, or the relevant compelling reason.
    • Right to restrict processing: This means that we temporarily restrict the processing of your Personal Information. You have the right to request restriction of the processing when:
      • you have requested rectification of your Personal Information in accordance with this Privacy Policy, during the period of time we are verifying the accuracy of the data;
      • the processing is unlawful and you do not want the Personal Information to be erased;
      • as data controller, we no longer need the Personal Information for the purposes for which it was collected, but you require us to retain the information for the establishment, exercise or defense of legal claims; or
      • you have objected to our legitimate interest for the processing in accordance with this Privacy Policy, during the period of time that we are determining whether the legitimate interest overrides your privacy rights.
  • Right to object to processing. You have the right to object to the processing of your Personal Information based on our legitimate interest. If you object to such processing, we will only continue with the processing if we have a compelling legitimate reason for the processing that outweighs your interest, rights or freedoms, or if continued processing is necessary for the establishment, exercise or defense of a legal claim.
  • Right to portability. You have the right to receive certain of your Personal Information in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller. You only have this right when your Personal Information is processed by automated means and our legal basis for the processing is performance of a contract between you and us.
  • Right to lodge a complaint. You have the right to lodge any complaints regarding our processing of your Personal Information with the supervisory authority.



Security of Your Information

We take reasonable technical, administrative and physical security measures to protect your information, including applying generally accepted industry standards to protect the information submitted to us during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure, so we unfortunately cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), please contact us immediately as detailed under the “Contact Us” heading below.



International Transfers

Some of the parties with which we may share your information, as detailed in “How We Share Your Information”, may be located in countries that do not provide an equivalent level of protection as your home country. Where required, eVestment has implemented appropriate cross-border transfer solutions to provide adequate protection for transfers of certain personal information, including, but not limited to, the European Commission’s Standard Contractual Clauses (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en). To the extent permitted by applicable law, by using our Sites, and providing us information about you, you consent to the international transfer of information about you to the above parties.



Retention of Your Information

We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy and as otherwise needed to comply with applicable law and recordkeeping requirements or to address any complaints, challenges, legal or compliance matters related to the information.



Cookies and Similar Technologies

When you use our Sites, we along with our affiliates, subsidiaries and third party service providers may use “cookies” and similar technologies (e.g., log files, clear gifs, pixel tags and Flash LSOs) (collectively, “technology”). This technology may involve placing small files/code on your device or browser that serve a number of purposes, such as remembering your preferences (e.g., language) and generally improving your experience on our Sites. Specifically, we may use such technology for purposes such as to:

  • Provide us with general analytics about our Sites, including demographic information in a non-identifiable form, in order to improve our Sites’ performance and customize users’ experience;
  • Enable us to help you make better use of our services or Sites such as by suggesting how you can improve your use of different features or functionality or help address technical issues that you encounter in using our services or Sites;
  • Support security measures, such as requiring re-login into your account or additional authentication when using a new device to access our Sites;
  • Measure the success of our marketing campaigns and compile statistics about the Site’s usage and email response rates;
  • Allow you to engage in our social media offerings on our Sites (e.g., Facebook “Like” button and LinkedIn integration); and
  • More effectively market our Sites and advertise other Sites that may be of interest to you.

To learn more about the technology used on our Sites and how to disable some of the technology, visit our more comprehensive Cookie Policy at https://www.evestment.com/cookie-policy/. Where required by law, we collect your consent for the use of such technologies.



Referrals

If you choose to use our referral service to tell someone about our products or services or Sites, we will ask you for your friend’s name and email address. We will send your referral a one-time email to invite him/her to access the Site or with information about the product or service, and store his/her email address for the sole purpose of sending this one-time email and tracking the success of our referral program. Your referral may contact us as detailed under the “Contact Us” heading below to request we remove this information from our database.


Links to Other Websites

Our Sites may contain links to other websites or services that are not owned or controlled by eVestment or Nasdaq. This Privacy Policy only applies to information collected by our Sites. We have no control over third party websites, and your use of third party websites and features are subject to privacy policies posted on those websites.

We may use third party payment services to process purchases made through the Sites. If such service is made available and you wish to make a purchase through the Site, your Personal Information may be collected by the third party (and not by us). In that case, the information you provide to the third party will be subject to that third party’s privacy policy and not this Privacy Policy.

We are not responsible or liable for the privacy or business practices of any third party websites linked to our Sites. Your use of third parties’ websites linked to our Sites is at your own risk, so we encourage you to read the privacy policies of any linked third party websites when you leave one of our Sites.



Use of Sites by Children

None of our Sites are targeted for use by children under the age of sixteen. We do not target any of our products or services or Site content/features for use by children of such age.



Changes to this Privacy Policy

Except to the extent limited by applicable law, we reserve the right to update this Privacy Policy to reflect changes to our information practices by prominently posting notice of the update on our Sites. To the extent practical, we will provide advance notice of any chances; however, we may be unable to do so if the revisions are in response to legal or regulatory changes or guidance.



Contact Us

If you have any questions about this Privacy Policy or information we have collected about you, please contact us by email at privacy@evestment.com or by postal mail at:
General Counsel – Privacy Request
eVestment Alliance, LLC
100 Glenridge Point Parkway
Atlanta, GA 30324

Office of General Counsel – Privacy Team
Nasdaq, Inc.
805 King Farm Blvd
First Floor
Rockville, MD 20850

Office of General Counsel – Stockholm Office
Tullvaktsvägen 15
10578 Stockholm
Sweden

With respect to Personal Information processing subject to European Union jurisdiction, in addition to contacting our business contacts and Data Protection Officer (for our EEA Regulated Businesses), you may also contact a data protection supervisory authority. Within Europe, Nasdaq’s headquarters is located in Sweden, making the responsible data protection supervisory authority:

The Swedish Data Protection Authority

Contact details:

Telefon: 08-657 61 00
E-post: datainspektionen@datainspektionen.se
Fax: 08-652 86 52
Postadress:
Datainspektionen
Box 8114
104 20 Stockholm

eVestment Alliance Terms of Service

Date last revised: 7/1/2011

Welcome to the website of eVestment Alliance, LLC (“eVestment Site”).Your use of the eVestment Site is subject to the following terms and conditions (“Agreement”).By registering, you (also referred to as “Member”) agree to the terms and conditions of the Agreement. PLEASE READ THE AGREEMENT IN ITS ENTIRETY BEFORE ACCEPTING ITS TERMS AND CONDITIONS.If you do not agree to be bound by this Agreement, you may not log onto the eVestment Site and may not use it.

ACCEPTANCE: By registering with and using the eVestment Site, you acknowledge that you have read and agree to all terms, conditions contained or referenced in this Agreement. We reserve the right, at our discretion, to update or revise this Agreement at any time. eVestment Alliance also reserves the right to change the terms and conditions under which the eVestment Site and its many offerings are extended to the Member. Your continued use of the eVestment Site following the posting of any changes to the Agreement constitutes acceptance of those changes.Please check back often for changes as eVestment Alliance will not send notification of changes.The most recent revision date will be posted above.By accessing, viewing, or utilizing the products and/or services available on or through the eVestment Site, you indicate that you understand and recognize this Agreement to be the legal equivalent of a signed, written contract and equally binding.

  1. TARGETED MEMBERS: eVestment Alliance products and services are designed for the major participants in the institutional investment industry; including plan sponsors/pension funds, investment/asset/fund managers, hedge funds, fund-of-funds, investment consultants, financial advisors, investment banks, endowments & foundations, and third-party marketing organizations.All data and content is targeted to the institutional investment community.
  2. NATURE OF EVESTMENT SITE : The eVestment Site is designed to serve as an informational source on institutional money managers as well as various other institutional investment oriented content.Information is intended for educational and research purposes ONLY. eVestment Alliance does NOT provide investment advice nor give recommendations on the suitability of an investment manager or their respective investment funds.Accordingly, eVestment Alliance assumes no responsibility or liability for any investment decisions made or services rendered by any institutional money manager or vendor, or any other entity featured on the eVestment Site. We do not specifically endorse any of the investment managers and/or vendors on the eVestment Site. eVestment Alliance recommends seeking the advisement of an independent advisor before making an investment decision.Additional due diligence may be necessary before making an investment decision and should be based on a case-by-case basis depending on the circumstances. eVestment Alliance shall not be held liable for investment decisions made based on content provided through the eVestment Site.
  3. EVESTMENT SITE CONTENT: As stated, the content on the eVestment Site is intended for informational, research and educational purposes only.The data and information collected on investment managers has been obtained from sources believed to be reliable.It is of the utmost importance to strive for the highest level of data integrity, and while there are a variety of data validations and checks in place, eVestment Alliance cannot and does not guarantee accuracy or comprehensiveness of the eVestment Site. eVestment Alliance relies on the self-reporting of investment managers and eVestment Alliance does not independently verify or warrant data accuracy.You hereby acknowledge and agree that eVestment Alliance makes no claims with regard to accuracy on the part of either the investment managers, eVestment Alliance or the eVestment Site; that there may be delays, omissions or other inaccuracies in the information contained on the eVestment Site; and that such information may become unreliable because of changing market or economic situations.Any decisions made based upon information gathered herein may include incorrect information that may lead to results differing from the past. Before committing to any investment, seek the advice of an independent advisor. Past performance does not guarantee similar results in the future.
  4. REGISTERED MEMBERS: Members of the eVestment Site will consist of Plan Sponsors (i.e. corporate pensions, government pensions, foundations, endowments, hospitals, religious entities and other financial institutions), investment managers, financial advisors, consulting organizations and various other investment professionals whose business services the institutional investment industry.
  5. REGISTRATION AND ACCESS: Each Member will be required to register with eVestment Alliance prior to receiving a username and password to access the eVestment Site. Once registration is verified, the Member will receive a username and password granting access to the eVestment Site.By registering with eVestment Alliance, the Member agrees that all information provided is accurate and complete.The Member will have the ability to maintain the registration information and change the information as necessary.However, Members shall be solely responsible for the upkeep and security of the username and password.It is possible for anyone with knowledge of the Member’s username and password to view certain portions of the eVestment Site and modify information on the eVestment Site. The Member hereby agrees to keep all information confidential and notify eVestment Alliance if theft or any other breach of secure information occurs. eVestment Alliance reserves the right to grant or deny access to the eVestment Site to any Member and modify or delete a Member’s access at any time for any reason without notice or liability. eVestment Alliance will not be held responsible for damages incurred due to Member’s carelessness or noncompliance with the above statements.
  6. PRIVACY: eVestment Alliance is dedicated to protecting our Members’ privacy.Please refer to our Privacy Policy for a more complete description of our use of personal information.
  7. MEMBER CONDUCT: The Member hereby agrees not to use the eVestment Site or services in any way that is unlawful or prohibited by these terms and conditions.Unauthorized commercial uses of the eVestment Site, or the resale of eVestment Alliance’s services, is expressly prohibited. The content and software on the eVestment Site may only be used for the purposes intended by eVestment Alliance.Any other use, including the reproduction, modification, distribution, transmission, republication, display, or performance, of the content on the eVestment Site is strictly prohibited.The Member hereby agrees not to upload, post or distribute any content through the various mediums via the eVestment Site that:
    • restricts or inhibits any other user from using the eVestment Site;
    • is unlawful, threatening, abusive, harassing, defamatory, libelous, deceptive, fraudulent, invasive of another’s privacy, tortuous, obscene, vulgar, offensive, pornographic, profane, indecent, or contains explicit or graphic descriptions or accounts of sexual acts;
    • discriminates, victimizes, harasses, degrades, or intimidates an individual or group of individuals;
    • attempts to gain unauthorized access to the eVestment Site, network, server or other systems related to the eVestment Site;
    • constitutes unauthorized or unsolicited advertising, junk or Spam e-mail, chain letters, pyramid schemes, any other form of unauthorized solicitation, any form of lottery or gambling or any information, software or other material of a commercial nature;
    • contains viruses, corrupted files, or any other similar software or programs that may damage the operation of another’s computer;
    • collects or stores personal data about other Members;
    • violates, plagiarizes or infringes the rights of third parties including, without limitation, copyrights, trademark, patent, rights of privacy or publicity or any other proprietary right;
    • constitutes or contains false or misleading indications of origin or statements of fact; or
    • violates or encourages conduct that would violate any other applicable laws or regulation or give rise to civil liability.

    eVestment Alliance reserves the right at all times to edit, refuse to post or remove any information or materials, in whole or in part, that in eVestment Alliance’s sole discretion are objectionable or in violation of this Agreement.

  8. LINKS: eVestment Alliance may, at its sole discretion, offer links to websites of various vendors and providers of institutionally oriented services.As these websites are not maintained by eVestment Alliance, we do not guarantee or attest to the accuracy and completeness of the information obtained through these links.Accordingly, eVestment Alliance will not be held liable for decisions made based upon information on these linked websites.These links should not serve as an endorsement for any particular vendor’s capabilities or services, as we have no control over the quality, accuracy or comprehensiveness of the information obtained.As always, an independent advisor’s assistance should be sought before making an investment decision.
  9. COPYRIGHT AND TRADEMARK NOTICE: You hereby acknowledge and agree that all content and materials available on the eVestment Site are protected by copyrights, trademarks, service marks, patents, trade secrets, or other proprietary rights and laws. Except as expressly authorized by eVestment Alliance, you agree not to sell, license, rent, modify, distribute, copy, reproduce, transmit, publicly display, publicly perform, publish, adapt, edit, create derivative works from such materials or content, or in any manner commercially exploit any content or materials on/from the eVestment Site.You must abide by all copyright notices, information, or restrictions contained in or attached to any content or portion of the eVestment Site.“eVestment Alliance,” “eVestment” and the eVestment logo and any other logos or similar marks are trademarks and service marks of eVestment Alliance.All other trademarks, service marks and logos used in the eVestment Site are the trademarks, service marks or logos of their respective owners.
  10. DISCLAIMERS: All CONTENT materials, information, software, FUNCTIONS, products, and services included in or MADE available through the eVESTMENT Site are provided “as is” and “as available” for your use.WHILE EVESTMENT ALLIANCE ENDEAVORS TO PROVIDE THE MOST ACCURATE, UP-TO-DATE INFORMATION AVAILABLE, THE INFORMATION, CONTENT, PRODUCTS, AND SERVICES AVAILABLE ON THE EVESTMENT SITEMAY INCLUDE INACCURACIES OR UNRELIABLE DATA.MOREOVER, EVESTMENT ALLIANCE MAY MAKE MODIFICATIONS AND/OR CHANGES IN THE EVESTMENT SITE OR IN THE INFORMATION, CONTENT, PRODUCTS AND SERVICES DESCRIBED IN THE EVESTMENT SITE AT ANY TIME, FOR ANY REASON.YOU ACKNOWLEDGE THAT YOUR USE OF THE EVESTMENT SITE IS SOLELY AT YOUR RISK.IN ADDITION, TO THE FULLEST EXTENT PERMISSIBLE BY LAW, EVESTMENT AND ITS SUBSIDIARIES AND AFFILIATES MAKE NO REPRESENTATIONS OR WARRANTIES OF ANY KIND WHATSOEVER FOR the CONTENT ON THE EVESTMENT SITE OR THE MATERIALS, INFORMATION AND FUNCTIONS MADE ACCESSIBLE BY THE SOFTWARE USED ON OR ACCESSED THROUGH THE EVESTMENT SITE, FOR ANY PRODUCTS OR SERVICES OR HYPERTEXT LINKS TO THIRD PARTIES OR FOR ANY BREACH OF SECURITY ASSOCIATED WITH THE TRANSMISSION OF SENSITIVE INFORMATION TRANSMITTED THROUGH THE EVESTMENT SITE.FURTHER, EVESTMENT AND ITS SUBSIDIARIES AND AFFILIATES DISCLAIM ANY EXPRESS OR IMPLIED WARRANTIES, INCLUDING WITHOUT LIMITATION, NON-INFRINGEMENT, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE.COMPANY DOES NOT WARRANT THAT THE FUNCTIONS CONTAINED IN THE EVESTMENT SITE OR ANY MATERIALS OR CONTENT CONTAINED THEREIN WILL BE UNINTERRUPTED OR ERROR FREE, OR THAT DEFECTS WILL BE CORRECTED. EVESTMENT AND ITS SUBSIDIARIES AND AFFILIATES SHALL NOT BE LIABLE FOR THE USE OF THE EVESTMENT SITE, INCLUDING, WITHOUT LIMIATION, THE CONTENT AND ANY ERRORS CONTAINED THEREIN.
  11. LIMITATION OF LIABILITY: IN NO EVENT SHALL EVESTMENT ALLIANCE BE LIABLE FOR ANY INDIRECT, PUNITIVE, INCIDENTAL, SPECIAL, EXEMPLARY OR CONSEQUENTIAL DAMAGES ARISING OUT OF OR IN ANY WAY CONNECTED WITH THE USE OF THE EVESTMENT SITE OR WITH THE DELAY OR INABILITY TO USE THE EVESTMENT SITE, OR FOR ANY INFORMATION, CONTENT, PRODUCTS AND SERVICES OBTAINED THROUGH THE EVESTMENT SITE, OR OTHERWISE ARISING OUT OF THE UTILIZATION OF THE EVESTMENT SITE, WHETHER BASED IN CONTRACT, TORT, STRICT LIABILITY, OR OTHERWISE, EVEN IF EVESTMENT ALLIANCE HAS BEEN ADVISED OF THE POSSIBILITY OF DAMAGES. BECAUSE SOME STATES/JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES, THE ABOVE LIMITATION MAY NOT APPLY. IF, NOTWITHSTANDING THE ABOVE, EVESTMENT ALLIANCE IS FOUND LIABLE FOR ANY LOSS OR DAMAGE RELATING TO THE USE OF THE EVESTMENT SITE, YOU AGREE THAT YOUR SOLE REMEDY AND THE SOLE LIABILITY OF EVESTMENT ALLIANCE SHALL NOT EXCEED THE TOTAL AMOUNT PAID BY MEMBER TO EVESTMENT ALLIANCE IN CONNECTION WITH THE SUBJECT MATTER FROM WHICH YOUR CLAIM ARISES.
  12. INDEMNIFICATION: You agree to indemnify, defend and hold harmless eVestment Alliance and its affiliates, and any of their officers, directors, shareholders, employees, consultants, agents, licensors, licensees, information providers and suppliers, from and against any and all claims, liability, damages, costs and/or expenses, including but not limited to reasonable attorneys’ fees, arising from your use or misuse of the eVestment Site or any breach of any covenant, representation or warranty contained herein.
  13. APPLICABLE LAW: This Agreement shall be governed by and construed in accordance with the laws of the State of Georgia, as applied to agreements entered into and completely performed in the Georgia, without regard to conflicts of law rules.You agree to submit to the sole and exclusive jurisdiction of and venue in the federal or state courts presiding in Atlanta, GA for all actions or proceedings arising out of or related to this Agreement and waiver any jurisdictional, venue or inconvenient forum objections to such courts. eVestment Alliance makes no representation that the materials on the eVestment Site are appropriate or available for use in locations outside the United States, and access to them from territories where any of the contents of the eVestment Site are illegal are prohibited.Those who choose to access the eVestment Site from other permissible locations do so on their own volition and are responsible for compliance with applicable local laws.
  14. TERM AND TERMINATION: This Agreement will take effect at the time the Member begins using the eVestment Site, thereby indicating acceptance of this Agreement and at each use thereafter the Member shall be deemed to have reaffirmed his or her acceptance of this Agreement. eVestment Alliance reserves the right at any time and for any reason in its sole discretion to deny any Member access to the eVestment Site or any portion thereof, and to terminate this Agreement. Termination will be effective without notice.

By accepting this Agreement, the Member hereby acknowledges that he or she has read, understood and agrees to the terms and conditions contained in this Agreement.If you have any questions about these Terms and Conditions, please contact us at support@evestment.com.


Copyright/DMCA

We respect the intellectual property of others, and we require that our users to do the same. On this page, you will find information about our copyright infringement procedures and policies.

Notification of Copyright Infringement

If you are a copyright owner (or an agent of a copyright owner) and believe material posted or linked to on our site infringes upon your copyright, you may submit a Notification of Claimed Infringement under the Digital Millennium Copyright Act (“DMCA”) by sending an e-mail to our Designated Copyright Agent containing the following information:

  1. A clear identification of the copyrighted work claimed to have been infringed. If multiple copyrighted works are posted on a single web page and you notify us about all of them in a single notice, you may provide a representative list of such works found at the site.
  2. A clear identification of the material you claim is infringing on the copyrighted work, and information sufficient to locate that material on our website.
  3. A statement that you have a “good faith belief that the material that is claimed as copyright infringement is not authorized by the copyright owner, its agent, or the law.”
  4. A statement that “the information in the notification is accurate, and under penalty of perjury, the complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.”
  5. Your contact information so that we can reply to your notice, preferably including an e-mail address and telephone number.
  6. The notice must be physically or electronically signed by the copyright owner or a person authorized to act on behalf of the owner.

Your written Notification of Claimed Infringement must be sent to our Designated Copyright Agent at the e-mail address listed below. We will review and address all notices that substantially comply with the requirements identified above. If your notice fails to substantially comply with all of these requirements, we may not be able respond to your notice.

We suggest that you consult your legal advisor before filing a Notification of Claimed Infringement. Please note that you may be liable for damages if you make a false claim of copyright infringement. Section 512(f) of the Copyright Act provides that any person who knowingly materially misrepresents that material is infringing may be subject to liability.

Counter Notification of Copyright Infringement

  1. If you believe material was removed in error, you may send a Counter Notification to our Designated Copyright Agent at the e-mail address provided below.
  2. To file a Counter Notification with us, you must send us an e-mail that sets forth the items specified below:
    • Identify the specific file or URL of material that we have removed or to which we have disabled access.
    • Provide your full name, address, telephone number, and e-mail address.
    • Provide a statement that you consent to the jurisdiction of Federal District Court for the judicial district in which your address is located (or Atlanta, Georgia if your address is outside of the United States), and that you will accept service of process from the person who the provided notification of claimed infringement to which your notice relates or an agent of such person.
    • Include the following statement: “I swear, under penalty of perjury, that I have a good faith belief that the material was removed or disabled as a result of a mistake or misidentification of the material to be removed or disabled.”
    • Sign the notice. If you are providing notice by e-mail, an electronic signature or scanned physical signature will be accepted.
  3. If we receive a Counter Notification from you, we may forward it to the party who submitted the original Notification of Claimed Infringement. The Counter Notification we forward may include some of your personal information, such as your name and contact information. By submitting a Counter Notification, you consent to having your information revealed in this way.  We will not forward the Counter Notification to any party other than the original claimant unless required or expressly permitted to do so by law.

After we send out the Counter Notification, the original claimant must respond to us within 10 business days stating that the original claimant has filed an action seeking a court order to restrain you from engaging in infringing activity relating to the material on our web site.

We suggest that you consult your legal advisor before filing a Counter Notification of Copyright Infringement. Please note that you may be liable for damages if you make a false claim. Under Section 512(f) of the Copyright Act, any person who knowingly materially misrepresents that material was removed or disabled by mistake or misidentification may be subject to liability.

Please note that we may not be able to contact you if we receive a Notification of Copyright Infringement about material you posted online. In accordance with our Terms of Service, we reserve the right to remove any content posted on our web sites at any time at our sole discretion.

Termination of Subscriber Accounts

It is our policy, in what we deem in our sole discretion to be appropriate circumstances, to disable and/or terminate the accounts of users, subscribers or account holders who repeatedly infringe the copyrights or other intellectual property rights of others.

Designated Copyright Agent Contact Information

Notices with respect to this web site should be sent to:

Legal name and address:eVestment Alliance, LLC
Names doing business under:Evestment; eVestment Alliance; evestment.com; easeexchange.com; evestment.co.uk; evestment.eu; evestmentalliance.com; evestmenthfn.com; evestmenthfn.net; evestmentalliance.co.uk
Designated Agent:Gene Luciani, General Counsel
Address of Agent:100 Glenridge Point Parkway
Suite 100
Atlanta, GA 30342
Telephone:+1.678.238.0738
Fax:+1.678.560.3036
Email:gluciani@evestment.com

The Designated Copyright Agent should be contacted only about notices regarding alleged copyright. Any other feedback, comments, requests for technical support, and other communications should be directed to customer service at support@evestment.com.


Third-party Data Vendor Notices

 

Morningstar

For all Morningstar data: © 2013 Morningstar.  All Rights Reserved.  The information contained herein: (1) is proprietary to Morningstar and/or its content providers; (2) may not be copied or distributed; and (3) is not warranted to be accurate, complete or timely.  Neither Morningstar nor its content providers are responsible for any damages or losses arising from any use of this information.  Past performance is no guarantee of future results.