Last Updated: September 30, 2014
This Privacy Statement forms part of the legally binding agreement between You and State Street Bank and Trust Company (“Company”) (the “Privacy Statement”) and governs how Company uses Your Personal Information on the Website. By clicking on the box to accept the Privacy Statement, You are consenting to the collection, storing, transmission, disclosure and use of Your Personal Information as set out in this Privacy Statement and to be bound by the terms and conditions that apply herein. We advise you to read the Privacy Statement in its entirety. As used herein, the term “Personal Information” means any information that relates to You and that could be used, either directly or indirectly, to identify You. Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the Terms of Service (the “Agreement”).
This Privacy Statement provides information to You about the following:
- What Personal Information is collected through the Website?
- What happens if I include Personal Information within my Submitted Materials to the Website?
- What are cookies, and how are they used to collect Personal Information?
- Does Company collect non-personally identifiable information, and what does Company do with it?
- How will my Personal Information be used?
- What about other websites?
- Is the Personal Information collected about me secure?
- What happens when Company changes this Privacy Statement for the Website?
- How long does Company keep my Personal Information?
- Who can I contact about accessing, deleting or amending my Personal Information?
This Website is administered by Conenza, Inc. on behalf of Company. As such, You are consenting to the collection, storing, transmission, disclosure and use of Your Personal Information as set out in this Privacy Statement by Conenza as well as the Company. All actions by Company referenced below related to Your Personal Information also pertain to Conenza; however, for simplicity purposes we have only listed Company.
Company and Conenza have policies to treat Personal Information as confidential and to protect it from accidental, malicious or unauthorized disclosure, misuse, modification, destruction, loss and/or damage. To that end, Company and Conenza have developed controls and procedures reasonably designed to protect the confidentiality of, prohibit the unauthorized disclosure of, and limit access to Personal Information.
1. What Personal Information is collected through the Website?
Company collects and may use certain Personal Information about You in order to operate and provide access to the Website. If you decide to register, You will be required to provide a user name and email address. Without this information, You will not be able to use the Website. By using the Website, You agree that the Website may collect other Personal Information about You, including but not limited to, the following:
- further Personal Information that You may voluntarily provide (including, without limitation, your email addresses, your telephone numbers, other contact details, the identity of your current employer and other biographical information) when You participate in the Website, including without limitation when you complete your profile, on the Website or You Submit material to the Website. Please do not include in your Submitted Materials any financial or sensitive information (other than as may be included in Your User profile) about You or any other person (including but not limited to social security numbers or other government issued identification numbers, information about Your or any other individual’s religious, confessional or similar beliefs, racial or ethnic origin, physical, physiological or mental health or sexual life, genetic code, addictions, political affiliation or political party membership, trade union membership or information about criminal offences or any other categories of personal information defined as sensitive under applicable data protection laws);
- information about Your usage of the Website (e.g., the pages You request and visit, the posts You Submit, and Your interaction with other Users and the Website);
- information obtained in the course of maintaining or supporting the Website; and
- information about your internet use, such as Your IP address, the URLs of sites from which You arrive or leave the Website, Your type of browser, Your operating system, Your internet service provider (ISP) and, if You access the Website via your mobile device, We may also collect information about Your mobile provider and Your mobile device.
Children are not eligible to use the Website and We ask that minors (under the age of 18 or the age of majority in Your country if this is higher) do not Submit any Personal Information to Us or use the Website.
2. What happens if I include Personal Information within my Submitted Materials to the Website?
If You Submit any Personal Information to the Website and it is posted, Your user name and any other Personal Information contained in Your Submitted Material will be visible and publicly available to authorized Company Personnel who administer or maintain the Site (“Authorized Company Personnel”) and, if you grant access to such Personal Information, to other Users who are registered with the Website (“Registered Alumni Users”) and current Company employees (“Other Company Employees”). Company is not responsible for the Personal Information You choose to Submit to this Website and, by providing such Personal Information, You are agreeing that it may be freely copied and used (or reused) by Company. As such, You should not include any Personal Information in Your Submitted Materials (other than Your user name which will appear automatically) that You do not want to be used in this manner.
3. What are cookies, and how are they used to collect Information?
You have the ability to accept or decline cookies by modifying the settings in Your browser. However, You may not be able to use all the features of the Website if cookies are disabled.
We occasionally use other companies to set cookies on our websites and gather cookie information for us. In some cases, We will also use another company to operate web servers for our sites. We use the cookie information gathered by these companies in the same manner as stated above. The companies We use may not use these cookies for their own purposes or share the information gathered in connection with the cookies with others, in accordance with the terms of the contracts they have signed with us.
4. Does Company collect non-personally identifiable information, and what does Company do with it?
In addition to Content, which is addressed in the Privacy Statement, Company collects certain non-personally identifiable information in connection with Your use of the Website. For example, Company may collect click stream data, data on how You navigate the Website, and anonymous demographic information which We may use for website administration, analytics, market research, advertising and promotions or any other legitimate business use. We may share such information with various affiliated and unaffiliated entities for such purposes.
5. How will my Personal Information be used?
Any Personal Information that you Submit that is designated by the Website as being accessible through the Directory on this Website (“Directory”) will be available to Authorized Company Personnel and, if you grant access to such Personal Information in the Directory, to other Registered Alumni Users and Other Company Employees and may be used by any of them to contact you directly for any purpose not specifically prohibited by the Privacy Statement or the Agreement, including for any networking, social and business-related purposes.
Any Personal Information that you Submit about Yourself for publication on the Website and that is designated by the Website as being accessible through the Directory will be available to all other Registered Alumni Users, Other Company Employees, and Authorized Company Personnel and may be used by any of them for any purpose not specifically prohibited by the Privacy Statement or the Agreement. Any Personal Information that You Submit about You that is not for publication on the Website and is designated by the Website as not being accessible through the Directory will be available only to Authorized Company Personnel.
In addition to other uses described herein, Company will have access to and may use Personal Information that you Submit on, or otherwise provide in connection with, the Website for administering and managing and providing other services in relation to the Website, including but not limited to:
- processing your registration and facilitating your participation in the Website;
- providing and maintaining a Directory of Registered Alumni User contact information;
- enabling You to communicate with other Registered Alumni Users as well as enabling other social and networking communications;
- enabling communications with You, including providing You with invitations and/or information about:
- Company and Company-sponsored and/or third party-sponsored social and/or business-related events, activities and opportunities;
- The financial services industry and financial services industry events, activities and opportunities;
- Company products and services;
- Company employment opportunities;
- offering You Company services or products, including those that may be made available on or through this Website from time to time;
- monitoring compliance with the Privacy Statement and the Agreement and complying with applicable law or regulations and Company policies; and
- investigating any complaints about the use of the Website.
Company may also disclose Personal Information in order to protect the legal rights, privacy, safety, security or legitimate interests of Company, its affiliates, and each of their respective investors, directors, officers, employees, agents and suppliers. These instances may include, but are not limited to: protecting the safety and security of visitors to our websites or other properties; complying with Company policies; enforcing the Privacy Statement and the Agreement; complying with the law or regulations, or responding to a subpoena or other process; responding to inquiries or requests from public authorities; permitting Company to pursue available remedies or limit the damages that it may sustain; protecting against fraud, crime, illegal activity, anti-money laundering, anti-terrorism, or for risk management purposes; or otherwise in connection with legal, compliance, regulatory and investigative purposes.
If Company appoints third parties to host, maintain, manage, or to provide other services in relation to the Website, then the Personal Information included in the Website may be accessed and used by these third parties to the extent necessary to fulfill their hosting, maintenance, managerial, and/or other functions. Company 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 Company when processing Personal Information.
If We sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, We may transfer Your Personal Information to a third party as part of that transaction (and will seek your consent where required by applicable law).
We do not rent, sell or otherwise provide Your Personal Information to third parties for their marketing purposes without your prior consent.
You may be invited to participate in polls and surveys on the Website. Your selection may be at random or it may be based on Your non-personally identifiable information such as job title, geography, industry sector. Whether or not You participate is entirely up to You. We may use third parties to deliver incentives to You to participate in polls and surveys. You may be required to provide Your contact details to the third party in order to fulfill the incentive offer. It is up to You whether You provide this information to take advantage of the incentive.
6. What about other websites?
The Website may contain links to other websites. Please note that Company is not responsible for the privacy or information security practices of other websites. You should carefully review the applicable privacy and information security policies and statements for any other websites to which you click through to via the Website. This Privacy Statement applies solely to Your Personal Information collected by this Website.
7. Is the Personal Information collected about me secure?
The Website uses reasonable physical, electronic, and procedural measures to safeguard information against loss, theft, and unauthorized use, disclosure, or modification. Unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while We strive to protect Your information, We cannot guarantee its security.
You are responsible for maintaining the secrecy of Your password and other Website registration information, and for controlling access to Your email communications at all times.
8. What happens when Company changes this Privacy Statement for the Website?
From time to time, We may revise this Privacy Statement. Changes may be made for any number of reasons, including to reflect industry initiatives, changes in the law, and changes to the scope of the Site, among other reasons. You can tell when We last updated the Privacy Statement by checking the “Last Updated” legend at the beginning of the Privacy Statement. If your country requires you to reaccept any changes to this Privacy Statement in order for such changes to be enforceable, we will facilitate such approach. Otherwise, Your continued use of the Website will indicate Your agreement to the new Privacy Statement.
9. How long does Company keep my Personal Information?
Personal Information that You include in Your user profile will be retained in accordance with applicable law.
If You no longer wish to participate in the Website, You may contact email@example.com to request that Your profile data on this Website be deemed inactive. Even if Your profile data is deemed inactive, Company may retain your profile data in accordance with applicable law.
Company will use reasonable efforts to notify You by email before deleting Your profile. If Your profile is deleted, other data and Information that You have included on the Website may still remain on the Website and be visible to other Users.
10. Whom can I contact about accessing, amending or deleting my Personal Information?
In certain countries, consistent with applicable law, You may have certain rights with respect to the Personal Information which Company holds about You including the right to access or correct (and sometimes, object to or delete) the information. If You would like to request deletion of Your profile information or have questions or requests, please contact firstname.lastname@example.org who will be able to guide you as to how to do this.
If You have any other questions concerning this Privacy Statement, You may submit them to email@example.com. Please do not send emails to us for other purposes.