Children Under the Age of 16. Our Website is not intended for children under the age of 16. We do not knowingly collect personal information from children under 16. If you are under the age of 16, do not use or provide any information on our Website, including providing any information about yourself to us. If we learn we have collected or received personal information from a child under the age of 16 without parental consent, we will delete that information. If you believe we have any information from a child under the age of 16, please contact us (see Help below).
Information We Collect About You And How We Collect It
We collect personal information about you in a variety of ways, including, for example, when you visit our Website, send information to us when you submit an application to apply for a job or enter a competition, or contact us to request information. In the past twelve months, we have collected the following categories of personal information, which does not include any information that is publicly available from government records or is deidentified or aggregated consumer information:
- We collect Identifiers, such as, for example, your name, postal address, email address, and telephone number; Personal Information (e.g., categories of personal information listed in the Customer Records Statute Section 1798.80(e)), such as the Identifierslisted above and your employer name, your job title, and your job category; and Professional or employment related information, such as your employer name, your job title, and your job category. We collect this information directly from you when you submit a form to contact us or when you ask to obtain information from us on our Website. We retain this information for a minimum of 6 years. We do not disclose, share, or sell this information to third parties.
- We collect Identifiers and Personal Information (e.g., categories of personal information listed in the Customer Records Statute Section 1798.80(e)), such as your name, address, email address, telephone number, and your education history; Professional or employment related information, such as your prior work history, work experiences, qualifications, applicable course of study or certifications, and any other information provided on your resume or provided with your application. We collect this information directly from you and use this information to evaluate your candidacy for a position with us. We may also collect your Social Security Number, or other government issued identification number, to run applicable background checks, such as, for example, criminal, educational, identity, credit, and Do Not Trade status check(s), where such background checks may depend on the job position. We retain this information in accordance with applicable laws. We do not disclose, share, or sell this information to third parties.
- We collect Internet or other similar activity, such as, for example, your browsing history, interaction with our Website, and your interaction with the information available on our Website. We collect this information to improve the content on our Website, to analyze and track the performance and use of our Website, to capture your web activity, and to perform research for our marketing purposes. We will keep this information for at least six years. We do not disclose, share, or sell this information to third parties.
- We also collect Internet or other similar activityto maintain our Website, including debugging, and to secure our Website, including detecting, preventing, or prosecuting a security incident or other illegal activity. We keep this information for a minimum period of 6 years. We may disclose this information to our service providers, to government entities, and our operating systems and platforms.
- Additionally, we may also collect Internet or other similar activity, such as, for example, information regarding your interaction with our Website, your browser information, your operating system, your referring site details, your network location, and other information provided by Google Analytics, our data analytics service provider. We collect this information to evaluate our marketing effectiveness, including determining how our Website is performing, the number of Website visitors, the Website interactions and duration, and details regarding how you come to our Website to improve the effectiveness of our Website. We keep this information for at least 6 years. We do not disclose, share, or sell this information to third parties. To prevent your data from being used by Google Analytics, you may install the Google Analytics Opt-Out Browser Add-On.
We may also use or disclose your personal information for one or more of the following purposes:
- To improve our client service and more effectively respond to your requests and needs.
- To meet or fulfill the purpose for which you provided the information and/or to evaluate your eligibility to receive any requested information. For example, to respond to your inquiry or to provide you with requested information. We may also save your information, preferences, and areas of interest to provide additional information to you about our products and services.
- To detect and help maintain the security and integrity of our Website, including detecting incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and taking appropriate steps in response to such activity.
- To protect against imminent harm to the rights, property or safety of PanAgora, our clients, or the public as required or permitted by law.
- To respond to law enforcement requests and as required by applicable law, court order, governmental regulations.
- In corporate transactions, we may share your information with a potential buyer or other successor to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets (“transaction”), whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred, which may occur prior to consummation of such transaction.
- As otherwise described to you when we collect your personal information.
We will not collect additional categories of information or use the information we have collected for materially different, unrelated, or incompatible purposes without providing you notice.
If you are submitting information on behalf of a third party, we expect that you have received appropriate consent, according to applicable privacy laws, before transferring any personal information to us.
PanAgora respects your personal information and we work to adopt appropriate steps to protect it from loss, misuse, or alteration. Where appropriate, these steps can include technical measures like firewalls, intrusion detection and prevention systems, unique and complex passwords, and encryption. We also use organizational and physical measures such as training staff on data processing obligations, identification of data incidents and risks, restricting staff access to your personal information, and ensuring physical security including appropriately securing information when not being used. However, please remember that no data transmission over the internet is completely secure. Although we have taken appropriate steps to protect your personal information, we cannot guarantee the security of any information you provide to us or from our Website and therefore you use our site at your own risk. Information on how to report security questions, issues, or possible incidents can be found in the Help section below.
PanAgora reserves the right to change this Policy. If we decide to make changes, we will post the updated policy on our Website so you are always aware of what information we collect, how we use it, and the circumstances, if any, we disclose it. The date this Policy was last revised is identified at the top of the page. Your continued use of our Website following the posting of changes constitutes acceptance of such changes. Where required by applicable data protection laws, we will also seek your consent to any material changes that affect how we use your information.
Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit the Privacy Notice for California Residents.
If you need help or have questions regarding this Policy and our practices, you may contact us by:
Writing us at:
PanAgora Asset Management, Inc.
One International Place
Boston, MA 02110
Attn: Legal Department
Emailing us at:
Privacy Notice for California Residents
Effective Date: November 2023
This Privacy Notice for California Residents (“California Notice”) supplements the information contained in our Policy above and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights and Enforcement Act of 2020, (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this California Notice.
Your Rights and Choices
This section describes your rights regarding your personal information under the CCPA and how to exercise those rights.
Right to Know – Categories Request
You have the right to request, twice in a 12-month period, the following information about the personal information we have collected about you during the past 12-months:
- The categories of personal information we collected about you.
- The categories of sources from which we collected the personal information.
- Our business or commercial purposes for which (if applicable) we collected, sold, or shared that personal information.
- The categories of third parties to whom we sold or shared the personal information, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared.
- The categories of personal information about you that we disclosed for a business purpose, and the categories or persons to whom we disclosed that information for a business purpose.
Right to Know – Specific Pieces
You have the right to request a transportable copy of the specific pieces of personal information we collected about you in the 12-month period preceding your request. Please note that personal information is retained by us for various time periods, so there may be certain information that we have collected about you that we do not retain for a 12-month period and thus, it would not be able to be included in our response to you. Also, you may be limited to a certain number of “right to know” requests in any 12-month period.
Right to Delete
You have the right to request that we delete certain personal information that we collected from you. Please understand that we cannot delete personal information in those situations where our retention is required for our own internal business purposes or otherwise permitted by relevant U.S. Privacy Laws (such as fraud prevention, regulatory or legal compliance). When we receive and confirm your verifiable consumer request, we will delete your personal information from our records, unless an exception applies.
Right to Correct
You have the right to request that we correct inaccuracies that you find in your personal information maintained by us. Once we receive and confirm your verifiable consumer request, we will use commercially reasonable efforts to correct any inaccurate information and we will instruct our service providers or any contractors to correct such information. We will also inform you whether or not we have complied with your request, including any basis for denial of the request.
Exercising Your Rights
Certain requests you submit to use are subject to an identity verification process (“verifiable request”). We will not fulfill such requests unless you have provided sufficient information for us to reasonably verify you are the individual about whom we have collected personal information. To complete your request, please contact us by either:
- Calling us at (800) 423-6041; or
- Emailing us at [email protected]
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. If you submit a request on behalf of another person, we may require proof of authorization and verification of identity directly from the person for whom you are submitting a request.
The verifiable request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include your name and email address in addition to other specific information regarding your relationship to PanAgora;
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will review the information provided as part of your request and may ask you to provide additional information via email or other means as part of this verification process.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact [email protected].
We endeavor to respond to a verifiable consumer within 45 days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, which may include either a screen shot of the information or a pdf.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales/Sharing Opt-Out and Opt-In Rights
Under the CCPA, if you are 16 years of age or older, you have the right to direct us not to sell or share your personal information at any time (the “right to opt-out”). We do not sell or share your information with third parties.
We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted under the law, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you with a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
We reserve the right to change this Policy. If we decide to make changes, we will post the updated Policy on our Website so you are always aware of what information we collect, how we use it, and the circumstances, if any, we disclose it. The date this Policy was last revised is identified at the top of the page. You are responsible for ensuring that we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and the Policy to check for any changes. Your continued use of our Website following the posting of changes constitutes acceptance of such changes. Where required by applicable data protection laws, we will also seek your consent to any material changes that affect how we use your information.
If you need help or have questions regarding this Policy and our practices, or have a disability and need an alternative format of this Policy, you may contact us by:
Writing us at:
PanAgora Asset Management, Inc.
One International Place
Boston, MA 02110
Attn: Legal Department
Emailing us at: