Legal

Privacy Policy

PanAgora Asset Management, Inc. (“PanAgora”) respects your privacy and are committed to protecting it through compliance with this Privacy Policy (this “Policy”).

This Policy was last updated on June 4, 2020.

Introduction

This Policy describes the types of information we may collect from you or that you may provide when you visit our website https://www.panagora.com/ (“Website”), and our practices for using, disclosing, protecting, and sharing that information.

This Policy does not apply to information collected by any third party, including through any application or content, including advertising, which may link to or be accessible from our Website.  PanAgora is not responsible for the privacy practices or content of those other websites.

This Policy does not apply to employment related personal information collected from employees, job applicants, contractors, or similar individuals.  Our policies regarding these individuals are provided separately, as applicable, at or before the time of collection of such information.

Where noted, this Policy does not apply to personal information reflecting a written or verbal business-to-business communication between us and an individual contacting us in their role as an employee, owner, director, officer, or contractor of an entity to either obtain our services or provide us with a product or service (“business-to-business information”).  We do not disclose or share business-to-business information with any other entity without first obtaining consent.

Please read this Policy carefully to understand our practices regarding your personal information and how we treat it.  This Policy may change from time to time (see Changes to Our Privacy Policy) so please check this Policy periodically for updates.  If there are any material changes to this Policy, we will notify you as required under applicable law.

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

Information you provide to us voluntarily.  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 aggregated consumer information:

  • Identifiers, such as name, postal address, email address, and telephone number.
  • Personal Information, such the identifiers listed above and employer name, job title, and job category.
  • Internet or other similar activity, such as, browsing history, interaction with our Website, and interaction with the information available on our Website.
  • Professional or employment related information, such as, employer name, job title, and job category.

We obtain the above categories of information when you submit a form to contact us or when you ask to obtain information from us on our Website.

Information we collect automatically.  We also use automatic data collection technologies to collect certain information about your equipment, browsing activity and patterns, and the resources you access when you navigate and interact with our Website.  The technology we use for this automatic collection may include cookies (or browser cookies), which is a small file placed on the hard drive of your computer.  You may refuse to accept browser cookies by activating the Do Not Track setting on your browser.  However, if you select this setting you may be unable to access certain parts of our Website.  Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

We also use the third party marketing and analytical services provided by Google Analytics and Google Ad services.  These services use cookies with a randomly-generated ClientID in your browser.  This ID is anonymized.  IP anonymization is also activated on our Website, which shortens your IP Address.  We send Google this shortened your IP Address to understand how visitors interact with our Website, what webpages are accessed, how often, and for which period of time our pages viewed.  This analysis is used to optimize our Website.  The IP address transferred through your browser to Google Analytics will not be combined with other data held by Google.  You can manage the data collected by Google Analytics by deleting your (_ga)cookies, installing the Google Analytics Opt-Out Browser Add-On, or by contacting us (see Help below).

Use of Personal Information

We may have used or disclosed the personal information we collect for one or more of the following purposes:

  • 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 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 improve and develop our Website, recognize you when you return to our Website, and to provide a more personalized service based on our automatic data collection practices.
  • 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 respond to law enforcement requests and as required by applicable law, court order, governmental regulations.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, 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.

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.

Sharing of Personal Information

We may disclose personal information that we collect or you provide as follows:

With our service providers that we use to support our business and who are bound by contractual obligations to keep personal information confidential and to use it only for the purposes for which we disclose it to them.

With respect to business-to-business information, with your consent, we may share Identifiers, Personal Information and Professional Information, as noted above, with our affiliates to market their products or services to you in your role as a business contact.  Additionally, we may share such information with our service providers in connection with, among other things, security monitoring efforts and compliance with AML obligations.

To comply with any court order, or legal process, including responding to any governmental or regulatory request.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of PanAgora, our customers, or others.

As may be described when we collect your information.

Otherwise, in the context of individuals acting on their own behalf, in the past twelve months, we have not sold personal information.  For purposes of this Policy, sold means the disclosure of personal information to a third-party for monetary or other valuable consideration.

Security

PanAgora respects your personal information and takes 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.

Changes to Our Privacy Notice

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 to California residents.

Help

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
24th Floor
Boston, MA  02110
Attn:  Legal Department

Emailing us at:
[email protected]

Privacy Notice for California Residents

Effective Date:  January 1, 2020

If you are a California resident, this portion of the Policy discusses your rights under the California Consumer Privacy Act of 2018 (“CCPA”).

Under the CCPA you have the right to:

  1. Request we disclose to you the following information covering the twelve months preceding your request:
    • The categories of personal information we collected about you.
    • The categories of sources for the personal information we collected about you.
    • Our business or commercial purpose for collecting or selling that personal information.
    • The categories of third parties with whom we share that personal information.
    • The specific pieces of personal information we collected about you.
    • If we disclosed your personal information for a business purpose, the personal information categories that each category of recipient obtained.
  2. Request we delete personal information we collected from you, unless the CCPA recognizes an exception; and
  3. Be free from unlawful discrimination for exercising your rights under the CCPA.

We do not provide these rights for business-to-business information.

We will acknowledge receipt of your request and advise you how long we expect it will take to respond if we are able to verify your identity.  We will use your email address to verify your identity.  Requests for specific pieces of personal information may require additional information to verify your identity.

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.

In some instances, we may not be able to honor your request.  For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual.  Additionally, we will not honor your request where an exception applies, such as where the disclosure of personal information would adversely affect the rights and freedoms of another consumer or where the personal information that we maintain about you is not subject to the CCPA’s access or deletion rights.

We will advise you in our response if we are not able to honor your request.  We will not provide social security numbers, driver’s license numbers or government issued identification numbers, financial account numbers, health care or medical identification numbers, account passwords or security questions and answers, or any specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft or fraud or unreasonable risk to data or systems and network security.

We will work to process all verified requests within 45 days pursuant to the CCPA.  If we need an extension for up to an additional 45 days in order to process your request, we will provide you with an explanation for the delay.

How to Exercise Your Rights

If you are a California resident, you may submit a request by:

  1. (800) 423-6041
  2. [email protected]

Help

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
24th Floor
Boston, MA  02110
Attn:  Legal Department

[email protected]