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 January 1, 2023.

Introduction

This Policy describes the types of information we may collect from you or that you may provide to us, including 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 personal information collected from employees or job applicants.  Our policies regarding these individuals are provided separately, as applicable, at or before the time of collection of such information.

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

We collect personal information about you in a variety of ways, including, for example, when you visit our Website, 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 Identifiers listed 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 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 activity to 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, your truncated IP address, and other information provided by from 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.  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 also collect Internet or other similar activity when you visit our social media page. For example, we use LinkedIn analytics in connection with the operation of our LinkedIn page in order to obtain anonymized statistical data about visitors to our LinkedIn page.  For this purpose, LinkedIn places a cookie on your device when you visit our LinkedIn page at  https://www.linkedin.com/company/panagora-asset-management/.  Each cookie contains a unique identifier code that remains active for a period described in the LinkedIn cookie table https://www.linkedin.com/legal/l/cookie-table unless it is deleted before the end of this period.  LinkedIn receives, records, and processes the information stored in the cookie, including demographic information from any LinkedIn profile you may have, to provide us with anonymized metrics to help us measure the effectiveness of our LinkedIn page for marketing purposes.  For more information on the privacy practices of LinkedIn, please visit the LinkedIn Privacy Policy here: https://www.linkedin.com/legal/privacy-policy.

We may also use or disclose your personal information 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 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.
  • 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.
  • 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.

We do not use or disclose sensitive personal information for purposes other than those specified in Section 7027(m) of the CCPA, such as, for example, to perform the services requested by our clients.

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, 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.

Reselling Personal Information

The CCPA prohibits a third party from reselling personal information unless you have received explicit notice and an opportunity to opt-out of further sales.  No businesses purchase personal information from us.

Your Rights and Choices

This section describes your rights regarding your personal information under the CCPA and how to exercise those rights.

Accessing Your Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information since January 1, 2022, including beyond the12-month period preceding your request, unless doing so would involve disproportionate effort or is not possible.  Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • 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, selling, or sharing that personal information.
  • The categories of third parties with whom we disclose that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold, shared, or disclosed your personal information for a business purpose,

o      Sales, identifying the personal information categories that each category of recipient purchased; and

o      Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Requesting Deletion of Information

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.  Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers and contractors to delete)your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the business’s deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on the relationship with us and compatible with the context in which you have provided the information.
  • Comply with a legal obligation.

Right to Correct Information

You have the right to request that we correct any inaccurate personal information that we have about you.  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 Access, Data Portability, and Deletion Rights

To exercise the access, data portability, correction, and deletion rights described above, please submit a verifiable consumer request to us by either:

  1. (800) 423-6041
  2. [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.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.  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.

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.

Response Timing

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 California Consumer Privacy Act (“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.

Non-Discrimination

We will not discriminate against you for exercising any of your rights under the CCPA.  Unless permitted by the CCPA, 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.

Changes to the Privacy Statement

We reserve the right to change this Statement.  If we decide to make changes, we will post the updated statement 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 Statement 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 Statement 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.

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]