ITI Funds (“We / ITI Funds”) recognizes the importance of protecting your personal and financial information when you visit our websites (each a “Website” and together “Websites”). This Policy including the Cookies Policy is designed to help you understand the information collection practices on all Websites owned or operated by or on behalf of companies within the ITI Funds group of companies. Information collected on our Website is collected by ITI funds. Contact information is included in this Policy and on the Website.
We are committed to:
(a) protecting the personal data you provide to us;
(b) telling you how we use the information we gather about you; and
(c) ensuring that you know the circumstances under which we may disclose your personal data.
This Policy covers the privacy and data protection policies on our website and should be read in conjunction with any other applicable policies, terms, and conditions in place between you and ITI Funds.
Contact Us
If you have any questions about this Policy, or our privacy related practices, please contact us:
• by email at info@itifunds-etf.com
• by phone at ITI Funds +44 (0) 207 562 8000
• by post: Compliance Officer, ITI Funds, Level 33 Tower 42, 25 Old Broad Street, London EC2N 1HQ
Data Protection and Privacy
Information Collection and Use
Personal Data:
Any personal data and other information you submit to our Website is used to provide you with information on ITI Funds products and services. The types of personal data that may be collected at our Websites include: name, address, email address and telephone number. We will not sell, share or rent your personal data to others in contravention of this Privacy Policy.
If you are a visitor who has entered the Website via a click through link in an email which we have sent you, information about you, including information about the pages you visit, the documents you download and other information which can help us personalize our future interaction with you may be collected. Any information collected about you from this Website may be associated with other identifying information that we have about you.
Your Rights
You may contact us to:
• request that we amend, rectify, delete or update the personal data we hold about you;
• where possible (e.g., in relation to marketing) amend or update your choices around processing;
• request a copy of personal data held by us.
Where you would like to receive a copy of all personal data held, such request should be in writing (email or post), addressed to our Compliance Officer at our London Office and should contain as much information as possible to facilitate our dealing with this request.
Aggregate Information:
We generally record certain usage information, such as the number and frequency of visitors to our Websites. This information may include the websites that you access immediately before and after your visit to our Websites, the Internet browser you are using and your IP address. If we use such data at all it will be on an aggregate basis, and we will not disclose to third parties any information that could be used to identify you personally.
Sharing your information with other Service Providers
Your personal data may be collected and processed for the purposes above:
(i) By any of the companies within the ITI Funds group; or
(ii) By a third-party service provider engaged by us for these purposes;
ITI Funds companies and service providers we engage may be based in countries outside of the European Union / EEA in countries having different standards of protection for personal data. Recipients will be required by us to protect your information in accordance with applicable data protection laws.
Compliance with Laws
Your personal data will be held and processed by us in accordance with applicable data protection law.
We will not provide any personal data to any other persons, except if we are required to make disclosures by any law, any government or private parties in connection with a lawsuit, subpoena, investigation or similar proceeding.
E-mail and Marketing
ITI Funds does not sell its customers’ personal data, nor will we provide your personal data to third parties for their marketing purposes without your consent. ITI Funds will not send you e-mail messages without first receiving your permission, unless it relates to servicing your account or unless you have consented to receiving electronic delivery of fund documents. It is our policy to include instructions for unsubscribing from these permission-based programs.
Business Transfers
If the business, stock or assets of ITI Funds are acquired or merged with another business entity, we will share all or some of your information with this entity to continue to provide our service to you. You will receive notice of such an event and the new entity will inform you of any changes to the practices in this Privacy Policy. If the new entity wishes to make additional use of your information, you may decline such use at such time.
Disclosure to Third Parties
The personal data you provide to us will only be disclosed to third parties if we have your permission, or as set out in this Privacy Policy. We may disclose details about the general use of our Websites to third parties – for example, to demonstrate patterns of use to advertisers and other business partners. Information we pass on for this purpose will not include any personal data by which you may be identified. We endeavour to prevent unauthorised disclosures of your personal data by third parties but we are not responsible for any unauthorised disclosures or other breaches of security or for the actions of others if the information was passed to them with your authority or with the authority of anyone other than us or our group companies.
Third-party Websites
ITI Funds disclaims responsibility for the privacy policies and customer information practices of third-party internet websites hyperlinked from our Website or this Privacy Policy.
Security
We recommend that you do not send us any personal data via non secure methods of correspondence, including via public electronic communication channels, such as Internet e-mail, which are generally not secure.
Cookies Policy
What are cookies?
Cookies are small text files that are stored in your computer’s memory and hard drive, in your mobile device or tablet when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website, or other third parties which receive data obtained from that website.
When you visit any web site, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalised web experience.
Why do we use cookies?
Cookies help us to provide customised services and information. We use cookies on our Website to tell us, in general terms, how and when pages in our Website are visited, what our users’ technology preferences are – such as what type of video player they use – and whether our Website is functioning properly. Depending on their purpose, some cookies will only operate for the length of a single browsing session, whilst others have a longer life span to ensure that they fulfil their longer-term purposes (as explained in more detail below). Please note that, however long the cookies’ active life may be, you can delete cookies (and therefore stop any further data collection by them) as further described below.
In broad terms, we use cookies on our Website for the following purposes:
• Analytical purposes: Analytical cookies allow us to recognise, measure and track visitors to our Website and compile a record of this usage information. This helps us to improve and develop the way our Website work, for example, by determining whether site visitors can find information easily, or by identifying the aspects of websites that are of the most interest to them.
• Usage preferences: Some of the cookies on our Website are activated when visitors to our sites make a choice about their usage of the site. Our Website then ‘remembers’ the settings preferences of the user concerned. This allows us to tailor aspects of our sites to the individual user.
• Terms and conditions: We use cookies on our Website to record when a site visitor has seen a policy, such as this one, or provided consent, such as consent to the terms and conditions on our Website. This helps to improve the user’s experience of the site – for example, it avoids a user from repeatedly being asked to consent to the same terms. We also track whether a user has seen other similar documents (such as an online survey) before – again, to ensure that a user’s experience of our Website is a smooth one.
• Session management: The software that runs our website uses cookies for technical purposes needed by the internal workings of our servers. For instance, we use cookies to distribute requests among multiple servers, authenticate users and determine what features of the site they can access, verify the origin of requests, keep track of information about a user’s session and determine which options or pages to display in order for the site to function.
• Functional purposes: Functional purpose cookies store information that is needed by our applications to process and operate. For example, where transactions or requests within an application involve multiple workflow stages, cookies are used to store the information from each stage temporarily, in order to facilitate completion of the overall transaction or request.
• Advertising: Advertising cookies allow us (or third parties) to monitor the behaviour of users of our Website. This information is used to ensure that products and services highlighted to those individuals are targeted in a focused and relevant manner – e.g. through advertisements on ITI Funds website or through advertisements on third-party websites (e.g. Bloomberg, Agefi.com Handlesblatt.de, etc) where we are legally allowed to do so which are based on your experience with our Website; or to monitor the effectiveness of those digital marketing campaigns. We also monitor whether any adverts displayed on our Website are of interest to users and retain this information to ensure that adverts seen by users of our Website over a period of time are appropriate.
Please note that third parties may use cookies. The kind of cookies and the consequent data processing carried out by such third parties are regulated by their privacy policy.
Your cookie preferences
Cookies are necessary in order for you to be able to make full use of ITI funds Website. In addition, cookies help us provide you with personalised features on our Website. If you chose to disable cookies, some of ITI Funds Website functionality might be impaired.
Local Flash Storage
Our website may contain content designed for display using Adobe Flash Player, such as animations, videos and tools. Local flash storage (often referred to as “Flash cookies”) can be used to help improve your experience as a user. Flash storage is retained on your device in much the same way as standard cookies, but is managed directly by your Flash software.
If you wish to disable or delete information stored locally in Flash, please see the documentation for your Flash software, located at www.adobe.com. Please note that, if you disable Flash cookies, some site functionality may not work.
Amending cookie preferences
If you wish to remove cookies set by our Website from your browser in the future, you may delete them. The instructions for removing cookies from your computer or mobile device depend on the operating system and web browser you use. Please note, however, that withdrawing your agreement to the use of cookies on our site will impair the functionality of the site.
The site www.allaboutcookies.org includes instructions for managing cookies on many commonly used browses, or you may consult the vendor documentation for your specific software.
Further information about cookies
If you would like to find out more about cookies in general and how to manage them, please visit www.allaboutcookies.org.