Effective Date: May 14, 2020
[replaces version effective on October 24, 2016]
This policy applies to information we collect:
- On this Website;
- From your participation in our online surveys and promotions;
- From email and content we send to you; and
- Other types of electronic messages between you and this Website.
It does not apply to information collected by:
- Us, if you are a client;
- Us, offline (except for your use of an alternative entry option for online promotions, discussed below) or through any other means; or
- Any third party (including our affiliates and subsidiaries), including through any other website or application or any content (including advertising) that may link to or be accessible from this Website.
Children Under 13
This Website is directed to investment professionals. We do not knowingly invite children under 13 to visit this Website and we do not knowingly collect personal information from children under 13. For more information about the Children’s Online Privacy Protection Act or COPPA, please visit the U.S. Federal Trade Commission website at www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online.
Information We Collect About You and How We Collect It
We collect several types of information from and about visitors to our Website and our online content, including information that:
- may be used to contact or locate, or to authenticate the identity of, a specific individual like you, such as name, postal address, e-mail address, telephone number and other identifiers by which an individual may be contacted online or offline (“personal information”);
- is about you, specifically your interactions with our online content, such as the content you viewed, where you were when you viewed the online content and the length of time you viewed it; or
- is about you, but individually does not identify you, such as your actions while browsing this Website, your Internet connection and the software and equipment you use to access our Website.
We collect this information:
- Directly from you when you provide it to us;
- Automatically, as you navigate through the Website or interact with our online content or our advertising, directly or on other’s websites, which may include usage details, Internet Protocol (IP) addresses, geo-location, and other information collected through cookies, web beacons, and other tracking technologies; and
- From third parties, such as our service providers.
Information You Provide to Us
The personal information we collect on or through the Website may include information you provide by:
- Completing the “Advisor Registration” form and establishing a login so that you may access certain content or tools we make available to investment professionals at this Website. We will ask for information such as your name, your firm’s name, your zip code, your broker central registration depository (CRD) number, your business email address, your confirmation that you are an investment professional and certain other information about your business;
- Using the “Contact Us” form on our Website. In addition, we may retain records and copies of your correspondence (including email addresses), if you use the “Contact Us” form;
- Subscribing to our email newsletters and registering for or attending our online events; and
- Participating in our online surveys or the online promotions sponsored by us, even if you choose to submit your entry for a particular online promotion by U.S. mail. We may also retain your entry form.
We may also gather information about your use of the tools and content we make available at, and your activities on, this Website.
Information We Collect through Automatic Data Collection Technologies
As you navigate through and interact with our Website and online content, third-party service providers we have retained to view and analyze website traffic and activity may:
- Use automatic data analysis technologies to collect information that does not personally identify you;
- Provide us with details of your visits to our Website or our online content, which may include your IP address, your geo-location, the domain from which you access the Internet, the date, time and duration of your visit to the Website or to our online content, the specific pages, links and forms you access during your visit, the resources that you access and use on the Website, and whether you are a new or a returning visitor to this Website;
Gather information about your Internet connection, the type of device you use to visit the Website and your operating system and browser type, and the website (such as www.google.com or www.bing.com) or referral source (such as an advertisement or social media site) that directed you to this Website; and
Collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). To opt out of behavioral tracking on this Website you should disable your browser’s ability to accept cookies (see definition below).
The information we collect automatically is mainly about content viewership and statistical data, but it may include personal information, or we may maintain or associate the statistical data we gather with personal information we collect in other ways or receive from third parties.
The technologies we use for this automatic data collection may include the following.
- A cookie is a small text file placed on your computer or mobile device when visiting a website. Cookies are then sent back to the originating website on each subsequent visit or to another website that recognizes the cookie in order to develop a record of the visitor’s online activity. Cookies on this Website may be placed by this Website, one of our third-party service providers, or in association with email messages you receive from us.
Certain cookies are required in order for you to navigate this Website and access our content and tools. These cookies do not gather personal information and cannot be disabled.
We use Google Analytics cookies and scripts to gather information about the use of the Website by visitors. The Google Analytics system immediately aggregates the information. Both Google and we may see the aggregated data from all visitors for a particular time period. See https://support.google.com/analytics/answer/6004245 for a summary of the privacy of the Google Analytics cookies.
We use a sales enablement program that places a cookie when you open a link to or view our online content and tracks your usage of that online content for sales purposes. To opt out of this tracking, you should follow the instructions in the email in which the link was included.
We also use a marketing database program that places a cookie when a recipient interacts with our marketing emails or visits this Website. This cookie can connect website visitors to personal information we have on file, such as a name, the pages visited on the Website, from where the visit originated and content accessed at the Website. To opt out of this tracking, you should disable your browser’s ability to accept cookies.
Certain pages of our Website and our marketing emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, or single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened that email and for other related Website statistics (for example, recording the popularity of certain website content).
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information, for our everyday business purposes, such as to:
- Present our Website and its contents to visitors and to improve visitor experience with this Website over time;
Deliver a more personalized service by storing information about your preferences, allowing us to customize our Website according to your individual interests, speed up your searches and recognize you when you return to our Website;
Conduct market research;
Engage in corporate reporting and management;
Provide you with the information that you request from us;
Use the information in any other way that we may describe when you provide us with personal information; and
Use the information for any other purpose, with your consent.
We may also use your information to tailor marketing to your interests, to contact you about our and our affiliates’ products and services that may be of interest to you, such as telephone calls or print advertising materials from your Ivy wholesaler, to send you email newsletters, to provide you with announcements and notify you of upcoming events. For more information, see Choices About How We Use and Disclose Your Information.
Disclosure of Your Information
We may also disclose personal information:
- To a buyer or other successor in the event of 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 visitors to our Website is among the assets transferred;
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- If we believe that disclosure is necessary or appropriate to protect our rights, property, or safety of our employees, our clients, or others.
Retention of Your Information
We only retain the information we collect ourselves and through Google Analytics and our other third-party service providers as long as necessary to complete the purpose for which the information was collected, or as required by applicable law and our record retention policies.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. The following are the options for you to exercise control over your information.
- You may choose not to provide us with personal information. Sections of our Website that require a login are inaccessible without providing certain personal information.
- If you do not want us to use your contact information to promote our products and services and the products and services of our affiliates, you may send us an email stating your request to email@example.com.
Accessing and Correcting Your Information
You can request access to, review and change your personal information by sending an email to firstname.lastname@example.org to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your account. We may not accommodate a request to change information if we believe the change would violate any law or regulatory requirement or cause the information to be incorrect.
We have implemented administrative, physical and technical safeguards designed to reduce the risk of accidental loss or unauthorized access, use, alteration, or disclosure of personal information in our possession or under our control.
The safety and security of your information also depends on you. Where you have chosen a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.