Overview of Privacy Policy

A. Application

This Privacy Policy applies to information we collect through our websites, www.researchaffiliates.com and www.rafi.com (the “Websites”), as well as through email or other electronic messages. 

B. Access to the Websites

We provide Visitors and Registered Users with access to the Websites as described below.

• Visitors:  Visitors are individuals who do not create a login and can only access publically-available features and functionalities of the Websites.
• Registered Users:  Registered Users are individuals who create a login and can access public as well as password-protected areas of the Websites.  Registered Users are also considered those individuals who provide personal information in connection with an event registration form created by the RA Companies. 

C.  Collection of Information

We may collect information as described below (collectively, the “Information”).

• For Visitors: As a Visitor, if you consent to our Cookies Policy, we will collect information that identifies you or your computer automatically through the use of cookies.
• For Registered Users: As a Registered User, we may collect your name, employer, email address, postal address, phone number, and, in limited circumstances, your tax identification number. Additionally, we may collect analytic information relating to your use of the Websites, including, but not limited to, the areas of the Websites you view, the number of times you visit specific areas of the Websites, the amount of time you spend on specific areas of the Websites, your visit dates, your exits to partner sites, your geolocation information, etc. If you consent to our Cookies Policy, we will also collect information that identifies you or your computer automatically through the use of cookies. 

D. Use of Information

The Information that we collect is used by us for client service, marketing, business development, regulatory and analytics purposes. 

E. Sharing of Personal Information

The RA Companies do not sell any of your Information.

The RA Companies may share your Information, in whole or in part, with non-affiliated third parties in the following limited circumstances:

1. We disclose your Information to companies that assist us in the servicing of your account.
2. We may enter into "joint marketing relationships" with third-party financial institutions. If we enter into such relationships, we will ensure that such third-parties are contractually required to protect the confidentiality of any Information provided.
3. We may share lists of RA event attendees and clients (to the extent permitted) in addition to aggregated, non-personal data with our affiliates, agents, business and promotional partners, and other third parties.  We may also disclose aggregate statistics in order to describe the Websites to current and prospective business partners, or other third parties.
4. We may disclose or report your Information to the extent we reasonably believe that the law requires disclosure or reporting. For example, disclosure of your Information may be required to cooperate with regulators or law enforcement authorities for institutional risk controls or authentication checks. 

F. Security and Protection of Your Information

We take commercially reasonable steps to protect your Information from loss, misuse, and unauthorized access or disclosure.  Such commercially reasonable steps include physical, electronic, and procedural safeguards.  For example, we make extensive use of firewall barriers, encryption techniques and authentication procedures. Additionally, we use best efforts to:

1. Ensure that any third parties with which we share your Information maintain strict confidentiality procedures and data privacy frameworks, and only use your Information as expressly authorized by us;
2. Restrict access to Information to only those employees and agents required for legitimate business purposes; and
3. Contractually require our employees to maintain the confidentiality of Information we collect.
4. The Information we collect is maintained in secure locations, and is mapped and overseen by the RA Companies’ Data Protection Officer.  The RA Companies’ Data Protection Officer and Compliance Department conduct periodic reviews to monitor access and use of the Information.
5. Despite the steps we take to protect your Information, please be aware that we cannot guarantee the security of our databases or the databases of the third parties with which we may share your Information.  We also cannot guarantee that the Information will not be intercepted while being transmitted over the internet, such as via e-mails you send to us. 

G. Your Rights

We make every effort to keep your Information accurate and up-to-date. Please contact us at dataprivacy@rallc.com if you:

• Identify any inaccuracy in your Information;
• Wish to make a change to your Information;
• Wish to make a request for access to your Information; or
• Wish to request that we delete your Information.

The RA Companies will respond to such requests within the timeframes required under applicable laws.   

H. Data Breaches

In the event of a data breach, the Data Privacy Officer and the RA Companies will take any and all reasonable steps necessary, which may include technical measures to limit further breaches and informing affected parties and authorities.

I. Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time.  By continuing to access and/or use the Websites, you are deemed to have accepted any such changes. 
 

Contact

If you have any questions or concerns regarding this policy, please contact us at compliance@rallc.com or compliance@rafi.com.