WisdomTree maintains a variety of product-specific websites and applications. The privacy policies we post on those websites and applications govern how we handle personal information in connection with those specific products or services.
Personal Information We Collect
Information you provide to us includes:
- Contact details such as your first and last name, organization name (if applicable), address, email and phone number.
- Account data such as the username and password that you may use to establish an online account with us.
- Communications that we exchange with you, including when you contact us with questions, feedback or otherwise.
- Marketing data such as your preferences for receiving our marketing communications and details about your engagement with them.
- Job applicant data when you use the “Careers” section of the services, such as your employment history, and as otherwise described in the Job Applicants section below.
Automatic data collection. We, our service providers and our business partners may automatically log and combine information about you, your computer or mobile device, and your interaction over time with the services, online resources and our communications, such as:
- Device data such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings and general location information such as city, state or geographic area.
- Online activity data such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the services, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access and whether you have opened or otherwise engage with our communications, such as our marketing emails or clicked links or files within them.
Third party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
- Institutional clients that provide us with data on their affiliated financial advisors.
- Financial advisors who may input their client information to use certain tools and solutions.
- Market data reporting companies that provide us with financial services industry data, insights, and analytics.
- Marketing partners such as companies that have entered into joint marketing relationships with us.
- Social media companies such as LinkedIn, Twitter and YouTube, when you interact with our profiles on those services.
- Publicly available sources such as government databases.
How We Use Personal Information
We use personal information for the following purposes or as otherwise described at the time of collection:
Communicate with you about our services. It is in our legitimate business interests to use personal information to respond to your requests, provide customer support, and communicate with you about our services, including by sending announcements, updates, security alerts and support and administrative messages.
Improve, monitor, personalize, and protect our services. It is in our legitimate business interests to improve and keep our services safe for our users, which includes:
- understanding your needs and interests, and personalizing your experience with the services and our communications;
- troubleshooting, testing and research, and to keep the services secure; and
- investigating and protecting against fraudulent, harmful, unauthorized or illegal activity.
Research and development. We may use personal information for research and development purposes in our legitimate business interests, including to analyze and improve the services and our business. As part of these activities, we may create or use aggregated, de-identified or other anonymized data from personal information we collect. We make personal information into anonymized data by removing information that makes the data personally identifiable to you. We may use this anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the services and promote our business. For example, we use anonymized traffic statistics from Google Analytics to recognize and count the number of visitors to the website and to see how visitors move around the website when they are using it to enable us to improve the way the website works.
Marketing and advertising. We, our service providers, and our third-party advertising partners may collect and use personal information for the following marketing and advertising purposes:
- Direct marketing. We may send you WisdomTree-related direct marketing communications as permitted by law, including by email. You may opt out of our marketing communications as described in the Opt-out of marketing communications section below.
Except where consent is required, we undertake such marketing and advertising on the basis of our legitimate business interest. Where we seek your consent, you may withdraw your consent at any time.
Compliance and protection. We may use personal information to comply with legal obligations, and to defend us against legal claims or disputes, including:
- protecting our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- auditing our internal processes for compliance with legal and contractual requirements and internal policies;
- enforcing the terms and conditions that govern the services;
- preventing, identifying, investigating and deterring fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
- complying with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
How We Share Personal Information
We may share personal information with the following entities:
Service providers. Companies and individuals that provide services on our behalf or help us operate the services or our business (such as hosting, information technology, customer support, email delivery and website analytics services).
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, WisdomTree (including, in connection with a bankruptcy or similar proceedings).
Advertising partners. Third party advertising companies, including for the interest-based advertising described above, that may collect information on the website through cookies and other automated technologies.
Privacy Rights and Choices
Update your information. If you have a WisdomTree account, you can review and update certain account information by logging into your account. You may also contact us to request deletion of your account and certain personal information. If we delete your account, you will not be able to access it.
Opt-out of marketing communications. You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us. If you have a WisdomTree account, you may also manage your subscriptions by logging into your account and updating your subscription preferences in your account. You may continue to receive services-related and other non-marketing emails.
Personal information requests. We also offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our services, you may request the following in relation to personal information:
- Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
- Correction of personal information that is inaccurate or out of date.
- Deletion of personal information that we no longer need to provide the services or for other lawful purposes.
- Additional rights, such as to object to and request that we restrict our use of personal information.
To make a request, please email us or write to us as provided in the “How to Contact Us” section below. We may ask for specific information from you to help us confirm your identity. California residents can empower an “authorized agent” to submit requests on their behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.
Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “How to Contact Us” section below.
Other Sites and Services
We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of personal information. You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, email sent to or from the services may not be secure, and you should therefore take special care in deciding what information you send to us via email. Moreover, where you use passwords, ID numbers, or other special access features on the services, it is your responsibility to safeguard them.
Retention of Personal Information
Where required under applicable laws, we retain personal information only for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable).
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.
How to Contact Us
250 West 34th Street, 3rd Floor
New York, NY 10119