Privacy Policy

Your privacy is a priority at Research Affiliates, LLC and its sister company, RAFI Indices, LLC (individually, “RA” and “RI”, respectively, and together the "RA Companies," “we,” “us,” or “our”).  This privacy policy (the “Privacy Policy”) describes our approach to the collection, processing, storage, and use of the information that we collect from you.

We understand that you have entrusted us with private information and we care about your privacy.  For purposes of certain data protection laws, the RA Companies are considered the “controller” with respect to your Personal Information.

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 and related to events that we may hold.  This Privacy Policy does not apply to information we formally collect from our current and former clients, who should refer to our Client Privacy Notice, as previously provided to our clients.  This Privacy Policy also does not apply to information that we collect about our employees.  If you are an employee, please refer to our Employee Privacy Policy that was previously provided to you.

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 publicly-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. 

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

For Visitors: As a Visitor, we will collect automatically, internet or other electronic network activity information, including, but not limited to, referring URL, browser, operating system, device type, and Internet Protocol (“IP”) address.  If you consent to our collection of cookies as set forth below in Cookies Policy, for example by affirming acknowledgement upon visiting our Websites, we will also collect additional internet activity information as described in that section.

For Registered Users: As a Registered User, we collect information that you provide us, including:

• Identifiers, such as your name, employer, email address, postal address, phone number, and, in limited circumstances, your tax identification number.
  
• Dietary information, in some circumstances, if you attend one of our events.

We may also collect Internet or other electronic network activity information, such as 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 collection of cookies as set forth below, for example by affirming acknowledgement upon visiting our Websites, we will also collect additional internet activity information as described in that section.

The Information that we collect is used by us for the performance of a contract with you (or on your behalf), based on your consent, where it is requested and provided, or on the basis of our legitimate business interests, including for client service, marketing, business development purposes, to improve our Websites and services, for legal and regulatory purposes, and to conduct analytics.

The RA Companies do not sell any of your Information and has not done so in the last 12 months, and the RA Companies have not shared any of your Information for cross-context behavioral advertising purposes in the last 12 months.

We use your e-mail address to acknowledge your comments and/or reply to your questions, and we will store your communication and our reply in case we correspond further. Unless prohibited by law, we may use your e-mail address to send you information about offers on products and services that we believe may be of interest to you. If you don't want us to contact you by e-mail with offers on products and services, you may tell us so at any time.  If you have asked us to put you on an e-mail mailing list to provide you with certain information on a regular basis, or if we send you information about our offers on products and services by e-mail, you may ask us to remove you from the list and your Personal Information at any time (using the unsubscribe instructions provided with each e-mail and on the site where you signed up).

The RA Companies may share certain Information described above, in whole or in part, for business or commercial purposes with non-affiliated third parties in the following circumstances, or in other circumstances where there is a legitimate business purpose:

1. We may 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.
   
5. We may share your information if we believe it is necessary in order to investigate, prevent or take action regarding inappropriate or illegal activities, fraud, or situations involving potential threats to the safety of any person or property.
   
6. We may share your information as part of a corporate transaction with a successor or affiliate or in connection with any acquisition, merger or sale of assets.

However, the RA Companies will not share your phone number or opt-in consent with third parties for marketing or promotional purposes.

The RA Companies are established and store data in the United States.  As such, any Personal Information processed by us will be processed there. An adequacy decision has not been made by the European Commission in respect of the United States.

Where privacy laws impose restrictions on the transfer of Personal Information, your Personal Information will be transferred to and stored by us upon any of the following conditions:

• the transfer is necessary for the performance of a contract between you and us, or if the transfer is necessary for the performance of a contract between the RA Companies and a third party, and the contract was entered into in your interest;
• the transfer is necessary to establish, exercise or defend legal claims or to protect your vital interests; or
• the transfer is made pursuant to Standard Contractual clauses approved by the European Commission as ensuring adequate safeguards.

We take steps to protect your Information from loss, misuse, and unauthorized access or disclosure.  Such steps include physical, electronic, and procedural safeguards.  For example, we make use of firewall barriers, encryption techniques and authentication procedures.  Additionally, we restrict access to Information to only those employees and agents required for legitimate business purposes.

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.   For example, e-mail sent over the Internet is generally unencrypted. If RA requests that you transmit confidential information to us over the Internet when filling out an application online, we use secure forms to encrypt such transmission. We recommend that you use caution when forwarding free-format e-mail messages to us and that you do not include confidential information (such as account numbers) in those messages, as they are not encrypted.

Individuals in Andorra, Argentina, Australia, California, Canada, Colorado, Europe, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, Virginia, the United Kingdom, Uruguay, and certain other jurisdictions may have certain data subject rights. These rights vary, but they may include the right to: (i) request access to and rectification or erasure of their Personal Information; (ii) restrict or object to the processing of their Personal Information; and (iii) obtain a copy of their Personal Information in a portable format. Individuals may also have the right to lodge a complaint about the processing of Personal Information with a data protection authority.

If you wish to exercise any of these rights please email dataprivacy@rallc.com with the phrase “Data Subject Rights” in the subject line. You may also call us toll-free at 888-412-1255 or complete this web form. We will review your requests and respond accordingly. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. Additionally, if we retain your Personal Information only in de-identified form, we will not attempt to re-identify your data in response to a Data Subject Rights request.

Additionally, applicable laws allow interested parties to “opt out” of only certain kinds of information- sharing with third parties. We do not share Personal Information of any interested party that triggers the “opt out” rights with any third parties. Further, we do not discriminate against any individuals who wish to exercise their rights to “opt out” or delete their Personal Information.

If you make a request related to Personal Information about you, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying the request. For requests related to particularly sensitive information, we may require additional proof of identification.

If you make a Data Subject Rights request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf.

We will process your request within the time provided by applicable law.

Research Affiliates, LLC uses cookies on our website to distinguish you from other users of our Websites. Our objective is to optimize your experience when you browse our Websites and to continually improve our Websites. This cookies policy provides you with information about the types of cookies we use and the purposes for using those cookies. For further information about this policy, please contact our Compliance Department at compliance@rallc.com.

A cookie is a small file that is stored on your web browser or the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive.

Two common types of cookies with different storage durations are, "session cookies" and "persistent cookies". Session cookies store information only for the length of time that you are connected to a website through a browser - they are not written onto your hard drive. Once you close the browser, the cookie is removed.

Research Affiliates uses session cookies as an additional security feature for its online services. For example, when you login to any web service and are authenticated through your login ID and password, a cookie will store the identification number of your browser. Throughout your session, the cookie acts as a type of digital signature to identify your current session to the web server.

We also use session cookies, to track your visits within our Websites. We use that information to determine the type of information that you are looking for in our Websites and to improve our Websites. We use information about the site you visited immediately prior to our Websites to assess the viability of links to our Websites that we have created on third party sites.

The information stored in "persistent cookies" is written onto your hard drive and remains there until the expiry date of the cookie. Research Affiliates uses persistent cookies to store non-sensitive information as set forth below.

The cookies used on our Websites are generally categorized as follows:

A. Strictly Necessary
'Strictly Necessary' cookies allow you to enter and move around the Websites and use the Websites’ features. Without these cookies, services and information you have asked for cannot be provided. We use these Strictly Necessary cookies primarily to identify you as having confirmed your eligibility to enter and use our Websites, and to assure that you connect to the correct service on our Websites after we make any changes to the way the Websites work. Consenting to the use of these cookies is not a condition of using the Websites, however, if you do not consent, you will be redirected to a static website with limited information.

B. Performance
'Performance' cookies collect information about how you use our Websites, such as which pages you visit. These cookies may collect information that could identify you and are only used internally and confidentially to help us improve website performance and understand what interests our users. We use performance cookies for: (1) Analytics, to provide statistics on how our Websites are used; (2) Error management, to help us improve the Websites by measuring any errors that occur; and (3) Design testing, to test different designs of our Websites to improve users' experiences.

C. Functionality
'Functionality' cookies help to provide services or to record settings to improve your visit. We use Functionality cookies to identify when you've visited our site before and any personal settings or configurations you may have saved.

D. Third Parties
Some of our Performance and Functionality cookies are managed for us by certain third parties. Third Parties are not allowed to use the cookies for any purpose other than those listed above.

D. Information Collected by Cookies
Information gathered through cookies may include the date and time of visits to our Websites, IP addresses, the pages viewed, time spent at our Websites, the websites visited just before and just after our Websites and information about the device and software used to access our Websites. 

F. Withdraw Consent, Delete, or Block Our Cookies
You can change your cookie preferences by using the settings on your web browser that allows you to delete or refuse the setting of cookies. Disabling cookies from your web browser will disable all cookies used by your browser, including those from other website, which may cause certain setting or information to be altered or lost.

You can easily accept or reject the cookies on this site by choosing the appropriate link on our site. The cookie consent is valid for up to 12 months.

For further information about deleting or blocking cookies, please visit: www.allaboutcookies.org.

We may use third-party web analytics services (such as those of Google Analytics) and other technologies on our Services to collect and analyze usage information through cookies and similar tools; engage in activities such as auditing, research, or reporting; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here (https://tools.google.com/dlpage/gaoptout).

Do Not Track:  Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not currently recognize or respond to browser-initiated DNT signals.

We will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy, or as long as we are legally required or permitted to do so (subject, under certain circumstances, to any right you may have to have your Personal Information erased).

When deciding how long to retain your Personal Information, we take into account our legal and regulatory obligations; the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure of your Personal Information; the purposes for which we process your Personal Information described above and whether we can achieve those purposes through other means.  We may also retain your Personal Information to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.

We may make changes to this Privacy Policy from time to time.  If we decide to change our Privacy Policy, we will post the updated Privacy Policy at https://www.researchaffiliates.com/legal/privacy-policy, so that you are aware of the kinds of Personal Information we collect, use, share, and otherwise process.  If you do not agree with the changes, please discontinue use of the Websites.  By continuing to access and/or use the Websites after notice of such changes, you are deemed to have acknowledged any such changes. 

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