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.
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 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.
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 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.
Collection of Information
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.
Use of Information
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.
International Transfers
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.
Security and Protection of Your Information
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.
Your Rights
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.
Other Technologies
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.
Retention of Your Personal Information
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.
Changes to this Privacy Policy
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.
Contact
If you have any questions or concerns regarding this policy, please contact us at compliance@rallc.com.
