Privacy Policy

LAST UPDATED: December 29, 2022

PRIVACY POLICY

This Privacy Policy describes our practices in connection with information that we collect through websites operated by ALPS Holdings, Inc. and its subsidiaries (“us” or “SS&C ALPS”) from which you are accessing this Privacy Policy (the “Websites”), through the software applications made available by us for use on or through computers and mobile devices (the “Apps”), through our social media pages (collectively, our “Social Media Pages”) (collectively, including the Websites, the Apps and our Social Media Pages, the “Services”). By using the Services, you agree to this Privacy Policy. The Privacy Policy also describes our practices in connection with information that we collect in person, over the phone, via email and from affiliates and third parties. Fund investors should refer to a fund’s privacy policy.

PERSONAL INFORMATION

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual, including but not limited to:

Name
Postal address (including billing and shipping addresses)
Telephone number
Email address
Profile picture
Social media account ID

We may need to collect and process these types of Personal Information in order to provide the requested Services to you, or because we are legally required to do so. If you do not provide the information that we request, we may not be able to provide you with the requested Services.

Collection of Personal Information

We and our service providers may collect Personal Information in a variety of ways, including:

Through the Services: We may collect Personal Information through the Services.
Offline: We may collect Personal Information from you offline, such as when you attend one of our trade shows.
From Other Sources: We may receive your Personal Information from other sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and from affiliates and third parties. In addition, if you elect to connect your social media account to your Website account, certain Personal Information from your social media account will be shared with us, which may include Personal Information that is part of your profile or your friends’ profiles.

If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information

We and our service providers may use Personal Information for our legitimate business interests, including the following:

To respond to your inquiries and fulfill your requests, complete your transactions, and provide you with related customer service.
To send administrative information to you, such as changes to our terms, conditions and policies, as well as marketing communications that we believe may be of interest.
To personalize your experience on the Services by presenting products and offers tailored to you, and to facilitate social sharing functionality.
For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.

Disclosure of Personal Information

Your Personal Information may be disclosed to our affiliates and is subject to the following policy: https://www.ssctech.com/about-us/privacy. Additionally, personal information may be shared by us to:

Third party service providers who provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.
Third parties, to permit them to send you marketing communications, consistent with your choices.
By you, on message boards, chat, profile pages and blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
To your friends associated with your social media account, to other website users and to your social media account provider, in connection with your social sharing activity. By connecting your Services account and your social media account, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media provider’s privacy policy.

Other Uses and Disclosures

We may also use and disclose your Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include authorities outside your country of residence, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

In addition, we may use, disclose or transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

OTHER INFORMATION

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as:

Browser and device information
App usage data
Information collected through cookies, pixel tags and other technologies
Demographic information and other information provided by you that does not reveal your specific identity
Information that has been aggregated in a manner that it no longer reveals your specific identity

If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.

Collection of Other Information

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

We are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as LinkedIn or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:

Receiving electronic communications from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by clicking the applicable link provided within such marketing-related email and following the instructions for updating your preferences as provided therein.
Our sharing of your Personal Information with affiliates for their direct marketing purposes: If you would prefer that we not share your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt-out of this sharing by clicking the applicable link provided within such marketing-related email and following the instructions for updating your preferences as provided therein.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.

How you can access, change or suppress your Personal Information

If you would like to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us, you may do so by using the self-service functionality within the applicable Service.

RETENTION PERIOD

We will retain your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the Services to you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.

JURISDICTION AND CROSS-BORDER TRANSFER

The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or criminal background) on or through the Services or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy. The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS

This California Consumer Privacy Act Notice provides information for certain California residents in connection with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and their implementing regulations (collectively, “CCPA”). Under the CCPA, and for purposes of this notice, “Personal Information” generally means information that identifies, relates to, or describes a California resident or household and includes the categories listed below. Below are details about the categories of Personal Information of California residents that we have collected or disclosed during the last 12 months. Unless noted otherwise below, references to “Personal Information” include “Sensitive Personal Information” as defined by the CCPA. SS&C ALPS employees should reference the Privacy Policy of SS&C Technologies, Inc. for information regarding Personal Information about you collected and maintained by SS&C ALPS in connection with employment records.

Categories of Personal Information Collected: We collected the following categories of Personal Information:

Identifiers, such as name, contact information, and online identifiers;
Personal information, as defined in the California customer records law, such as employment and government-issued ID numbers;
Internet or network activity information, such as browsing history and interactions with our website;
Professional or employment-related information, such as company name;
Business email content (limited to persons registered with an SS&C ALPS broker-dealer and/or employed by an SS&C ALPS entity); and
Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

Sources of Personal Information. We collected Personal Information directly from California residents themselves in person, over the phone, via email, via the Services and separately from affiliates and third parties.

Purposes. We may use this Personal Information to respond to your requests, provide our products and services, and to accomplish our business purposes and objectives, including, for example, to market our products and services and those of our clients, conduct analytics, comply with law, legal process, and internal policies, and maintain records. Our use of Sensitive Personal Information is limited to that use which is necessary to perform services to which the Sensitive Personal Information relates. We do not utilize “automated decision making technology” with respect to Personal Information.

Disclosures of Personal Information. We disclosed the following Personal Information to our affiliates and service providers for our operational business purposes:

Identifiers, such as name, contact information, and online identifiers;
Personal information, as defined in the California customer records law, such as employment and government-issued ID numbers;
Internet or network activity information, such as browsing history and interactions with our website;
Professional or employment-related information, such as company name;
Business email content (limited to persons registered with an SS&C ALPS broker-dealer and/or employed by an SS&C ALPS entity); and
Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

“Sales” of Personal Information. The CCPA defines a “sale” as the disclosure of Personal Information in exchange for monetary or other valuable consideration. We have not “sold” Personal Information for purposes of the CCPA. The CCPA definition of “sale” does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

“Sharing” of Personal Information. The CCPA defines “sharing” as communicating Personal Information to a third party for cross-context behavioral advertising. We have not “shared” Personal Information for purposes of the CCPA.

If you are a California resident, you have the following rights:

(1) Right to Know. You have the right to request that we disclose to you the following information covering the 12 months preceding your request:

The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
The specific pieces of Personal Information we collected about you;
The business or commercial purpose for collecting Personal Information about you; and
The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information.

(2) Right to Request Deletion. You have the right to request that we delete Personal Information we collected from you.

(3) Right to Request Correction of Inaccurate Personal Information. You have the right to request that we correct inaccurate Personal Information we maintain about you.

To make a request for the disclosures, deletion or correction described above, please contact us at ALPSPrivacy@alpsinc.com or call us at (844) 511-9635. We will respond to your request consistent with applicable law.

In order to verify your identity, SS&C ALPS will provide you with a CCPA request document, which will include a request for information including your name, your home and work addresses, your home and work email addresses and your home (or cell) and work phone numbers. We will also ask you to provide information about your relationship with SS&C ALPS.

If you are requesting disclosure of specific pieces of information maintained by SS&C ALPS, we will ask you to provide a signed declaration under penalty of perjury that you are the “Consumer” whose personal information is the subject of the request.

If you are an “Authorized Agent” making a request on behalf of a Consumer, in addition to the above information regarding the Consumer, we will ask you to provide a copy of a document permitting you to act on behalf of the Consumer, signed by you and the Consumer. SS&C ALPS will also require that the Consumer confirm directly to SS&C ALPS that they provided you permission to submit the request.

(4) Right to Be Free from Discrimination.You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

CONTACTING US

ALPS Holdings, Inc., a wholly-owned subsidiary of SS&C Technologies, Inc, located at 1290 Broadway Suite 1000, Denver, CO 80203, is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy. If you have any questions about this Privacy Policy, please contact us at ALPSPrivacy@alpsinc.com. Because email communications are not always secure, please do not include sensitive information in your emails to us.

IMPORTANT INFORMATION FOR AUSTRALIAN RESIDENTS

Under the Australian Privacy Act 1988 (Cth), as amended, including the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (collectively “Aus PA”)), you (if you are an Australian resident) may have certain privacy rights in connection with your Personal Information (as such term is described in the Aus PA). Some of those rights and disclosure requirements are already outlined in the various Sections above.

Collection of Information

We collect the personal information categories outlined below, which we may disclose to other legal entities within SS&C, third party service providers who host our website or other information technology systems or otherwise hold or process your information on our behalf, under substantially similar conditions of confidentiality and security, and business partners, suppliers and sub-contractors for our operational business purposes:

Identifiers, such as name, contact information, date of birth, gender, tax file number, financial details, online identifiers and any other required information to maintain a super fund’s records in a format that identifies the member. These records are essential to the proper management of a superannuation fund (Fund) and to enable the Fund to provide members with superannuation benefits and may be provided by the Fund to us.
Personal information, as defined in the Aus PA.
We might also collect health information on behalf of our clients to enable death or disability insurance cover from the Fund’s insurer or to process a member’s disability claim. Information about a member’s potential beneficiaries is also held by us or our client.
Professional or employment-related information, such as company name.

Depending on how you choose to interact with us, we may collect your personal information when you contact us by telephone, email, through our website or when you complete an application form.

We do not share or sell your personal information with third parties for such third parties’ direct marketing practices; nor do we sell personal information (as contemplated by the Aus PA) about you that you have provided to us or that we may have collected.

If you are an Australian resident, you have the following rights as set forth in the Aus PA:

Access to and Correction of Personal Information

You can access your own personal information by contacting us. Requests for access to your personal information will be responded to within a reasonable period after the request is made. Access to your personal information will be given in the manner requested by you, if it is reasonable and practical to do so. A fee for providing the requested access may apply.

There are some circumstances in which we are entitled to deny you access to your personal information. These include circumstances where such personal information is used in confidential decisions or in a commercially sensitive decision-making process, where the privacy of others may be breached if the personal information was accessed or where the law requires or authorises such access to be denied.

If access to requested information is refused or not provided in the manner requested, or there is a refusal to correct the information, then written notice will be provided setting out reasons for the refusal and mechanisms available to complain about the refusal.
If we are holding personal information in relation to you that is inaccurate, out of date, incomplete, irrelevant or misleading or you request to correct the information, we will take reasonable action to correct the information to ensure that, having regard to the purpose for which it is held, the information is accurate, up to date, complete, relevant and not misleading.

Transfer of Personal Information Overseas

In certain situations, personal information that we collect may be disclosed to other legal entities within SS&C, third party service providers that operate overseas. This may include India and the United Kingdom that may lead to personal information disclosed to overseas recipients.

Before disclosing personal information overseas, reasonable steps will be taken to ensure the recipient does not breach the Aus PA or the effect is that the information will be protected in at least a substantially similar way in which the Aus PA protect the personal information.

Notifiable Privacy Data Breaches

A data breach happens when personal information is accessed or disclosed without authorisation or is lost. Where we assess that we have reasonable grounds to believe that an eligible data breach has occurred, we will notify you and the Australian Information Commissioner about the breach when a data breach involving personal information is likely to result in serious harm.

How do you Contact Us regarding your rights under the Aus PA?

In addition to the contact details in section 10 of this SS&C group privacy policy, if you have any questions, complaints, feedback, or would like further information about this Australian privacy policy, or if you wish to make a complaint as regards our compliance with the Aus PA when processing your information you can contact us by:

Post: Level 17, 469 La Trobe St Melbourne VIC 3000

Phone: (03) 9903 6700

cont