LAST UPDATED: December 29, 2022
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual, including but not limited to:
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.
We and our service providers may collect Personal Information in a variety of ways, including:
We and our service providers may use Personal Information for our legitimate business interests, including the following:
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:
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” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as:
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.
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.
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.
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.
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:
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.
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).
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.
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.
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.
Categories of Personal Information Collected: We collected the following categories of Personal Information:
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:
“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:
(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.
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.
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:
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?
Post: Level 17, 469 La Trobe St Melbourne VIC 3000
Phone: (03) 9903 6700