Privacy Policy

This Privacy Policy applies to any website (all references to the singular shall include the plural where applicable), including ETF Strategy Hub (hub.etfstrategy.com), which links to this policy and is published by ETF Strategy Limited.

If you wish to amend any of the personal information that we hold about you, you can do so at any time by contacting us.

If you have any queries about how we use your personal information, please contact our Managing Director (simon.smith@etfstrategy.com).

Information we collect

This section details the information we may collect about you. We explain why, and how, we use it in later sections.

Account information

If you decide to register to become a Member, we may ask you to provide us with some specific information, for example:

• Basic personal details (e.g. Full Name)
• Work contact details (e.g. email, telephone number)
• Employment details (e.g. job title, company name)
• Log in details

Information we obtain through cookies and similar tools

We use cookies (and similar technologies) and analytics tools across the Website to collect information about you. This information can be used to improve the performance of the site and enhance your user experience. We provide information about cookies within our Cookies statement.

Lawful basis for processing

We only process personal information where we have a lawful basis for doing so, such as the following:

• User consent
• Legitimate business purposes
• Contractual necessity
• Legal obligation

How we use your information

We collect information for nine main reasons:

• To provide our service – We require some of your basic personal information so our services work as you would expect, for example, delivering notifications of new Content to your correct email address or providing CPD certification
• To improve and maintain performance
• To monitor compliance with our User Agreement, policies and terms
• To personalise our products and services – We improve your experience of our products and services by personalising parts of our Websites with the information you give us and what we learn about you. This includes showing you Content you may be interested
• To communicate product changes and offers
• To pass on to our Partners when you view their Content

Who we share your personal information with

Where relevant and applicable, we will disclose your information to certain third parties. Commonly, we will disclose information to:

• Partners – We share information with our sponsor Partners (including ETF issuers, index providers, market makers and authorised participants) who produce, either independently or in collaboration with us, Content (such as webcasts, videos, podcasts and white papers) that is published on the Website. Information we may pass on to our Partners may include your name, the company you work for, your job title, telephone number and company email address, and details of the Content and/or types of Content that you have viewed. We will only ever disclose information relating to your professional employment and your use of the Website, which, by definition, is in an exclusively professional capacity. Our Partners may contact you directly and their use of your information and data will be governed by their privacy policy. If you do not want your details to be passed on to our Partners, you must not use the Site or access any of the Content published on it. If you do not wish to accept this term, please do not register to become a Member. If you are already a Member but decide that you no longer wish for your information to be passed on to our Partners, you must immediately cease using the Site and desist from accessing any Content. In this instance, you are advised to terminate your membership forthwith.
• Advertisers and sponsors – We share aggregated, non-identifiable information with third parties. Before sharing this information, we ensure that it cannot identify you as an individual. For example, we may release information about the size and growth of our digital audience
• Legal processes and successors in title – We may also disclose your information to comply with applicable laws, court orders or other valid legal processes, and to enforce or apply our terms of use, any subscription agreement, or any of our other rights. We may transfer or disclose your personal information to any entity which takes over or acquires the relevant ETF Strategy business.

How long we retain your personal information

We retain the majority of your personal information for as long as your membership is active and therefore open; this allows you to continue accessing our content, products and services.

If you become inactive, we may delete elements of the information associated with your account. We will normally warn you if your access is going to be withdrawn and give you the opportunity to retain your account.

Where we don’t need to keep all of your information in full, we will obfuscate or aggregate it, for example, web activity logs and survey responses. This is to ensure that we do not retain your information for any longer than is necessary.

It is sometimes necessary for us to keep your information for longer periods of time, for example: If there is a statutory requirement to retain it; If we require the information for legal reasons or there is a legitimate business need for us to retain it; To ensure we do not contact you if you have asked us not to.

How we keep your personal information secure

We have endeavoured to put appropriate technical and administrative security measures in place to help ensure that our users’ information is protected against unauthorised or accidental access, use, alteration, or loss.

Your rights

Under data protection laws, you have rights as an individual in relation to any personal data we hold about you. You can exercise these rights through your account or by contacting our Managing Director (simon.smith@etfstrategy.com). You also have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner’s Office (ICO).

Other

The Website is not intended for non-investment professionals or individuals under the age of 18. The Website is designed only for use by Professional Investors with discretionary investment authority or influence. If you are not a professional person working in investment management or in an investment research or investment support role, you must not register or gain access to the Website and its Content. Moreover, the Content of this Website is additionally designed only for use by Professional Investors who are based in Europe, including the United Kingdom, the Channel Islands, European Union and European Economic Area countries, and Switzerland. If you are not based and authorised to practise in Europe, you must not register or try to gain access to the Website and its Content. You represent and warrant that you are 18 years of age or older and are fully able and competent to enter into and abide by this policy.

Our Websites contain links to third-party websites which are not subject to this privacy policy. We are not responsible for their content, use of personal information, or security practices.

Please also read our  User Agreement and Cookies statement.

If you have a query in regards to the processing of your information, please contact our Managing Director (simon.smith@etfstrategy.com).

ETF Strategy Limited
8 Denmark Street
London WC2H 8LS

This policy is effective from 10th December 2021.