IR3 ONLINE PRIVACY STATEMENT
State Street Bank and Trust Company, its parent and all other related affiliates and subsidiaries (collectively "State Street") respects your privacy and values our relationship with you. This Online Privacy Statement (the "Privacy Statement") applies to our privacy practices for the handling of information relating to your use of our online services (the "Services"), including all use of such Services through mobile computing devices (each, a "Mobile Device"). This Privacy Statement describes the types of personal and non personal online information which we collect when you access State Street's Site, how we may process that information and with whom we can share it.
State Street's goal is to provide you with a personalized Internet experience that delivers the information, resources, and services that are most relevant and helpful to you. To achieve this, we may collect personally identifiable information ("Personal Information") as well as anonymous information as you access and use the Services. Personal Information is information that can be used to uniquely identify you, such as your name, job title, telephone number and e-mail address. Anonymous information is information that tells us what you do on the Site, such as functions utilized, searches conducted, the time of day you visited the Site without telling us who you are. Any information gathered is confidential and is used in the delivery of the service you have requested and to allow State Street to improve the service and your on-line experience.
This Privacy Statement also describes the measures we take to protect the security of your information. We will not disclose or provide Personal Information about you to any third party for any purpose without your written consent, except as described in this Privacy Statement.
Please read this online Privacy Statement carefully. Your use of the Site or the Service, including your input of any Personal Information into the Mobile Device or the Site, is subject to and governed by this Privacy Statement. State Street may change this Privacy Statement at any time without prior notice to you. Any changes or updates will be effective immediately upon posting to the Site. It is your responsibility to check the Privacy Statement each time you use the Site and/or the Services. By accessing the Site or the Services, you agree to the terms of this online Privacy Statement. The effective date of the Privacy Statement is indicated above.
This Privacy Statement supplements any other Privacy Statement that you may have received from State Street. This Privacy Statement applies only to the use of the Site and the Services.
TYPES OF PERSONAL INFORMATION WE MAY COLLECT
State Street or one of our service providers will collect Personal Information that you voluntarily provide via your Mobile Device when you elect to use our Services. For example, in order to use the Services, you will be required to input your State Street User ID or e-mail address. The Services are password protected. Accordingly, once you submit your user ID and password, State Street will recognize who you are and collect all information that you submit, including all electronic instructions (including all transaction information). Any information collected about you may be associated with other identifying information that we have about you or that is publicly available from other sources.
State Street may collect information on certain technical information regarding your Mobile Device, such as the operating system, unique identifier, and model name of your Mobile Device, as well as its user configurations and settings. We may also collect information relating to your use of the Site and our Services.
The information that we collect enables State Street to provide you with access to the Site and the Services on your Mobile Device. State Street uses the information that it collects about and from you to offer you an enhanced, personalized online experience on your Mobile Device or our Site and third-party websites linked to our Site. We can use this information to better tailor and personalize our Services. We also use it to authenticate you as an authorized user and to facilitate communications between us that you request.
Other than the collection of information as described in this Privacy Statement, we will not collect Personal Information about you when you use the Site or the Services, unless you choose to directly provide such information to us when contacting us. We will use your Personal Information to process your request and, when applicable, respond to you. By contacting us in this manner, you consent to the collection and the use of your Personal Information for purposes of responding to your request and in the support of services requested.
State Street recognizes that certain jurisdictions have enacted laws that require higher protection of certain sensitive personally identifiable information, such as state or national ID numbers, or other information regarding racial or ethnic origin, political opinions, religious or political beliefs, trade-union membership, health or medical records, or criminal records ("Special Data"). State Street does not require such Special Data from you, and you should not input such information if someone asks you.
HOW WE COLLECT INFORMATION
State Street may periodically collect information from you through automated means when you use the Site or the Services.
Cookies are common on the Internet, and many Web browsers are initially configured to accept cookies automatically. If you would prefer not to accept cookies, you can set your Web browser to prompt you before you accept a cookie or to refuse all cookies automatically. However, if you choose not to accept cookies from the Site, then you may not be able to access and use all or part of the Site or benefit from the information and services which it offers. To read just your Web browser's cookie options, please refer to the documentation of your particular browser, or seek online assistance. It is important to note that cookies do not capture any information that can personally identify you or enable a third party to contact you via telephone, e-mail or postal mail.
- Unique Device Identifiers. When you access the Site or the Services, we collect the unique identifier of the Mobile Device you use to connect to the Internet. This unique identifier helps to facilitate communications which you have elected to receive from us.
- Information that you Input. State Street also will collect information that you key into the Device, such as your password and User ID. In addition, State Street may collect your feedback and opinions (for example through surveys) for business purposes, such as improving processes or user experience. You may respond to these surveys or elect not to respond.
HOW WE USE AND SHARE PERSONAL INFORMATION
The purposes for which your information may be processed include but are not limited to the following:
- State Street may use Personal Information in order to operate our business in a prudent manner in accordance with industry standards and applicable law, which may include, in addition to supporting the Services; responding to inquiries and requests; prevent fraud; and monitoring and archiving communications.
- State Street may disclose or share nonpublic personal information about its customers to its affiliates, as permitted by law, in order for its affiliates to provide services. This may, where permitted by local law, include archiving your Personal Information in a jurisdiction other than your own, which may not have equivalent data protection laws.
- State Street may also share Personal Information with government agencies, exchanges, or other self regulatory organizations and law enforcement authorities as required or permitted by law, rule, regulation or legal process, including, without limitation, for governmental reporting or to enforce any rights State Street may have against you as necessary. Information about you that is available to you via the Site or the Services, including any of your financial information, can become subject to the legal systems and laws in force in each state or country (a) where it is held, received or stored by you or us, (b) from where it is accessed by you or us, or (c) through which it passes. In addition, because your account(s) may include information about more than one individual and about your business relations with State Street and its affiliates, statements released to comply with legal process may contain information regarding your relationship with these individuals and with us and our affiliates.
- State Street may disclose your Personal Information (i) at the request of a bank or other regulatory agency or in connection with an examination of us by bank or other examiners; (ii) to our internal or external auditors or attorneys; (iii) when State Street believes disclosure is necessary or appropriate to prevent physical harm or financial loss in connection with an investigation of suspected or actual illegal activity, (iv) to an internet service provider or any other third party agent or service provider for any purpose related to offering, providing, administering or maintaining the Services and/or (v) if disclosure is necessary to protect the vital interests of a person.
- State Street does not sell or rent Personal Information. State Street may disclose or share Personal Information about its customers to nonaffiliated third parties with whom it has contracted to perform services on its behalf. State Street requires its third-party servicers to agree to comply with appropriate privacy and security standards or to undertake to provide similar and appropriate levels of protection as State Street when processing Personal Information. In addition, State Street may share Personal Information and other data collected through the Site and the Services with a successor entity in the event of a merger, acquisition or similar transaction.
- State Street does not disclose nonpublic personal information about former customers, except as permitted or required by law.
HOW WE TRANSFER AND STORE PERSONAL INFORMATION
State Street will transfer Personal Information to the United States and may transfer Personal Information to other countries where State Street does business, which may not have the same data protection laws as the country in which you reside. The transfer of Personal Information to other countries is based on a business need or to comply with applicable laws. Personal information stored or processed in a foreign jurisdiction may be accessed under a lawful order made in that jurisdiction. By providing your information to State Street in the course of your access and use of the Site or the Services, you explicitly consent and opt in to your Personal Information being transferred to and stored in other countries, including the United States, for the purposes explained in this Privacy Statement.
HOW WE PROTECT PERSONAL INFORMATION
Our practices are designed to ensure that Personal Information is:
- Relevant to and not excessive for the purposes for which it is collected;
- Kept up-to-date, with necessary steps taken to correct or delete information that is inaccurate or incomplete if State Street becomes aware of such occurrences;
- Kept only as long as is reasonably necessary for the purposes for which it was collected and processed or, as otherwise required to comply with applicable laws; and
- Subject to appropriate technical and organizational measures to prevent unauthorized access, unlawful processing, and unauthorized or accidental loss, destruction, or damage
- We use encryption technology and other layered security to protect the transmission of data to or from you via IR3 using 128-bit encryption and Secure Sockets Layer. Nevertheless, because information about you and your relationship with us can be accessed through a public network, the Internet, there can be no assurance that your information will remain secure and you accept the risk that unauthorized persons may view such information. If you believe that an unauthorized person has accessed your information, please contact your Client Services Officer immediately.
- To safeguard against unauthorized access to Personal Information by third parties outside State Street, all electronic Personal Information held by State Street is maintained on systems protected by secure network architectures that contain firewalls and intrusion detection devices. The servers holding Personal Information are "backed up" (i.e., recorded on separate media) on a regular basis in an effort to avoid any inadvertent erasure or destruction of such Personal Information. The servers are stored in facilities with appropriate security and fire detection and response system.
- You select your preferred user name and password and these items must be entered every time you sign in to the Site. For information security reasons, you will be instructed to change your password periodically.
- When there is no activity for a certain period of time, your session will be terminated to help protect against unauthorized access.
- State Street limits access to its internal systems that hold Personal Information to authorized users, each of whom are given access through the use of a unique identifier and password, for the sole purpose of supporting the Site and the Services. State Street trains and educates its employees in the handling and safeguarding of Personal Information in accordance with applicable laws, rules, and regulations.
- When you call your Client Services Officer with questions about the Site or the Services, we must confirm your identity on the phone before discussing your information. The questions and answers you select when logging into the Site for the first time are used for this identification process.
HOW YOU CAN PROTECT YOUR ONLINE INFORMATION WHEN USING YOUR MOBILE DEVICE
Along with the security measures used by State Street, there are measures you can take to ensure the security of your electronic Personal Information:
- Log off the Site when you are done viewing your information or whenever you leave your Device.
- Always be careful not to use your Device in a way that permits others to view your personal or other information on your screen.
- Do not store any information that you access via the Site.
- Should you lose your Device, or reasonably conclude that another person may access or have accessed your password on your Device, you should take immediate actions such as changing your Information to limit the potential damage.
- Use all security features of your Device, including the "Passcode Lock" function, as one step to protect your Device and the confidentiality of your information and any other information contained therein.
- Notify State Street immediately if you become aware of any disclosure, loss, theft, or unauthorized use of your information or other security tools or any loss, theft or unauthorized use of your Device.
- Keep your Device updated with the latest security updates and patches.
- Review your Device security settings
- Be wary of e-mails from addresses or people you do not know.
- Avoid using "public" computers or network connections, especially when reviewing financial or Personal Information.
- Keep your password confidential and avoid using the same password for different Web sites.
WHAT IS THE PROCESS FOR REPORTING AND HANDLING SUSPECTED SECURITY INCIDENTS?
State Street is committed to offering our customers the highest level of support possible. If you suspect that there has been any unauthorized breach of your information online, you should notify State Street immediately.
If the circumstances require, security incidents will be escalated to our technical support staff for evaluation. If any breach of security appears to have occurred, State Street will investigate it further. If necessary, State Street will provide you an interim update of our investigations and the status of your case. Final resolution of any such incident, though, will depend on the nature and complexity of the incident, as well as the details surrounding the case.
As a person who provides State Street with Personal Information, you may inquire as to the nature of the Personal Information stored at and/or processed by State Street. You will be provided reasonable access to your Personal Information held by State Street and, where appropriate, with the ability to review and correct inaccuracies. State Street will reasonably cooperate in providing such access. All such requests for access may be made by sending a request in writing to: Client Service Manager.
To help protect your privacy and provide security, State Street takes reasonable steps to verify your identity before granting access to information. State Street shall respond to such reasonable request made by you within such time period as required under applicable law after your identity has been confirmed and you have clarified the specific Personal Information that you require. If you demonstrate that the purpose for which the Personal Information is being processed is no longer legal or appropriate, the Personal Information will be deleted, unless the law or applicable data retention requirements require otherwise.
HOW TO CONTACT US.
If you have questions or comments about this Privacy Statement, or about how your information is processed, please contact Client Service Office Manager.
Effective Date: January 1st, 2012