ETF Managers Group LLC
ETF Managers Group LLC, ETFMG Financial LLC and their respective affiliates (“ETFMG”), and the ETF Managers Trust on behalf of its series (the “Funds”) are committed to respecting the privacy of personal information you entrust to us in the course of doing business.
Information We Collect
We may collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you, your household, or device (“personal information”). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Personal information maintained by financial services firms that is covered under certain exemptions described in the CCPA, such as the federal Gramm-Leach-Bliley Act.
We obtain personal information from various sources, including directly and indirectly from you. For instance, we may receive information from transactions in your accounts, relating to the Funds, and from correspondence between you and us or third parties, such as our service providers. You may provide us your email address by registering to receive email updates and market commentary from us. In addition, our website uses “cookies” and other similar technology to help us measure and track visitors to the website and to collect certain technical and navigational information, such as browser type, internet protocol address, pages visited and time on site. We may also collect personal information from other publicly or commercially available sources.
This policy explains the types of personal information we collect, how we use it, who we share it with, how we protect it, and your legal rights. In the table below, we summarize the categories of personal information we may collect and examples of data within each category.
|Category of Personal
|Examples of Personal Information Collected|
|Social security number.|
|Contact Information||Full Name; titles, mailing address; email address; telephone, mobile and fax numbers|
|Other Unique Identifiers||Unique identification number of the Firm; advertising identifier; system identifier (e.g., user name).|
|Relationship Information||Age; date of birth; gender; marital status; demographic data; social media accounts; education information; professional information; marketing research and survey data.|
|Client account information; transaction history; records related to website usage (pages visited and documents accessed); data collected with our activities as a service provider.|
|Inferred and Derived
|Attributes and/or scores generated by internal analytics programs.|
|Online and Technical
|Internet protocol (IP) address; online user ID; passwords; browsing data; device characteristics (such as browser information); first-party cookies; third-party cookies.|
|Financial Information||Bank account numbers; credit reports and credit scores.|
|Geolocation Information||Approximate location or region you are in.|
|Children’s Information||Name; age; gender.|
Use of Personal Information
The business purposes for which we collect personal information include the provision of financial products and services (e.g., processing payments, shareholder servicing), sending marketing communications, surveys, and invitations, auditing user interactions and transactions, detecting security incidents and preventing fraud, identifying and repairing errors that impair functionality, activities to verify or enhance the quality of services, and other internal uses permitted under applicable laws.
Sharing Personal Information
We do not disclose any non-public personal information about you to anyone unless permitted by law or approved by you. We may share information with certain third parties who are not affiliated with us to process or service a transaction at your request or as permitted by law. For example, sharing information with non-affiliated third parties that maintain or service shareholder accounts for us is essential. We may also share information with companies that perform administrative or marketing services for us including research firms. For example, we may use third party applications to more effectively communicate and market our products to you. In such instances personal information may be stored on third party systems. When the entering into such a relationship, such third parties’ use of your information is restricted, and they are prohibited from sharing it or using it for any purposes other than those for which they were hired. We do not sell, and have not sold, any personal information to third parties.
We may share your personal information with the following categories of third parties:
- Our family of companies. We may share your personal information among our affiliates in order to administer your services and products, provide you with support, understand your preferences, send you information about products and services, and conduct the other activities described in this policy.
- Our service providers. We use service providers to perform services on our behalf or to assist us with the provision of products or services to you. While we may use a service provider to assist in relation to any of the purposes for which we may collect personal information, they generally fit within one or more of the following categories of service providers:
- Infrastructure and technology service providers;
- Marketing, advertising, analysis, research, event, and communications providers; or
- Providers of administrative services for the Firm’s products or services, such as transfer agencies, custodians, and securities’ pricing providers.
- External auditors, accountants, and legal and other professional advisors.
- Third parties permitted by law. In certain circumstances, we may disclose or share your personal information, such as when we need to comply with a legal or regulatory obligation (for example, we may be required to disclose personal information to the police, regulators, government agencies, or judicial or administrative authorities) or to perform transactions (for example, we may disclose personal information to a custodian or other third party in connection with the purchase or sale of securities you have requested). We may also disclose your personal information to third parties where disclosure is both legally permissible and necessary to protect or defend our rights, matters of national security, law enforcement, to enforce our agreements, or to protect your rights or those of the public.
Security and Location of Personal Information
We have implemented technical and organizational security measures in an effort to safeguard personal information in our custody and control. Such measures we have implemented include limiting access to personal information only to employees, contractors, and authorized service providers who need to know such information for the purposes described in this policy; training for our employees and contractors; and other technical, administrative, and physical safeguards. While we endeavor to always protect our systems, sites, operations, and information against unauthorized access, use, modification, and disclosure, due to the inherent nature of the internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
Depending on how you interact with us, you may have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Please note we are not obligated to respond to more than two access requests for the same individual’s personal information within a 12-month period. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The sources and categories of personal information we collected about you
- Our business or commercial purpose for collecting that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
Deletion Request Rights
You may have the right to ask us to erase personal information concerning you, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise, or defend legal claims or under other exceptions under the CCPA. Please note we will use our best efforts to erase your personal information, however we cannot guarantee that every single piece of information associated with you will be deleted from our systems.
You have a right to receive nondiscriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us Monday – Friday 8:30 a.m. to 5:30 p.m., ET at (844) 383-6477
- Emailing us at [email protected].
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Reasonable verification may include matching at least two data points provided by you with data points maintained by us.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Verification can involve matching up to three pieces of your personal data (as provided on your request) with our internal records.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
When we tell you that we need additional information to verify your identity, you must get us the information within ten (10) business days or we may deny your request. We will endeavor to respond to a verified request within 45 calendar days, unless there are grounds for extending our response timeframe by up to an additional 45 days. In the event of an extension, we will explain to you why the extension is necessary. In some cases, your ability to access or delete your personal information will be limited, as required or permitted by applicable law, even when the CCPA applies to the personal information we have for you.
We do not knowingly or intentionally collect any personal information directly from anyone under 13 years of age. And we do not target any advertising to children under 13. If you are a parent and believe we have collected personal information directly from your child who is under 13 years old, you may email or call us to report this. We will investigate your report, and if we discover that we have in fact collected such information, we will delete it.
Email: [email protected]
Phone: (844) 383-6477
Office Postal Address:
30 Maple Street
Suite 2 Summit, NJ 07901
Effective Date: January 1, 2020