Privacy Policy

Last updated – 12/26/2022

 

Who we are

EPFR, Inc. and its partners, affiliates, and subsidiaries respect your privacy. This Website Privacy Policy is intended to govern privacy practices with respect to visitors to our websites and our business-to-business customers.

EPFR operates in different jurisdictions, which each have varying data protection laws. This Privacy Policy applies to all EPFR businesses across the world except to the extent a country specific requirement supplements the policy.

To update your personal information or marketing preferences, contact inquiries@epfr.com. For any data privacy queries or complaints, you can address them to the Privacy team via privacy@epfr.com.

 

What we collect

This section describes what personal information we may collect from you when you use our products and services, and what other personal information we may receive from other sources.

1. Information submitted or provided by you: Through or in connection with EPFR’s corporate websites including, without limitation, EPFR.com, EPFR Global Platform, Money Fund Monitor, Money Fund Analyzer, Placement Tracker; through or in connection with business meetings with actual or potential customers or clients; through or in connection with promotions, meetings, events, and/or trade or industry shows or conferences sponsored by, hosted by, or attended by EPFR and/or EPFR’s employees, representatives, and/or agents; through telephone calls, email communications, and/or other forms of communication with you; through inquiries, from requests for bids or quotes from EPFR, and from orders for EPFR’s services.

2. Information collected from third parties: EPFR may collect information, including, business contact information, from third parties, including, information service bureaus, data brokers, social media platforms, and/or industry conference or event organizers or sponsors. We may use the information collected from these third parties for various purposes, including, sending you emails or other communications. In the event you receive such communications you will have the opportunity to optout of receiving communications from us. The information we collect automatically is statistical data and may also include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our services and our Website and to deliver a better and more personalized service, including by enabling us to estimate our audience size and usage patterns.

3. Information collected through automated means: EPFR Cookies. Cookies are small files that store certain data on a device or computer. EPFR may use session and persistent cookies for several purposes including, to enable you to use and transverse a website and quality control. Session cookies expire when you close your browser. Persistent cookies remain on your device or computer indefinitely until deleted. A user may disable and/or delete cookies via the user’s browser or otherwise, however; this may limit your use of a website or decrease available website functionality.

1. Third Party Cookies. EPFR uses third parties to provide certain services and functionality. Subject to contractual restrictions to limit their use of cookies to specified purposes consistent with these terms.
2. Log Files. EPFR’ websites may automatically gather and store certain information in log files, including, data available from your web browser, such as IP Address, browser type, internet service provider, referring/exiting pages, operating system, date/time stamp and click stream data.
3. Web Beacons. Pages of our website, third party partners and our e-mails may contain small electronic files known as web beacons that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics.
4. Opt-out of Cookies: We use Google Analytics cookies and EPFR cookies for internal marketing analytics. Google Analytics cookies will be transmitted to and stored by Google on servers in the United States of America in accordance with its privacy practices. To see an overview of privacy at Google and how this applies to Google Analytics, visit Google’s Privacy Policy. You may opt out of tracking by Google Analytics by visiting GA Optout. To opt-out of cookies set by EPFR, make your opt-out request by sending an email to: inquiries@epfr.com.

 

Do Not Track

EPFR does not currently take steps to respond to browsers’ “Do Not Track” signals as no uniform standard to respond to such signals has been developed at this time. Please go to All About Do Not Track for more information.

 

Children’s personal information

Our services and products are directed at business professionals. They are not intended for children under the age of eighteen. We do not knowingly collect personal information from users in this age group and reserve the right to delete such information if we become aware of having collected it.

 

How and why personal information is used

This section explains how and why we use personal information.

We may use information to:

• Provide, administer, and communicate with you about EPFR products, promotions,
  services, events (e.g., webinars), newsletters, and industry knowledge or expertise
  (e.g., whitepapers, articles)
• Execute advertising campaigns on email and social media platforms with you
• Operate, evaluate, conduct, and improve EPFR services
• Call recording and monitoring for coaching, training and quality monitoring purposes
• Protect against and prevent fraud and manage risk exposure
• Respond to inquiries and requests
• Process and manage opt-out and unsubscribe requests
• Comply with applicable laws, regulations, codes, and industry standards and
  practices
• Conduct marketing and market research activities
• Create and send targeted communications to you regarding your transactions with
  EPFR
• Respond to a subpoena or an order of a court or government agency
• Establish, exercise, or defend legal claims, to protect the safety of an individual or to
  protect EPFR rights or property
• Evaluate your interest in employment and contact you regarding possible
  employment opportunities

In the event that you provide EPFR with any feedback, suggestions, or comments regarding EPFR business activities, whether regarding current or future products or services, we may use, apply, and implement such feedback, suggestions, or comments, at our discretion and without any notice, consent, approval, compensation, attribution or credit, and you hereby irrevocably assign and transfer to EPFR all right, title, and interest in and to any such feedback, suggestions, or comments.

 

How do we share your personal information

This section describes how we share your personal information

We may share information, as follows:

• Within the EPFR group of entities and directly related products
• To service providers performing services on our behalf (e.g. email delivery, fraud detection and prevention services). Service providers are authorized to use and disclose the information only as necessary to perform and provide the services for which they are engaged.
• We may disclose information about you: (a) if we are required to do so pursuant to applicable laws or legal or court process or (b) when we believe disclosure is necessary to prevent harm or financial loss, or (c) in connection with an investigation of actual or suspected fraud or illegal activity. We reserve the right to transfer information about you in the event of a merger, acquisition, sale, or other transaction involving EPFR, including a change of control event.

 

How we protect personal information

We recognize the importance of protecting and managing personal information. Your personal information will be treated with the utmost care and security. This section sets out some of the security measures in place.

EPFR maintains appropriate technical, administrative and physical safeguards to protect information, including, without limitation, personal information, received or collected by EPFR. EPFR reviews, monitors, and evaluates its privacy practices and protection systems on a regular basis with safeguards designed to make the information we collect from these websites secure. However, no transmission or electronic storage of information is guaranteed to be secure. We therefore urge you to always use caution when transmitting information over the Internet.

 

Cookies

More information on our use of cookies can be found in our Cookie Policy.

A cookie is a small text file containing a unique identifier that is automatically placed on a user’s computer or other device when the user visits a website. For more information, please visit our Cookie Policy link on the bottom of the website.

 

Third-party links

This section explains that third party links on our websites are subject to separate privacy practices.

This website contains links to other websites. We are not responsible for the privacy practices of these websites and do not accept any liability in connection with their content. We recommend reviewing the privacy policy of each third-party site linked from this website to determine its use of your personal information.

 

How long your information is kept

We will only retain personal information for as long as is necessary and as permitted by applicable laws.

We will retain personal information while we are using it for the purposes described in this Privacy Policy. We may continue to retain it after we have ceased such uses for certain legitimate business purposes. For example, if you have opted out of marketing communications from us, we will retain limited details about you to ensure we can honor your opt-out request. We may also continue to retain your personal information to meet our legal requirements or to defend or exercise our legal rights.

The length of time for which we will retain your personal information will depend on the purposes for which we need to retain it. After we no longer need to retain your personal information, it will be deleted or securely destroyed.

 

International transfer of personal information

This section explains your legal rights in relation to how we process your personal information depending on jurisdiction.

EPFR is a global company headquartered in the United States with operations in the United States, Europe and Asia. When you use our websites and data, please be aware that your personal data may be transferred to, stored and processed by us and our affiliates in our hosting facilities in the United States, Europe and Asia. When and if EPFR transfers your personal data to hosting facilities outside of the United States or European Countries, we use appropriate legal mechanisms to help ensure all applicable laws, rights and regulations continue to protect your personal data. This may include the use of EU Commission approved standard contractual clauses. Where such standard contractual clauses are used, a copy is available on request.

 

California Consumer Rights and Choices

This section shares your rights as a resident of the State of California.

Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the Last Reviewed Date of this Notice), the following types of personal Information:

Identifiers 

First and last name, postal address, email address, username, IP address, online identifier, and similar identifiers.

Additional data subject to Cal. Civ. Code § 1798.80
First and last name, signature, address, telephone number, employment.
Commercial Information
Records of EPFR products licensed or used.

Online activity
Browsing history, search history, Information on a consumer’s interaction with a website, application, or advertisement. We may use your personal Information for the purposes described above in the EPFR
Privacy Policy. We do not sell Personal Information to third parties (pursuant to California Civil Code Sections 1798.100-1798.99, also known as the California Consumer Privacy Act of 2018 and The California Privacy Rights Act of 2020).

You have the right to opt-out of this disclosure of your Information, as detailed below.

California Consumer Rights
You have certain choices regarding our use and disclosure of your personal Information, subject to relevant exceptions under applicable law, as described below.

Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal Information we have collected, used, disclosed and sold or shared about you.

Correction: You have the right to request that we correct the personal Information we maintain about you, if that Information is inaccurate.

Deletion: You have the right to request that we delete certain personal Information we have collected from you.

Opt-Out of Sale or Sharing: You have the right to opt-out of the sale of your personal Information or the sharing of your personal Information for cross-context behavioral advertising purposes.

Shine the Light Request: If you are a California resident and have provided us with your personal Information, you may ask us to refrain from sharing your personal Information with third parties, including our affiliates if they are separate legal entities, for direct marketing purposes.

How to Make a Request

You may make a request to exercise your rights under CCPA by submitting your request here. To help protect your privacy and maintain security, we will take steps to verify your identity before actioning your request. To submit a request as an authorized agent on behalf of a consumer, please send the full information of the agent and the requested consumer to privacy@epfr.com. If you designate an authorized agent, we may require proof of identity and authority before actioning your request.

Additional Information

If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.

Updates to this Notice
From time to time, EPFR may update this notice. When the notice is updated, we will provide Information about the changes we have made, as well as the date of the update.

 

EU Residents

This section applies where the EPFR Controller you are dealing with is in the EU or UK or where an EPFR Controller outside the EU or UK provides services to you if you live in the EU or UK.

How and why we use personal information

EPFR maintains a number of legal uses of personal information under UK and EU data protection laws and we are required to define the use in our Privacy Policy. An explanation of the scope of the principal grounds that justify our use is set out below:

• Consent: where you have consented to our use of your information (you will have been presented with a consent form in relation to any such use and may withdraw your consent here
• Contract performance: where your information is necessary to enter into or perform our contract with you.
• Legal obligation: where we need to use your information to comply with our legal obligations.
• Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
• Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.

International transfer of personal information

Certain countries outside the European Economic Area (EEA) and UK have been approved by the European Commission as providing essentially equivalent protections to EEA and UK data protection laws and therefore no additional safeguards are required to export personal information to these jurisdictions. In countries which have not had these approvals, we will either ask for your consent to the transfer or transfer it subject to European Commission approved contractual terms that impose equivalent data protection obligations directly on the recipient, unless we are permitted under applicable data protection law to make such transfers without such formalities.

Your Rights

If you have any questions in relation to our use of your personal information, contact us. Under certain conditions, you may have the right to require us to:

• Provide you with further details on the use we make of your information
• Provide you with a copy of information that you have provided to us
• Update any inaccuracies in the personal information we hold
• Delete any personal information that we no longer have a lawful ground to use
• Where processing is based on consent, to withdraw your consent so that we stop the
  specified processing
• Cease direct marketing to you
• Where we undertake wholly automated decision making which results in the creation of a legal obligation or a similar significant impact, you may request that we provide information about the decision-making methodology and ask us to verify that the automated decision has been made correctly. We may reject the request, as permitted by applicable law, including when providing the information would result in a disclosure of a trade secret or would interfere with the prevention or detection of fraud or other crime. However, generally in these circumstances we will verify that the algorithm and source data are functioning as anticipated without error or bias or if required by law adjust the processing
• Object to any processing based on the legitimate interests ground unless our reasons for
  undertaking that processing outweigh any prejudice to your data protection rights
• Restrict how we use your information whilst a complaint is being investigated

Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.

We hope to resolve any privacy concerns you may have. If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you can complain to any supervisory authority or other public body with responsibility for enforcing privacy laws.

In the UK, the UK Information Commissioner’s Office regulates and enforces data protection law. Their procedures can be found at www.ico.org.uk.
In the Netherlands, the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) regulates and enforces data protection law. Their procedures can be found at www.autoriteitpersoonsgegevens.nl.

 

Updating your information and marketing preferences

This section explains who you can contact to update your personal information that we hold and how you can update how we can send you updates on our products, services and events.

We want you to remain in control of your personal information. We try to ensure the personal information held about you is accurate and up to date.

We will always provide the opportunity to unsubscribe or opt out of future marketing communications.

Information on how to unsubscribe or opt out will be provided on every marketing email we send you. However, if at any stage you would like to update and/or correct such personal information, or opt-out of future marketing communications, request this by sending an email to: inquiries@epfr.com.

 

Contacting us

For any questions about this Privacy Policy or our use of your information, you can contact our Privacy team at privacy@epfr.com.

We hope we will be able to resolve any privacy concerns you may have. However, you always have the right to complain to any supervisory authority or other public body with responsibility for enforcing privacy laws in your country. You can also contact us by mail using the details provided below:

EPFR Inc.
Attn: Privacy Office
200 Portland St. #5
Boston, MA 02114
USA

 

Changes to this Privacy Policy

Please note that we update our Privacy Policy from time-to-time.

To keep up with changing legislation, best practice, and changes in how we process personal information, we may revise this Privacy Policy at any time. Depending on the nature of the changes, we may update you via email if we have your personal information; or we may update the Policy without notice by posting a revised version on this website. To stay up to date on any changes, check back periodically.

This Privacy Policy was last updated on 12/23/2022