PRIVACY POLICY

Last Updated January 3, 2022


Welcome to the website (the “Site”) of WisdomTree Investments, Inc. and its U.S. subsidiaries and affiliates (collectively, “WisdomTree”, “Company,” “we,” “us” or “our”). WisdomTree is a leading global sponsor of exchange-traded products, advisor tools and other resources (collectively with the Site, the “Service”).


This Privacy Policy explains what personal information we collect, how we use and share that information, and your choices concerning our information practices. European residents should review the applicable privacy policy available from:  www.wisdomtree.eu. California residents should see the California Privacy Rights section for additional information about their rights under applicable law. This Privacy Policy is incorporated into and forms part of our Terms of Use.


Personal Information We Collect


Information you provide to us includes:

  • Contact details such as your first and last name, organization name (if applicable), address, email and phone number.
  • Account data such as the username and password that you may use to establish an online account with us.
  • Communications that we exchange with you, including when you contact us with questions, feedback or otherwise.
  • Financial information such as your income, current investments, risk and loss preferences and investment goals.
  • Demographic data such as your age, gender, marital status or other information you choose to provide.
  • Marketing data such as your preferences for receiving our marketing communications and details about your engagement with them.
  • Job applicant data when you use the “Careers” section of the Site, such as your employment history, and as otherwise described in the Job Applicants section below.
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Automatic data collection. We, our service providers and our business partners may automatically log and combine information about you, your computer or mobile device, and your interaction over time with the Site, online resources and our communications, such as:

  • Device data such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings and general location information such as city, state or geographic area.

     

  • Online activity data such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Site, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access and whether you have opened or otherwise engage with our communications, such as our marketing emails or clicked links or files within them.

 

Cookies and similar technologies. The Service may use the following technologies:

 

  • Cookies, which are text files that websites store on a visitor’s (i.e., your) device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping such visitor navigate between pages efficiently, remember his or her preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.

     

  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data in connection with specific applications.

     

  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

 

Third party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

 

  • Institutional clients that provide us with data on their affiliated financial advisors.

     

  • Financial advisors who may input their client information to use certain tools and solutions available on the Site.

     

  • Market data reporting companies such as Broadridge and Discovery Data.

     

  • Marketing partners such as companies that have entered into joint marketing relationships with us.

     

  • Social media companies such as LinkedIn, Twitter and YouTube, when you interact with our profiles on those services.

     

  • Publicly available sources such as government databases.

 

How We Use Your Personal Information

 

We use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery. We use your personal information to:

 

  • provide, operate and improve the Service and promote our business;

     

  • communicate with you about the Service, including by sending announcements, updates, security alerts and support and administrative messages;

     

  • understand your needs and interests, and personalize your experience with the Service and our communications; and

     

  • provide support for the Service, and respond to your requests, questions and feedback.

 

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create or use aggregated, de-identified or other anonymized data from personal information we collect. We make personal information into anonymized data by removing information that makes the data personally identifiable to you. We may use this anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business. For example, we use anonymized traffic statistics from Google Analytics to recognize and count the number of visitors to the Site and to see how visitors move around the Site when they are using it to enable us to improve the way the Site works.

 

Marketing and advertising. We, our service providers, and our third-party advertising partners may collect and use your personal information for the following marketing and advertising purposes:

 

  • Direct marketing. We may send you WisdomTree-related direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the Opt-out of marketing communications section below.

     

  • Interest-based advertising. We may engage third-party advertising companies, such as Google, to display our ads on their online services. We may also share information about our users with these companies to facilitate advertising for the Service to them or similar users on other online platforms. This is called interest-based advertising. You can learn more about your choices for limiting interest-based advertising in the Online tracking opt-out section below.

 

Compliance and protection. We may use your personal information to:

 

  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);

     

  • audit our internal processes for compliance with legal and contractual requirements and internal policies;

     

  • enforce the terms and conditions that govern the Service;

     

  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and

     

  • comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

 

How We Share Your Personal Information

 

We may share your personal information with the following entities:

 

Affiliates. Our current and future affiliates, meaning entities that control, are controlled by, or are under common control with WisdomTree. Our affiliates may use your personal information we share with them in a manner consistent with this Privacy Policy.

 

Service providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery and website analytics services).

 

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

 

Authorities and others. Law enforcement, government authorities and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

 

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, WisdomTree (including, in connection with a bankruptcy or similar proceedings).

 

Advertising partners. Third party advertising companies, including for the interest-based advertising described above, that may collect information on the Site through cookies and other automated technologies.

 

Your Choices

 

Access, correct or delete. If you have a WisdomTree Site account, you can review and update certain account information by logging into your account. You may also contact us to request deletion of your account and certain personal information. We may request information from you to help us confirm your identity and process your request. Applicable law may require or permit us to limit or decline access and deletion requests, for example, where we need to retain your information for security, compliance, fraud prevention and safety purposes. If we delete your account, you will not be able to access it. If we delete your information, it will generally be deleted from our active databases, and the information may remain for a period of time in our backup files and in unstructured files until these records are deleted in the ordinary course of business.

 

Opt-out of marketing communications. You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us. If you have a WisdomTree Site account, you may also manage your subscriptions by logging into your account and updating your subscription preferences in your account. You may continue to receive Service-related and other non-marketing emails.

 

Online tracking opt-out. There are a number of ways to limit the tracking of your online activity and collection of device data through automated means, which are summarized below. Note, however, that certain cookies are used to collect session ID and authentication data, which are necessary for the Site to work, and enable you to move around and use the Service. Disabling these necessary cookies will encumber the Site's performance and may make the Service unavailable.

 

  • Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

 

  • Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

 

  • Using privacy plug-ins or browsers. You can block the Site from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy BadgerGhostery or uBlock Origin, and configuring them to block third-party cookies/trackers. You can also opt-out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.

 

  • Platform opt-outs. The following advertising partners offer opt-out features that let you opt-out of use of your information for interest-based advertising:

 

 

 

 

 

 

  • Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:

 

 

 

 

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt-out on every browser and device that you use.

 

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online websites that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.

 

Other Sites and Services

The Service may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.  This Privacy Policy does not apply to such third-party sites or services.

 

Security

 

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.  You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, email sent to or from the Service may not be secure, and you should therefore take special care in deciding what information you send to us via email. Moreover, where you use passwords, ID numbers, or other special access features on the Site, it is your responsibility to safeguard them.

 

California Privacy Rights

 

If you are a California resident, you have the following rights:

 

  • Access.  You can request a copy of the personal information that we maintain about you.
  • Deletion. You can ask to delete the personal information that we have collected from you.
  • Opt-out of sale of your personal data.  We do not sell personal information. We offer instructions on how to limit online tracking in the Online tracking opt-out section above.

Please note that the California Consumer Protection Act limits these rights by, for example, prohibiting businesses from providing certain sensitive information in response to an access request and limiting the circumstances in which they must comply with a deletion request.

You are entitled to exercise the rights described above free from discrimination.

Exercising your rights. To exercise these rights, you can submit requests as follows:

  • To request access to or deletion of personal data collected via your use of the Service, please email us at privacy@wisdomtree.com.
  • To learn how to opt-out of interest-based ads and other online tracking, see the Online tracking opt-out section above.
  • To verify your identity prior to responding to your requests, we may ask you to confirm information that we have on file about you or your interactions with us. Where we ask for additional personal data to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer.
  • Authorized agents: California residents can empower an “authorized agent” to submit requests on their behalf. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.

Children

 

The Service is not intended for use by children under 13 years of age. If we learn that we have collected personal information through the Service from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it.


Job Applicants

 

When you visit the “Careers” portion of the Site, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, to monitor recruitment statistics, and to respond to surveys. We may also use this information to provide improved administration of the Site, and as otherwise necessary (a) to comply with relevant laws or to respond to subpoenas or warrants served on us; (b) to protect and defend our or others’ rights or property; (c) in connection with a legal investigation; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.


Changes to This Privacy Policy

 

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Site. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Service. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.


How to Contact Us

 

You can reach us by email at privacy@wisdomtree.com.