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PRIVACY SHIELD POLICY

INTRODUCTION

This Privacy Shield Policy (“Privacy Shield Policy”) describes how WisdomTree Investments, Inc. and its subsidiaries and affiliates in the United States (“WisdomTree,” “we,” or “us”) collect, use, and disclose certain personally identifiable information that we receive in the United States from the European Economic Area and Switzerland (“EEA/Swiss Personal Data”). This Policy supplements our Privacy Policy located at https://www.wisdomtree.com/privacy-policy (the “Privacy Policy”), and unless specifically defined in this Privacy Shield Policy, the terms in this Privacy Shield Policy have the same meaning as the Privacy Policy.

PRIVACY SHIELD

WisdomTree recognizes that the European Economic Area (“EEA”) and Switzerland have established strict protections regarding the handling of EEA/Swiss Personal Data, including requirements to provide adequate protection for EEA/Swiss Personal Data transferred outside of the EEA or Switzerland. To provide adequate protection for certain EEA/Swiss Personal Data received in the United States, WisdomTree has certified that it adheres to the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively, “Privacy Shield”). Additionally, WisdomTree has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability and the Supplemental Principles. If there is any conflict between the terms in this Privacy Shield Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

EEA/SWISS PERSONAL DATA COLLECTION AND USE

Our Privacy Policy describes the categories of EEA/Swiss Personal Data that we may receive in the United States as well as the purposes for which we use that EEA/Swiss Personal Data. WisdomTree will only process EEA/Swiss Personal Data in ways that are compatible with the purpose that WisdomTree collected it for, or for purposes the individual later authorizes. Before we use your EEA/Swiss Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. WisdomTree maintains reasonable procedures to help ensure that EEA/Swiss Personal Data is reliable for its intended use, accurate, complete and current.

ONWARD TRANSFERS TO THIRD PARTIES

WisdomTree may disclose EEA/Swiss Personal Data to trusted third parties as indicated in the Privacy Policy. WisdomTree will seek to obtain assurances from third party service providers that process personal information on WisdomTree’s behalf that they will process such information in a manner consistent with WisdomTree policies and Privacy Shield Principles. WisdomTree remains responsible under the Privacy Shield Principles if third party service providers that WisdomTree engages to process EEA/Swiss Personal Data on its behalf do so in a manner inconsistent with the Privacy Shield Principles, except where WisdomTree is not responsible for the event giving rise to the damage. Under certain circumstances, we may be required to disclose your EEA/Swiss Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements, or when such action is necessary to comply with a judicial proceeding or court order, or when otherwise required by law.

SECURITY

WisdomTree maintains reasonable and appropriate security measures to protect EEA/Swiss Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction, taking into account the nature of the EEA/Swiss Personal Data and the risks involved in processing that information, in accordance with the Privacy Shield.

ACCESS RIGHTS

You may have the right to access the EEA/Swiss Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your EEA/Swiss Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.

DISPUTE RESOLUTION

For purposes of enforcing compliance with the Privacy Shield, WisdomTree is subject to the investigatory and enforcement authority of the United States Federal Trade Commission. Any questions or complaints regarding the use or disclosure of your EEA/Swiss Personal Data should be directed to WisdomTree at the address provided below. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your EEA/Swiss Personal Data by reference to Privacy Shield Principles. In addition, WisdomTree has agreed to participate in the following independent dispute resolution procedure in the investigation and resolution of complaints to resolve disputes pursuant to the Privacy Shield Principles:

  • JAMS
    Information about how to file a complaint with the JAMS Privacy Shield program can be found at: https://www.jamsadr.com/eu-us-privacy-shield

An individual may invoke binding arbitration, at his or her own cost, subject to procedures set forth by the Privacy Shield.

 

CONTACT INFORMATION

If you have any questions regarding this Privacy Shield Policy and our privacy practices you can contact us via email at info@wisdomtree.com, telephone 212-801-2080, or in writing to Attn: Legal Notice, WisdomTree Investments, Inc., 245 Park Avenue, 35th Floor, New York, NY 10167.

CHANGES TO THIS PRIVACY SHIELD POLICY

This Privacy Shield Policy may be changed from time to time, consistent with the requirements of the Privacy Shield. You can determine when this Privacy Shield Policy was last revised by referring to the “LAST UPDATED” date at the bottom of this page.

EFFECTIVE DATE: MAY 24, 2018

LAST UPDATED: MAY 24, 2018