This is the Privacy Policy of Intech Investment Management LLC (also referred to throughout this policy as ‘Intech’, ‘we’, ‘us’, or ‘our’ and ‘you’ or ‘yourself’ may refer to an individual, Independent Financial Advisor, consultant, company, or other entity visiting this website.
Your privacy is important to Intech. This Privacy Policy applies to our website www.intechinvestments.com (“Website”) as well as to certain direct marketing communications you may receive from us. Intech strives to protect your online privacy, while providing an enjoyable website experience that among other functions, provides information about our firm, and products and services that are relevant and useful to you.
The purpose of this Privacy Policy is to notify and inform you of how and the purposes for which we collect, use, and disclose Personal Information (as defined below). It also describes your choices regarding our use of your Personal Information.
Please review this Privacy Policy carefully. By using the Website, you are accepting the terms of this Privacy Policy as well as our Terms of Use, which means that you will be consenting to our collection, use, disclosure, and retention of your Personal Information as described in this Privacy Policy. If you do not agree with any part of this Privacy Policy or our Terms of Use, you are not permitted to use this Website.
This Privacy Policy is currently only provided in English. For investors located in Quebec, please contact privacy@intechinvestments.com for a French version of this document.
1. Important Information
1.1. Changes to this Privacy Policy
We may update this Privacy Policy from time to time by posting a new version online. You should check this page occasionally to review any changes. The date on which the Policy was last revised appears at the bottom of the page so that you can easily determine if we have made changes since you last time you reviewed this Policy. If we make any changes, we will post the revised Privacy Policy on our Website. By using the Website, including providing us with your Personal Information, after changes are made to this Policy, you will be agreeing to the terms of the updated Privacy Policy. If you do not accept any changes to this Privacy Policy, you must stop using the Website.
1.2. Contact Us
If you have any questions about this Privacy Policy or our treatment of your Personal Information, please contact us by email at privacy@intechinvestments.com or by mail to:
Intech
Attn: Chief Compliance Officer
250 S. Australian Avenue
Suite 1700
West Palm Beach, FL 33401
United States of America
2. Personal Information We Collect
2.1. When You Visit our Website
You are free to explore the Website without providing any information about yourself except Navigational Information (see below). You may choose to share your Personal Information with us but doing so is voluntary, except as otherwise set out in this Policy. As a financial services provider subject to certain regulatory requirements, we do not provide our products and/or services to investors on an anonymous basis. General inquiries, however, can be made on an anonymous basis.
2.2. “Personal Information”
This refers to any information that identifies you personally, including contact information, such as your name, e-mail address, home address, contact number, and other information about yourself that is collected by us through the Website.
2.3. “Navigational Information”
This refers to information about your computer and your visits to this Website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please also see the “Navigation Information” section below.
2.4. Information About Children
The Website is not intended for or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13. If you believe that we have collected information about a child under 13, please contact us at privacy@intechinvestments.com, so that we may delete the information.
3. How We Use Personal Information We Collect
3.1. Compliance with Our Privacy Policy
We use the information we collect in compliance with this Privacy Policy, unless otherwise permitted or required by law.
3.2. We Never Sell Personal Information
We will never sell your Personal Information to any third party.
3.3. Use of Personal Information
In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to: (a) improve your browsing experience by personalizing the Website; (b) send information to you that we think may be of interest to you by post, email, or other means; and (c) send you marketing communications or other information relating to our business. We may share personal information with service providers to help us perform statistical analysis or provide client support. In our contracts with them, we prohibit such service providers from using your Personal Information except as required to provide their services, and they are required to maintain the confidentiality of your information.
3.4. Use of Navigational Information
We use Navigational Information to operate and improve the Website. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about Intech.
3.5. Service Providers
We employ other companies and people to provide services to users of our Website and may need to share your Personal Information with them to provide information, products, or services to you. Examples may include removing repetitive information from prospect lists, analyzing data, providing marketing assistance, and supplementing the information you provide us with in order to provide you with better service.
In all cases where we share your Personal Information with such persons, we explicitly require them to acknowledge and adhere to our privacy and other client data handling policies to ensure that the information in its care is properly safeguarded at all times.
3.6. Security of your Personal Information
We have physical, administrative, procedural, and technical safeguards in place to protect your information from unauthorized access, use, or disclosure. We regularly adapt these controls to respond to changing requirements and advances in technology. We also contractually require that our third-party service providers protect such information. When sensitive Personal Information (such as geo-location data) is collected on our Website and/or transmitted to other websites, it is protected using encryption, such as the Secure Socket Layer (SSL) protocol.
As a condition of employment, Intech employees are required to follow all applicable laws and regulations, including data protection laws and receive periodic training on data protection. Access to sensitive information is limited to those employees who need it to perform their roles. Unauthorized use or disclosure of confidential client information by an employee is prohibited and may result in disciplinary measures.
If you have any questions about the security of your Personal Information, you can contact us at privacy@intechinvestments.com.
3.7. Social Media Features
Our Website and third-party social media venues may include social media features, such as a “Like” button and Widgets, such as “Share.” These features may collect your IP address, which page you are visiting on our Website, and may set a cookie on our Website to enable the feature to function properly. Social media features and Widgets are either hosted by a third party or hosted directly on our Website. This Privacy Policy does not apply to features hosted on third party websites. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them, which can be found on their respective websites.
3.8. External Websites
Our Website may sometimes provide links to other websites. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to their own privacy and other policies.
3.9 Public Forums
We may offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you choose to post any information on our public message boards, blogs, or forums, this information will be publicly available and may be collected and used by other users. We will correct or delete any information you have posted if you request, as described in “Opting Out and Unsubscribing” below, however we are not able to require the deletion of information collected by other users. We suggest you give careful consideration before posting information on our publicly accessible message boards, blogs, and community forums.
3.10 Retention of Personal Information
We retain Personal Information that you provide us as long as we consider it potentially useful in contacting you about our services, unless you withdraw your consent for us to contact you, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements, and then we securely delete the information. We will delete your Personal Information from our servers at an earlier date if you so request, as described in “Opting Out and Unsubscribing” below unless such information is required to be maintained pursuant to regulatory or legal requirements.
3.11. Corporate Events
Upon the sale or transfer of Intech and/or all or part of its assets, your personal information will be among the items sold or transferred. We will request a purchaser to treat our data under the privacy policy in place at the time of its collection. In this event, you will be notified via email and/or a prominent notice on our Website, of any change in ownership.
3.12. Information Collected from Marketing Emails
If you consent to receiving direct marketing from us in order for us to tell you about our products, services, offers, investment or events that we think may be of interest to you, we will use your Personal Information to contact you email for direct marketing. You can contact us at any time to opt out of receiving direct marketing, or using the unsubscribe function in the email, if you do not wish to receive such materials or information.
When you receive content from us through marketing emails, you have to select one of two options before being able to view the content as follows: (1) accept and be tracked or (2) continue without tracking. If you agree to be tracked, we will know if you opened the content, and how long you viewed each page of content. We collect this information for marketing and statistical purposes as well as for internal analytics.
When you interact with our targeted emails, we automatically receive and record information on our server logs from your browser including your IP address via a cookie that is placed on your computer. This particular cookie saves your preference so that when returning you will not have to make the selection again. Refer to our Cookie Policy for additional information.
3.13. Additional Uses and Disclosures
In addition to the use of your Personal Information set out above and the disclosure of your Personal Information that is required to provide you with our products, services, and other information that you have requested, we reserve the right to use or disclose your Personal Information if required by law, a court order or legal process, or if we reasonably believe that the use or disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud or other violations or suspected violations of the law. Your Personal Information will be processed in the United States and subject to applicable privacy laws. Your Personal Information may be accessible to law enforcement as well as federal and state authorities.
4. How we use cookies
4.1. Cookies
Intech uses cookies and similar technologies to track users’ movements around the Website and gather demographic information about our user base as a whole to analyze trends and evaluate the Website. We also use cookies to administer the Website and to help you personalize your online experience.
A cookie is a text file that is placed on your hard disk by a Web server. Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to your computer and can only be read by a Web server in the Internet domain that issued the cookie. One of the primary purposes of cookies is to provide a convenience feature to save you time by telling the Web server that you have returned to a specific page. For example, if you register for downloadable content on our Website, a cookie helps us to recall your specific information on subsequent visits so that when you return to the Website, the information you previously provided can be retrieved, bypassing the need to register again.
You should be aware that cookies and other similar identification methods may be used to associate you (as a user) with the computer or device that you are using. These cookies do not reveal your identity to us or provide us with personally identifiable information about your use of the Website.
Some cookies may be stored on your computer and are not deleted when you close your browser. These permanent cookies retain your preferences for a particular website, allowing those preferences to remain for future browsing sessions, but do not collect information from you.
Intech also uses cookies to keep track of the pages you (as a user along with other users) visit in order to determine what portion of the Website is the most popular or most used. This data is used to deliver customized content within the Website to users whose behavior indicates that they are interested in a particular subject area. You may opt-out of communications from us at any time or manage your email preferences to select the types of communications you would like to receive in the future.
You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Website.
Refer to our Cookie Policy for additional information.
For more information about deleting or blocking cookies, please visit www.allaboutcookies.org.
4.2. Log Files
We may collect demographic information through log files. This information can include your IP address, geographic location, pages visited, browser type, domain names, internet service provider (ISP), the files viewed on our Website (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. We use this information to obtain general statistics regarding Website use. For these purposes, it is possible for us to link this automatically collected data to your Personal Information such as your name, business email address, business address, and contact number.
4.3. Clear Gifs (Web Beacons/Web Bugs/Tracking Pixels)
We employ software technology called clear gifs (a.k.a. Web Beacons/Web Bugs/Tracking Pixels), that help us better manage the Website by informing us what content is effective. These are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, they are embedded invisibly on Web pages or in emails and are about the size of the period at the end of this sentence. These features let us know which emails have been opened by recipients allowing us to gauge the effectiveness of certain communications and the effectiveness of our marketing efforts. We tie the information gathered in emails to our clients’ Personal Information. If you would like to opt-out of these emails, please see “Opting Out and Unsubscribing.”
4.4. Flash Cookies
The Adobe Flash Player (and similar applications) used on our Website, employs technology to remember settings, preferences and usage similar to browser cookies, but these are managed through a different interface than the one provided by your Web browser. This technology creates locally stored objects that are often referred to as “Flash Cookies.” Our Website does not use Flash Cookies. We do not have access or control over these Flash Cookies, however, but you may access your Flash management tools from Adobe’s web site directly here.
4.5 Wistia
Our website uses Wistia to power its videos. Wistia tracks how you interact with the videos on this site: how much of a video you watch at what points in a video you pause or rewind, etc. In some videos, we may pause the video and request that you provide your email address or name. You are under no obligation to provide this information, but we reserve the right to limit certain videos to identified users. Wistia aggregates the data collected through the videos here, including names and email addresses, and provides it to us. Wistia does not sell or provide the data it collects to third parties.
4.6. Advertising
We collaborate with a third-party ad network to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personal information about your activities on other Web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here: http://preferences.truste.com/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/).
Please note this does not opt you out of being served advertising. You will continue to receive generic ads.
4.7. Third Party Tracking Technologies
Our Privacy Policy does not cover the use of cookies and web beacons by any tracking utility company.
5. Opting Out and Unsubscribing
5.1. Reviewing, Correcting and Removing Your Personal Information
Upon request, Intech will provide you with information about whether we hold any of your Personal Information. It is important to provide us with sufficient detail to make the information reasonably retrievable.
If we are holding your Personal Information, you have the following options with respect to that information, unless otherwise set out in the law:
- To review your Personal Information without charge. However, there are certain exemptions that allow us to deny access to your Personal Information. If we deny you access to review your Personal Information, we will inform you of the reason in writing within 30 calendar days.
- To request that we correct any errors, outdated information, or omissions in the Personal Information.
- To request that your Personal Information not be used unless we are required to use it for a legitimate reason (e.g., we may need to use your Personal Information to comply with a legal or regulatory obligation).
- To request that your Personal Information be removed from any solicitation list that we use.
- To request that your Personal Information be erased from our records unless we are required to maintain such information pursuant to regulatory or legal requirements.
- To request access to your Personal Information and to obtain information about how we process it.
- To move, copy or transfer your Personal Information.
- To receive some Personal Information in a structured commonly used and machine-readable format and/or request that we transmit that data to a third party where technically feasible. Please note that this right only applies to information which you have provided directly to Intech and may not always apply.
- To lodge a complaint with the Intech or a relevant data protection regulator.
To exercise any of these options, please contact us at privacy@intechinvestments.com or by mail to:
Intech
Attn: Chief Compliance Officer
250 S. Australian Avenue
Suite 1700
West Palm Beach, FL 33401
United States of America
If you make a complaint, we will need to verify your identity and request further information in order to respond. If we are holding your Personal Information, we will endeavour to answer any questions, correct any error on our part or resolve any complaint you may have about our information handling practices. We will respond to your request to any of the foregoing within 30 calendar days and notify you of the action we have taken.
Note for EU Investors: If you are located in the EU, you have the right to complain to the data protection regulator in your jurisdiction.
Note for UK Investors: If you are located in the UK, you have the right to complain to the Information Commissioner’s Office, which enforces data protection laws: https://ico.org.uk/.
Note for Australian Investors: If you are located in Australia and believe we did not resolve a complaint to your satisfaction, you may refer the matter to the Office of the Australian Information Commissioner (“OAIC”). The OAIC has the power to investigate the matter and make a determination. Please note the OAIC generally requires that any complaint must first be made to the respondent organization. The law also allows 30 days for the respondent organization to deal with the complaint before a person may make a complaint to the OAIC.
The Commissioner can be contacted at:
Office of Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Fax: +61 2 9284 9666
Email: enquiries@oaic.gov.au www.oaic.gov.au
Intech is permitted to conduct financial services in Australia pursuant to an exemption from the need to hold an Australian financial services license under the Australian Corporations Act 2001. Intech is registered and regulated by the United States Securities & Exchange Commission (SEC) under U.S. laws, which differ from Australian laws (SEC File No.: 801-60987). At Intech, maintaining your privacy is important to us and we take precautions to safeguard your information as discussed herein. We comply with the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (“APPs”) in the Act and any other applicable privacy laws when handling Personal Information.
5.2. To Unsubscribe From Our Communications
You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, or by email to privacy@intechinvestments.com or by mail to:
Intech
Attn: Chief Compliance Officer
250 S. Australian Avenue
Suite 1700
West Palm Beach, FL 33401
United States of America
Please note that if you “unsubscribe” we will not send you marketing communications or information regarding events sponsored by Intech.
Note: Existing Intech clients cannot opt out of receiving transactional emails related to their advisory account with us through this means.
6. Disputes
6.1. Resolving Disputes
If you have a dispute with us relating to our privacy practices, please contact privacy@intechinvestments.com. Most disputes can be resolved that way.
7. Contact Information
If you have questions or comments about our Privacy Policy, the ways in which we collect and use your information, your choices and rights regarding such use, please contact us at:
Phone: 1-561-775-1100
Email: privacy@intechinvestments.com
Mail:
Intech
Attn: Chief Compliance Officer
250 S. Australian Avenue
Suite 1700
West Palm Beach, FL 33401
United States of America
We thank you for taking the time to read this Privacy Policy and exploring our Website.
Effective 2024/03/01
