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Last Revised January 2020

Introduction

Thank you for visiting www.agilefinancial.io, the Website of Agile Financial Insights LLC.  Agile Financial Insights LLC is a provider of integrated financial information and analytical applications to the global investment community. To protect your privacy better, Agile Financial Insights LLC wants you to know how we collect your information, the types of information we collect, how we use and share your information and what choices you can make about the way your information is collected and used.

This policy applies to information we collect:

  • on this Website.
  • in email, text, and other electronic messages between you and this Website.
  • when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

  • us offline or through any other means, including on any website operated by any third party; or
  • any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Additional information for California Residents under the California Consumer Privacy Act is available here.

Collection and Use of Personal Information

We collect several types of information from and about users of our Website, including information:

  • by which you may be personally identified, such as name, postal address, email address, telephone number, etc. (“personal information”);
  • about your internet connection, the equipment you use to access our Website and usage details (“usage information”).

We collect this information:

  • directly from you when you provide it to us.
  • automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

If you provide your personal information to us, we may use that information to service your account, send you news, information or promotions related to our products and services.  In some instances, you may receive information or promotions about products or services offered by another company.

When you have provided personal information to us, we may disclose such information to other companies that we have engaged to assist it in providing you goods or services.  This may include, but is not limited to, fulfilment houses, billing services, transaction managers, credit verification services, and other third party service providers.  We also may disclose your personal information to third party service providers that assist us in conducting market research for our own purposes.  We do not sell personal information to third parties for their own use, but may provide certain usage information to advertisers to help provide you with relevant advertising. 

We may also disclose any of your personal information or usage information to law enforcement or other appropriate third parties in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, or other suspected illegal activities, as may be required by applicable law, or, as we may deem necessary in our sole discretion, in order to protect our legitimate legal and business interests.

We reserve the right to disclose, share and/or otherwise transfer personal information and usage information, in connection with a corporate merger, acquisition, consolidation, the sale of a portion of our business or the sale of substantially all of our assets, or other fundamental corporate change, whatever form it may take. You will be notified via e-mail or prominent notice on our website prior to a change of ownership or control of your personal information or usage information, if your personal information or usage information will be used contrary to this policy.

Information You Provide to Us

The information we collect on or through our Website may include:

  • information that you provide by filling in forms on our Website. This includes information provided at the time of requesting information or further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
  • records and copies of your correspondence (including email addresses), if you contact us.
  • your responses to surveys that we might ask you to complete for research purposes.
  • your search queries on the Website. 
Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain usage information about your equipment, browsing actions, and patterns, including:

  • details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • information about your computer and internet connection, including your IP address, operating system, browser type, and internet service provider.
Use of Cookies and Other Electronic Tools

Agile Financial Insights LLC and the parties with whom we work (e.g., service providers, business partners, advertisers and advertising servers) may place, view, and/or use cookies, Web server logs, Web beacons, or other electronic tools to collect statistical and other usage information about your use of this Website and all other websites which relate to, provide, or market Agile Financial Insights LLC products and services. Your consent and acceptance of cookies shall suffice as notice and consent to collection and such usage. This usage information may include information about the IP address of your computer, browser type, language, operating system, your mobile device, geo-location data, internet service provider, the state or country from which you accessed this Web site, the Web pages visited, the date and the time of a visit, the websites you visited immediately before and after visiting this Web site, the number of links you click within this Web site, the functions you use on this Web site, the databases you view and the searches you request on this Web site, the data you save on or download from this Website and the number of times you view an advertisement.

The technologies we use for this automatic data collection may include:

  1. Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  2. Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
  3. Web Beacons. Pages of our Website and our emails may contain small electronic files known as Web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We may collect personal information automatically, and we may tie this information to personal information about you that we collect from other sources or you provide to us.

Collection of Information from Children

We do not seek information directly from children. If you are under 13, you should not provide us with any information without the involvement of a parent or guardian.

We comply with the Children’s Online Privacy Protection Act and all other applicable laws and regulations concerning children and the Internet.  If the parent or guardian, of a user who is a minor, discovers that the user has submitted his or her personal information without the parent or guardian’s permission or consent, we will take reasonable steps to remove that information from the Website and our servers at the parent or guardian’s request.  To request removal of personal information of a minor, please contact us as set forth below and be sure to include in the message the user name and legal name of the minor.

Advertisements

Agile Financial Insights LLC, its designated service providers, or third-party advertisers or their advertising servers may also place or recognize unique cookies on your computer or use other electronic tools in order to help display advertisements that you see on this Website or on other websites. Information about your visits to, and activity on, this Website and other websites, an IP address, the number of times you have viewed an advertisement, and other such usage information is used, alone or in combination with other information, to display on your device screen advertisements that may be of particular interest to you. We may use Web beacons, provided by third party advertising companies, to help manage and optimize our online advertising and product performance. Web beacons enable us to recognize a browser’s cookie when a browser visits this Website, and to learn which banner ads bring users to this Website. This Privacy Policy does not cover the use and collection of your information by these third party service providers, and third party advertisers and their advertising servers. To “opt out” of advertising cookies placed by the Network Advertising Initiative’s (“NAI”) online behavioural advertising member networks, and thereby limit the tracking of your online activity and the targeted advertising you receive, please click here. To opt out of advertising cookies for Your Online Choices if you are based in the EU, please click here. To opt out of Google Analytics for Display Advertising, please click here. You may also enable the “Do Not Track” setting in your web browser(s) or clear cookies from your browser after each browsing session. Please note that even if you exercise choice for targeted advertising, you will still receive online advertising.

Access

Agile Financial Insights LLC will enable you to access your personal information held by Agile Financial Insights LLC and you will be able to correct, amend, or delete that information where it is inaccurate, except (1) where the burden or expenses of providing access would be disproportionate to the risks to your privacy in the case in question, or (2) where the rights of persons other than you would be violated. If you wish to access your personal information held by Agile Financial Insights LLC, you may do so by contacting Agile Financial Insights LLC Compliance Officer using the contact information provided below.

Notice to California Residents/Your California Privacy Rights and Canadian Residents: California and Canadian residents are entitled to request and obtain certain information regarding our disclosure, if any, of your personal information and to request updates to such information or revocation of consent of use of such information.  To make such a request, please contact Agile Financial Insights LLC Compliance Officer using the contact information provided below.         

Data Security

Agile Financial Insights LLC takes reasonable precautions to protect personal information from loss, misuse, unauthorized access, disclosure, altercation, and destruction.  Unfortunately, while we work hard to ensure the security of your personal information while it is on our systems, no security measures are perfect and data transmitted over the Internet cannot be guaranteed to be 100% secure. We cannot and do not ensure or warrant the security of any information you transmit and you do so at your own risk.

Agile Financial Insights LLC is a global company. To offer our services, we may need to transfer your information among several countries, including the United States, where we are headquartered. For information collected from residents of EU member states, Agile Financial Insights LLC complies with the Standard Contractual Clauses as set forth by the EU regarding the collection, use, and retention of data from the EU. Agile Financial Insights LLC intends to comply with future EU laws related to the transfer of data outside of the EU.

For information collected regarding residents of EU member states, Agile Financial Insights LLC agrees to cooperate with the Data Protection Authorities located in the EU member states in resolving any individual complaints or disputes with regard to this Privacy Policy and the European Commission’s Directive on Data Protection.

Links to Other Websites

Our Websites may provide links to other websites for your convenience and information. These websites may operate independently from Agile Financial Insights LLC. Linked websites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not owned or controlled by Agile Financial Insights LLC, we are not responsible for the websites’ content, any use of the websites, or the privacy practices of the websites.

Changes to Our Privacy Policy

This Privacy Policy may be amended from time to time. Please review it periodically. Changes to this Policy will be effective upon posting to this Website. Your use of the Website following these changes means that you accept the revised policy.

How to Contact Us

If you have any questions or comments about this Privacy Notice, Agile Financial Insights LLC’s privacy practices or if you would like us to update information or preferences you provided to us, please write to us at:

Chief Operating Officer
Agile Financial Insights LLC.
6 Oregon Hollow Road, Armonk, NY 10504

AGILE FINANCIAL INSIGHTS LLC’S CALIFORNIA CONSUMER PRIVACY ACT STATEMENT

January 1, 2020

This Privacy Notice for California residents and addresses the requirements of the California Consumer Privacy Act of 2018 (“CCPA”).  Defined terms in the CCPA have the same meaning in this statement.

Information Collected

Agile Financial Insights LLC collects information that may be used to identify, describe or link to people who visit our website and/or request information about our product or the products of third parties.  The CCPA identifies categories of personal information that may be collected. The table below indicates whether Agile Financial Insights LLC has collected such personal information in the last 12 months, the source of that information, and whether it has been shared with a third party for a business purpose in the last 12 months:

Information CategoryExamplesCollected in last 12 months?Source of InformationInformation Shared in the last 12 months?
IdentifiersName, address, unique personal identifier, internet protocol (IP) address, email address, phone number, account name, job title, industry, employer [social security number, driver’s license]YES, excluding bracketed informationYou provide this information to us via forms you fill out and submit online; contact information you provide to sales representatives when making inquiries about our products and services via phone, email or other forms of correspondence; tracking technologies such as cookies collect IP addresses.Yes, to the extent you have consented to our sharing this information with third party providers on our OpenFactSet.com website.
Categories of personal information listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))Name, address, telephone, education, employment, employment history [signature, social security number, physical characteristics or description, number, passport number, driver’s license, or state identification number, insurance policy number, bank account number, financial information, medical information, health insurance information]YES, excluding bracketed informationYou provide this information to us via forms you fill out and submit to us online or through other contacts in conjunction with asking for information about our products and services or when you apply for a job on our website.Yes, to the extent you have consented to our sharing this information with third party providers on our OpenFactSet.com website.
Protected class characteristics under California or federal lawAge, race, color, ethnicity, ancestry, national origin, citizenship, religion, marital status, medical condition, physical or mental disability, sex (including gender, gender identify, gender expression), sexual orientation, veteran or military status, genetic information (including familial information)NON/AN/A
Commercial InformationPersonal property records, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendenciesNON/AN/A
Biometric InformationGenetic, physiological, behavioural, or biological characteristics, eye scans, face prints, finger prints, sleep, health or exercise dataNON/AN/A
Internet or other electronic network activity informationBrowsing history, search history, information regarding the consumers interaction with a website, application or advertisementYESTracking technologies such as cookies collect information from your use of our website, including search queries, surveys and content clicks. Third party advertisers or their advertising servers, or other third-party service providers may also place cookies on your devices used to access our site.NO
Geolocation dataPhysical location or movementsNON/AN/A
Sensory dataAudio, electronic, visual, thermal, olfactory informationNON/AN/A
Professional or employment-related informationCurrent or past job history or performance evaluationsNON/AN/A
Non-public education information as defined in the Family Education Rights and Privacy ActEducation records related to a student maintained by an educational institution or party acting on its behalf, such as student grades, transcripts, class lists, schedule, identification codes, financial information or disciplinary records.NON/AN/A
Inferences drawn from any of the information identified aboveInformation is used to create a profile of consumer’s preferences, [characteristics, psychological trends behaviour, attitudes, intelligence, abilities, and aptitudes]YES, excluding bracketed informationAs you click through our website, tracking technologies such as cookies track your clicks so that we can build a profile of your interests in order to recommend similar content and products that may be of interest to youNO
Agile Financial Insights LLC, Use of your Personal Information

Personal information collected from you may be used for one or more of the following business purposes:

  • To address your inquiries associated with the information you provided to us;
  • To provide you with products, services, and information you request from Agile Financial Insights LLC or Agile Financial Insights LLC partners;
  • To provide you with emails, event notifications, invitations, newsletters, announcements and other communications regarding our products, services, and matters that may be of interest to you;
  • To meet our obligations and enforce our rights under contracts we enter with you for our products and services;
  • To improve our website content and how it is presented to you;
  • To analyze for product development;
  • To comply with requests for information required by law.

Agile Financial Insights LLC does not sell the personal information we collect from you. 

California Residents’ Rights under the CCPA

You have specific rights regarding how your personal data is collected and used.

  • You have the right to request that Agile Financial Insights LLC disclose our collection and use of your personal information during the past 12 months, specifically:
    • Categories of personal information collected;
    • Sourced of personal information collected;
    • Our business purpose for collecting (or selling) that personal information;
    • Categories of third parties with whom we share your personal information;
    • Categories of personal information sold or disclosed to third parties.
  • You have the right to request a copy of the personal information collected prior to your request in the past 12 months;
  • You have the right to request deletion of that information (with exceptions noted by law);
  • You have the right to request that your personal information not be sold to third parties, if applicable; and
  • You have the right not to be discriminated against because you exercised these rights.

We will respond to your verifiable request to disclose and or delete your personal information within 45 days, providing you with an electronic copy of your information; however, if we up to an additional 90 days as permitted under the CCPA to respond, we will inform you within 45 days of your request.  

In the event you request deletion, Agile Financial Insights LLC will be unable to do so, as permitted by the CCPA, in event the personal information is necessary to:

  • Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of a business’s on-going business relationship with you, or otherwise perform a contract between Agile Financial Insights LLC and you;
  • Detect security incidents, protect against malicious deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with section 1546) of Title 12 of Part 2 of the Penal Code;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of that information is likely to render impossible or seriously impair the achievement to such research, if you have provided informed consent;
  • To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with a legal obligation;
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided information.
How to Contact Agile Financial Insights LLC to Exercise Your Rights

You can submit your request for disclosure, copies or deletions of your personal information to Agile Financial Insights LLC by contacting us (or contact us with your questions regarding our collection, use and sharing of your personal information):

  • compliance@agilefinancial.io
  • +1 914 584 2842
  • Visiting agilefinancal.io/privacy
  • Call our compliance officer +1 914 584 2842

The CCPA restricts you to two verifiable requests within a 12-month period.  Only you or a person registered with the California Secret of State that you authorize to act on your behalf may make a verifiable request regarding your personal information. Agile Financial Insights LLC cannot respond to a request if we are unable to verify your identity or authority to make the request on behalf of another.  Please provide information sufficient to confirm your identify or your authority to make the request on behalf of another, and describe your request with sufficient detail that allows us to understand and respond to your request. We will endeavour to respond to your request within 45 days of receipt.  If more time is required (up to 90 days), we will inform you of the reason and extension of time required.  There is no fee charged for processing your request.

Reservation of Rights

Agile Financial Insights LLC reserves it rights with regard to any verifiable request, its evaluation of what is necessary to comply with the CCPA, and to amend this notice at any time within Agile Financial Insights LLC discretion. 

LEGAL STATEMENT

 The following terms and conditions govern your use of this web site and all content, services and products available on or through the website (taken together, the “Site”). The Site is owned and operated by Agile Financial Insights LLC. and its affiliates (together, “Agile Financial Insights LLC”) as a service to its clients and investors and may be used for informational purposes only. Access to and use of the Site is subject to your acceptance without modification of all the terms and conditions contained herein, and all other operating rules, policies, and terms on this Site and any applicable written agreements with Agile Financial Insights LLC (which, in the event of a conflict with this terms and conditions, shall govern). Single copies of material contained on this Site may be downloaded for non-commercial, personal use subject to the provisions below and provided that you also retain all copyright and other proprietary notices contained on the materials. If you do not agree to these terms, do not use the Site or download any materials from it. If you do not agree to the terms, or if you cannot remain in compliance with such terms, you may not access or use the Site.

Agile Financial Insights LLC may revise these terms at any time by updating this posting. You should visit this page from time to time to review the then-current terms because they are binding on you. Certain provisions of these terms may be superseded by expressly designated legal notices or terms located on particular pages at this Site.

ACCOUNT RESPONSIBILITY: You are responsible for maintaining the security and confidentiality of your account and password, and you are fully responsible for all activities that occur under your account, whether by you or anyone else. You may not create or use an account for anyone other than yourself. You must immediately notify Agile Financial Insights LLC of any unauthorized uses of your account or any other breaches of security. Agile Financial Insights LLC will not be liable for any acts or omissions by you, including any damages of any kind incurred as a result of such acts or omissions. Agile Financial Insights LLC will not be liable for any loss that you or any other third party may incur as a result of someone else’s use of your account or password, either with or without your knowledge. Agile Financial Insights LLC may hold you liable for any losses incurred by Agile Financial Insights LLC or any other party due to someone else’s use of your account or password.

INTELLECTUAL PROPERTY INFORMATION: Unless otherwise noted, product names, designs, logos, titles, text, images, audio, video and other content within this Site are the trademarks, service marks, trade names, copyrights or other property of Agile Financial Insights LLC (“Agile Financial Insights LLC Intellectual Property”) or its third party content providers (“Third Party Intellectual Property”). Nothing contained on the Site should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any of Agile Financial Insights LLC Intellectual Property or Third Party Intellectual Property displayed on the Site without the written permission of Agile Financial Insights LLC. All rights in and to the Site and its content are retained by Agile Financial Insights LLC. To obtain permission, send an e-mail to marketing@agilefinancial.io.

COPYRIGHT NOTICE: Copyright © 2018 Agile Financial Insights LLC All rights reserved.

You acknowledge and agree that the contents of this Site, including Agile Financial Insights LLC Intellectual Property and Third Party Intellectual Property, are protected by the copyright laws of the United States and other foreign jurisdictions.

No portion may be reproduced in any form, or by any means, without the prior written consent of Agile Financial Insights LLC. To obtain reproduction consent, send an e-mail to Agile Financial Insights LLC marketing@agilefinancial.io.

As Agile Financial Insights LLC asks others to respect its intellectual property rights, it respects the intellectual property rights of others (please see Acceptable Use Policy below). If you believe that material located on the Site violates your copyright, you are encouraged to notify Agile Financial Insights LLC at  compliance@agilefinancial.io. Agile Financial Insights LLC will respond to all such notices, including as required or appropriate by removing the infringing material or disabling all links to the infringing material. Agile Financial Insights LLC will, to the extent it is able, terminate a user’s access to and use of the Site if, under appropriate circumstances, the user is determined to be a repeat infringer of the copyrights or other intellectual property rights of Agile Financial Insights LLC or others.

DISCLAIMER AND LIMITATION OF LIABILITY: USE OF THIS WEBSITE IS AT YOUR OWN RISK. THE MATERIALS ON THIS SITE ARE PROVIDED “AS IS” AND “AS AVAILABLE” WITHOUT ANY EXPRESS OR IMPLIED WARRANTY OF ANY KIND INCLUDING, WITHOUT LIMITATION, WARRANTIES OF MERCHANTABILITY, NON INFRINGEMENT OF INTELLECTUAL PROPERTY OR FITNESS FOR ANY PARTICULAR PURPOSE. YOUR SOLE AND EXCLUSIVE REMEDY IN THE CASE OF DISSATISFACTION WITH THIS SITE OR ANY OTHER GRIEVANCE SHALL BE YOUR TERMINATION AND DISCONTINUANCE OF ACCESS TO OR USE OF THE SITE.

IN NO EVENT SHALL Agile Financial Insights LLC OR ITS SUPPLIERS BE LIABLE FOR ANY DAMAGES WHATSOEVER (INCLUDING, WITHOUT LIMITATION, DAMAGES FOR LOSS OF PROFITS, BUSINESS INTERRUPTION OR LOSS OF INFORMATION) ARISING OUT OF THE USE OR INABILITY TO USE THIS SITE, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

Agile Financial Insights LLC assumes no responsibility, and shall not be liable for, any such damages to or viruses that may infect your computer equipment, software, data or other property on account of your access to, use of, or browsing in the Site or your downloading of any materials, data, text, images, video or audio from the Site or any linked sites. Agile Financial Insights LLC and its suppliers further do not warrant the accuracy or completeness of the information, text, graphics, links or other items contained within the materials posted, set forth, downloadable or linked to this Site. Agile Financial Insights LLC may make changes to or discontinue any or all of these materials, or the products described therein, at any time without notice. Agile Financial Insights LLC makes no commitment to update the information on this Site.

THE ABOVE LIMITATION OR EXCLUSION MAY NOT APPLY TO YOU TO THE EXTENT PROHIBITED BY APPLICABLE LAW.

USER SUBMISSIONS: Any content, material, information or other communication, including, without limitation, data, questions, comments, feedback, suggestions or the like (collectively, the “Communications”), that you transmit or post to this Site will be considered non-confidential and non-proprietary. If you transmit or post any Communications to this Site, you hereby grant Agile Financial Insights LLC a world-wide, royalty free, fully paid, perpetual, irrevocable, and fully assignable, transferable and sub licensable right to use, reproduce, modify, adapt, publish, perform, translate, create derivative works from, distribute, display and otherwise exploit such Communications throughout the world in any form, media or technology, whether now known or hereafter devised or developed.  Agile Financial Insights LLC will have no obligations in connection with any of the Communications, including but not limited to any obligation to retain or provide you with copies of your Communications or to guarantee any confidentiality with respect to your Communications. Agile Financial Insights LLC cannot prevent the “harvesting” of information from this Site, and you may be contacted by Agile Financial Insights LLC or unrelated third parties, by e-mail or otherwise, within or outside of this Site. Furthermore, at the sole discretion of Agile Financial Insights LLC, the Communications, including all data, images, sounds, text and other things embodied therein, may be edited by or on behalf of Agile Financial Insights LLC, may or may not be posted to this Site and may be used by Agile Financial Insights LLC for any purpose, including, reproduction, disclosure, distribution, transmission, publication, broadcast and posting. The Communications may be used by Agile Financial Insights LLC for any and all commercial or non-commercial purposes including, but not limited to, developing, manufacturing and marketing products using such information.

ACCEPTABLE USE POLICY: You are prohibited from:

  • posting or transmitting to this Site any Communications that are unlawful, threatening, libellous, defamatory, obscene or pornographic or that would otherwise violate any law;
  • posting or transmitting any Communications that could constitute or encourage conduct that would be considered harmful, fraudulent, infringing, offensive, illegal or give rise to civil liability;
  • posting or transmitting any Communications that contain any viruses, worms, malware, Trojan horses or other harmful, destructive or contaminating content;
  • posting or transmitting any unsolicited messages, promotions, advertising, or solicitations (like “spam”) or that is machine- or randomly-generated;
  • copying, modifying, publishing, transmitting, distributing, transferring, selling, creating derivatives of, or in any way exploiting, any material accessible through the website not submitted or provided by you, including by use of any robot, spider, scraper, scripting, deep link or other similar automated gathering or extraction tools, program, algorithm or methodology, unless you obtain Agile Financial Insights LLC prior written consent;
  • using the Site to advertise, market, sell or otherwise promote any commercial enterprise that you own, are employed by or are otherwise compensated by, either directly or indirectly;
  • using this Site in any way to violate the security or integrity of any network, computer or communications system, software application, or network or computing device or otherwise attempt to disrupt or tamper with Agile Financial Insights LLC servers;
  • attempting to gain unauthorized access to any of the Site or other accounts through hacking, password mining or other means; or
  • using or encouraging, promoting, facilitating or instructing others to use the Site in any matter not explicitly permitted under these terms.

Agile Financial Insights LLC has the right (but not the obligation) to monitor activity on the Site and investigate any violation of this Agreement or misuse of the Site. If you become aware of any violation of this Agreement or misuse of the Site, you must immediately notify us and provide us with assistance, as requested, to stop or remedy such violation. Agile Financial Insights LLC hereby notifies you that it will cooperate fully with any law enforcement authorities or court order requesting or directing Agile Financial Insights LLC to disclose the identity of or help identify or locate anyone posting any such information or materials. Agile Financial Insights LLC further has the right (but not the obligation) to refuse or remove any Communications from this Site or terminate or deny access to and use of the Site for any reason. Agile Financial Insights LLC is under no obligation to enforce these terms on your behalf against another user. Agile Financial Insights LLC reserves the right to take appropriate action in its sole discretion.

You hereby represent and warrant that (a) your use of the Site will not infringe the proprietary rights of any third party; (b) your use of the Site will be in strict accordance with these and any other applicable terms and with all applicable laws and regulations; (c) that any Communication you post or transmit to the Site is accurate.

USER RESPONSIBILITYAgile Financial Insights LLC has not reviewed, and cannot review, all of the Communications and material posted to the Site, and therefore cannot be responsible for its content, use or effects. By operating the Site, Agile Financial Insights LLC does not represent or imply that it endorses the material there posted, or that it believes such material to be accurate, useful, lawful or non-harmful. Neither Agile Financial Insights LLC nor any of this third party suppliers guarantees, endorses, or is otherwise responsible or liable for the accuracy, completeness, timeliness, reliability, availability, or usefulness of any Communications and material accessible through the Site. The information provided on this Site by Agile Financial Insights LLC speaks only as of the respective dates on which the information was first created. This information can become out-of-date. Agile Financial Insights LLC makes no commitment, and disclaims any duty, to update any of this information, except as expressly stated on this Site. You use this Site at your own risk and are responsible for taking precautions as necessary to protect yourself and your computer systems.

USE OF PERSONALLY IDENTIFIABLE INFORMATION: Information submitted to Agile Financial Insights LLC on this Site is governed according to  Agile Financial Insights LLC Online Privacy Policy.

LINKS TO OTHER MATERIALS: The linked sites are not under the control of Agile Financial Insights LLC, and Agile Financial Insights LLC is not responsible for the content, including, without limitation, the truthfulness or accuracy of any statement or other content, of any linked site or any link contained in a linked site. Agile Financial Insights LLC reserves the right to terminate any link or linking program at any time. Agile Financial Insights LLC has not reviewed all the information contained in the linked sites and does not endorse the companies, products or sites to which it links and reserves the right to note as such throughout the Site. If you decide to access any of the third-party sites linked to our Site, you do this entirely at your own risk.

INDEMNIFICATION: You agree to indemnify, defend and hold harmless Agile Financial Insights LLC t, its contractors, and its third-party suppliers, and their respective directors, officers, employees and agents from and against any and all claims, costs, liabilities and expenses (including attorneys’ fees) arising out of your use of the Site, including but not limited to your violation of these terms. Agile Financial Insights LLC reserves the right, at your expense, to control the defence of these claims. You agree not to settle any claims without Agile Financial Insights LLC written consent. You agree to notify Agile Financial Insights LLC immediately in writing of any such claims.

TERMINATION: Agile Financial Insights LLC may terminate your access to all or any part of the Site at any time, with or without cause, with or without notice, effectively immediately. If you wish to terminate these terms, or your user account (if you have one), you may simply discontinue using the Site. All provisions of these terms which by their nature should survive termination shall survive, including, without limitation, intellectual property ownership provisions, warranty disclaimers, indemnity and limitations of liability.  

APPLICABLE LAWS: This site is controlled by Agile Financial Insights from its offices located in the State of New York within the United States of America. Agile Financial Insights LLC does not make any representation that materials at this Site are appropriate or available for use outside the United States, and access to them from territories where the content of this Site is illegal is prohibited. While this Site may be viewed internationally and may contain references to products and services not available in all countries, such references do not imply that Agile Financial Insights LLC intends to make such products or services available in such countries. You may neither use, export or re-export the materials at this Site, nor may you use any copy or adaptation of such materials, in each case, in violation of any applicable laws or regulations, including, without limitation, United States export laws and regulations. Except to the extent applicable law provides otherwise, these terms, any access to or use of the Site, will be governed by the laws of the State of New York within the United States of America, excluding its conflict of law provisions, and the proper venue for any disputes arising out of or relating to any of the same will be the state and federal course located in Connecticut.

GENERAL: If any part of these terms is held invalid or unenforceable, that part will be construed to reflect the parties’ original intent, and the remaining portions will remain in full force and effect. A waiver by either party of any term or condition of these terms or any breach thereof, in any one instance, will not waive such term or condition or any subsequent breach thereof. You may not assign or otherwise transfer your rights under this Agreement to any party, including by operation of law. Agile Financial Insights LLC may assign or otherwise transfer its rights under this Agreement without condition. This Agreement will be binding upon and will inure the benefit of the parties, their successors and permitted assigns.

These terms were last updated 02.04.2020.

GDPR DATA PROTECTION NOTICE

Last Revised May 17, 2018

1. Introduction

Thank you for visiting www.agilefinancial.io, the Website of Agile Financial Insights LLC Research Systems Inc. and its affiliates (“Agile Financial Insights LLC” or “we”).  Agile Financial Insights LLC is a provider of integrated financial information and analytical applications to the global investment community. To protect your privacy better, Agile Financial Insights LLC wants our customers, suppliers and other relevant parties to know how we collect personal data, the types of personal data we collect, and how we use and share your personal data when we act as the controller of that personal data that is subject to the EU General Data Protection Regulation (GDPR). Hence this notice only applies to personal data which is subject to GDPR and which we collect:

  • on this Website;
  • on client and supplier facing applications and tools (e.g. Workstations, Starboard and Gateway, Object Reference, Endpoint Reference, Confluence, Jira);
  • in email, text, and other electronic messages between you and our employees; when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this notice;
  • from customers and suppliers subject to contractual relationships;
    from public and third party sources for the purposes of providing and/or administrating our content services;

It does not apply to any other personal data, and notably personal data collected by:

  • any third party regardless whether collected through any application; or
  • any content (including advertising) that may link to or be accessible from or on the Website.

2. Summary

We collect and process personal data mainly from our customers and suppliers while doing business with them and we collect and receive personal data on this Website and through social networks (see more information under section 3). The personal data we process is mainly business contact information from our clients and suppliers and also information you and our customers provide when using our products or accessing our websites or other applications (see more information under sections 4 and 5). We also collect and collate information (including some personal data) from third party suppliers and public sources to make available to our customers as part of the services we offer to them (see more information under section 6).  We mainly process the personal information in order to provide our services and to fulfil our contractual obligations and to improve our products and offerings (see more information under sections 7 and 8). We do not sell such personal data to third parties for their own use but we might share it with third parties when there is a legal requirement to do so or where we need a third party to fulfil our services (see more information under section 9). We transfer personal data within our group based on an Intragroup-Data-Transfer-Agreement, which subject to the GDPR (see more information under section 10). You can learn more about where and how we use cookies related to our Website and services by reading section 11. This notice informs you also about our retention policy (section 12). You have rights in respect of your personal data. To learn more about those rights, please read section 14. You will also find our contact information at the end of this notice under section 17.

3. Personal Data that we collect

We collect several types of information and personal data:

  • that relates to an identified or identifiable individual, such as name, postal address, email address, telephone number, IP or MAC address etc. and related information, such as the contents of an email (“personal data”);
    • about your internet connection, the equipment you use to access our Website and usage details (e.g. statistics) regarding our products (“usage information”).

We collect this information and personal data:

  • directly from you and/your employees when you or they provide it to us;
  • automatically as you and/or your employees navigate through the site and/or use our products. Information and personal data collected automatically may include usage information, IP addresses, and information and personal data collected through cookies, web beacons, and other tracking technologies;
    • from public and third party sources.

4. Personal Data You Provide to Us

The personal data we collect may include:

  • personal data that you provide by conducting business with us, by filling in forms on our Website, or at a trade show, or anywhere else we conduct business, by subscribing to newsletters or other communications, or by corresponding with us by phone, e-mail or otherwise using our contact details. This includes personal data provided at the time of requesting information or services, soliciting business or performing a service. We may also ask you for personal data when you enter a contract with us, or a contest or promotion sponsored by us, and when you report a problem;
  • records and copies of your correspondence (including email addresses);
  • your responses to surveys that we might ask you to complete for research purposes;
  • your search queries on the Website;
  • during the contractual relationship for execution of the supplier or customer contract;
  • by using our incident management and project management tools and applications;
  • by communicating with our customer care teams for error resolving issues, training and support;
    • Your usage of our products and relating tools and applications.

Typically, the personal data you give us may include name, business affiliation, business address, telephone number, and email address, and any personal details required to conduct business with you or to resolve any enquiries or complaints.

We will indicate to you when personal data is required to enter into a contract with you (such as in anticipation of a services agreement) or to perform a contract with you (such as to provide services at your request), and failure to provide any personal data may result in our inability to provide requested services or products.

5. Personal Data We Collect Through Automatic Data Collection Technologies

If you navigate through and interact with our Website and some of our products, we may use automatic data collection technologies to collect certain usage information about your equipment, browsing actions, and patterns. Automatic data collection is carried out through the use of cookies and related technologies.  For more information, please see section (11).

6. Personal Data We Collect From Public Sources and Third Parties

In order to provide our content services to our customers, we rely on content provided by third party suppliers, as well as content that is available to the public. Some of that content includes general information about names of directors, registered board members, managers, fund managers and other official persons of companies published on public accessible websites, letterheads, prospects, annual financial statements, invitations to shareholder meetings etc.

7. Lawful Grounds for Processing

All processing and use of your personal data is justified by a “lawful ground” for processing. In the majority of cases, processing will be justified on the lawful ground that:

  • the processing is necessary to perform a contract with you or take steps to enter into a contract at your request, such as to negotiate a contract with us, to fill an order, or to provide product information that you have requested;
  • the processing is necessary for us to comply with a relevant legal obligation, such as keeping accounting records;
  • the processing is in our legitimate interests, which are not overridden by the interests and rights of the relevant individual whose personal data is collected; and
  • you have consented to the processing.

Where we rely on our legitimate interests to process personal data, those interests are:

  • to use supplier, customer and website user data to conduct and develop our business activities and improve our services in order to grow our business and profitability, while limiting the use of their personal data to purposes that support the conduct and the development of our business and the improvement of our services;
  • to use third party supplier and publicly available content (which in some instances includes personal data) in order to provide our content services to customers for their business purposes, which may include, but not be limited to taking investment decisions or compliance with applicable laws and regulations such as insider trading regulations and anti-bribery legislation, but which are for our customers to determine and explain in their privacy notices).

8. Why We Collect Personal Data

The following is an overview of our purposes for using your personal data. Additional details on how we process your personal data may be provided to you in a separate notice or contract.

We use the personal data we collect to:

  • provide customer services, including products and services; to take, verify, process, and deliver orders and returns; to process payments, technical support, or other similar purposes; and to establish and maintain customer accounts;
  • to provide training and after-sales-support on our products and answer to and perform change requests;
  • to organize and perform incident management processes;
  • to implement projects by working together with customers and their users as part of the project team;
  • communicate with customers and suppliers, including responding to requests for assistance and to update them about the status of their orders by postal mail, email, telephone, and/or text message;
  • investigate, prevent or take action regarding unauthorized use of our services, illegal activities, suspected fraud or situations involving potential threats;
  • to provide you with underlying tools and applications helping to implement projects and solving incidents;
  • to discuss, carry out and implement change request and further developments of our products;
  • to provide our content services to our customers and to report and administer customers’ users’ usage of third party information products (e.g. real-time data from stock exchanges etc.);
  • administer and manage performance of purchase or sales agreements with our suppliers and customers;
  • to enhance the experience for our users, we use notes relating to support provided to specific employees, advisors or agents of customers in relation to our products and services for their future use of our services;
  • service your account;
  • market and promote our products including through email or equivalent electronic means, to send news and newsletters, special offers and promotions, or to otherwise contact customers about products, services or information;
  • process, evaluate and complete certain transactions involving the website, and more generally transactions involving Agile Financial Insights LLC products and services;
  • operate, evaluate, maintain, improve and develop the Website (including by monitoring and analysing trends, tracking user behavior, access to, and use of the website for advertising and marketing);
  • engage with you about events, promotions, the Website and Agile Financial Insights LLC products and services;
  • provide you with documentation or communications which you have requested or which is part of a product;
  • correspond with users to resolve their queries or complaints;
  • send you marketing communications, where it is lawful for us to do so;
  • protect the security of the Website, Agile Financial Insights LLC confidential and proprietary information (which may include personal data), and Agile Financial Insights LLC employees;
  • manage, protect against and investigate fraud, risk exposure, claims and other liabilities, including but not limited to violation of our contract terms or laws or regulations;
    • share your personal data with third parties in connection with potential or actual sale of our company or any of our assets, or those of any affiliated company, in which case personal data held by us about our users may be one of the transferred assets.

Agile Financial Insights LLC will not sell or rent your personal data you provided to us to third parties.

9. Sharing Your Personal Data

When you have provided personal data to us, we may disclose such personal data to other companies that we have engaged to assist us in providing you goods or services.  This may include, but is not limited to, fulfilment houses, billing services, transaction managers, credit verification services, and other third-party service providers.  We also may disclose your personal data to third party service providers that assist us in conducting market research for our own purposes.  We do not sell personal data to third parties for their own use, but may provide certain usage information to advertisers to help provide you with relevant advertising. 

We may also disclose any of your personal data or usage information to law enforcement or other appropriate third parties in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, or other suspected illegal activities, as may be required by applicable law, or, as we may deem necessary in our sole discretion, in order to protect our legitimate legal and business interests.

We reserve the right to disclose, share and/or otherwise transfer personal data and usage information in connection with a proposed or actual corporate merger, acquisition, consolidation, the sale of a portion of our business or the sale of substantially all of our assets, or other fundamental corporate change, whatever form it may take. You will be notified via a prominent notice on our website prior to a change of ownership or control of your personal data or usage information.

10. Transferring Personal Data

Agile Financial Insights LLC is a global organization headquartered in the United States, and we may need to transfer your personal data to third party suppliers and to our affiliates for the purposes described above.  If your personal data is subject to the GDPR and is transferred outside the EU to other Agile Financial Insights LLC affiliates or to third party service providers, we will take steps to ensure that your personal data receives the same level of protection as if it remained within the EU, including by entering into data transfer agreements using the European Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU – US Privacy Shield.  For transfers of personal data among Agile Financial Insights LLC affiliates we have put in place European Commission-approved Standard Contractual Clauses and have entered into an Intragroup data transfer agreement. You have a right to obtain details of the mechanism under which your personal data is transferred outside of the EU, although please note that we may need to redact copies of transfer agreements for reasons of commercial confidentiality, provided that you can retain access to the relevant safeguards.

Agile Financial Insights LLC reserves the right to share any information that you provide which is not deemed personal data or is not otherwise subject to contractual restrictions.

11. Use of Cookies and Other Electronic Tools

Our Website uses technologies that enhance user friendliness and engagement, to keep the Website operating as smoothly as possible and to provide web services and functionalities for each visitor. Examples of these technologies are cookies, pixel tags, local storage and scripts:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information (including personal data) about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
    • Web Beacons. Pages of our Website and our emails may contain small electronic files known as Web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We may collect personal data automatically, and we may tie this personal data to personal data about you that we collect from other sources or you provide to us.

In this Policy, we refer to cookies, flash cookies and web beacons as “cookies”.

Cookies are used for a variety of purposes. For example, they calculate web statistics, provide online advertising and they improve visitor’s experience on our Website. As your privacy is important to us, we would like to inform you about which cookies are used on our Website, as well as why we use them. We use the following cookies on our Website:

  • Functional cookies: these cookies are essential in order to ensure that our Website operates properly. They are used to save preferences, detect misuse of our Website and services and to distribute the load on our servers, which keeps our Website available. Certain services you may request cannot be provided without these cookies.
  • Web statistics cookies: these cookies are used to determine which parts of our Website interest our visitors. This enables us to make the structure, navigation, and content of our Website as user friendly as possible.  We and the parties with whom we work (e.g., service providers, business partners, advertisers and advertising servers) may place, view, and/or use cookies, Web server logs, Web beacons, or other electronic tools to collect statistical and other usage information about your use of this Website and all other websites which relate to, provide, or market Agile Financial Insights LLC products and services. This usage information may include information about the IP address of your computer, browser type, language, operating system, your mobile device, geo-location data, internet service provider, the state or country from which you accessed this Web site, the Web pages visited, the date and the time of a visit, the websites you visited immediately before and after visiting this Web site, the number of links you click within this Web site, the functions you use on this Web site, the databases you view and the searches you request on this Web site, the data you save on or download from this Website and the number of times you view an advertisement. Software from third parties (Google Analytics) may be used for these purposes. Information generated by the use of Google Analytics may be transmitted to and stored on a Google server in the US.
  • Social media cookies: our Website may integrate certain third-party plug-ins (such as a Facebook “like” button).  Even if you do not click on these plug-ins, they may collect information about you, such as your IP address and the pages that you view. These plugins are governed by the privacy policy of the third party providing them.
  • Advertising cookies: our Website may also enable third-party tracking mechanisms to collect data over time and across unaffiliated websites for use in interest-based advertising. For example, third parties may use the fact that you visited the Website to send you online ads for Agile Financial Insights LLC products on third party websites.  In addition, our third-party advertising partners might use information about you to send you targeted advertisements based on your online behaviour in general. Information (including personal data) about your visits to, and activity on, this Website and other websites, an IP address, the number of times you have viewed an advertisement, and other such usage information is used, alone or in combination with other information and personal data, to display on your device screen advertisements that may be of particular interest to you. We may use Web beacons, provided by third party advertising companies, to help manage and optimize our online advertising and product performance. Web beacons enable us to recognize a browser’s cookie when a browser visits this Website, and to learn which banner ads bring users to this Website. The use and collection of your information and personal data by these third party service providers, and third party advertisers and their advertising servers is not covered by this Privacy Notice. 

To opt out of advertising cookies for Your Online Choices if you are based in the EU, please click here. To opt out of Google Analytics for Display Advertising, please click here. You may also enable the “Do Not Track” setting in your web browser(s) or clear cookies from your browser after each browsing session. Please note that even if you exercise choice for targeted advertising, you will still receive online advertising.

  • Matching or connecting cookies: We or our third-party service providers also may use collected information to establish connections among related web browsers and devices (such as smartphones, tablets, computers, and TVs) for targeted advertising, analytics, attribution, and reporting purposes. These third parties may match your browsers or devices if you log into the same online service on multiple devices or if your devices share similar attributes that support an inference that they are used by the same person or household. This means that information about your activity on Website or apps on your current browser or device may be combined with information collected from your other browsers or devices.
  • Other cookies: this category includes cookies that do not fit into one of the above cookie categories. One example of this is the bundling of several of the cookies via Google Tag Manager.

How to manage cookies

If you do not want our Website to store cookies on your device, you can change your browser settings so that you receive a warning before certain cookies are stored. You can also adjust your settings so that your browser refuses most of our cookies or only certain cookies from third parties. You can also withdraw your consent to cookies by deleting the cookies that have already been stored.

Please be aware that if you do not want to accept any cookies, we cannot guarantee that our Website will function properly. It may be that several functions will be unavailable to you or that you will even be unable to view certain parts of the Website.

Please note that you will have to change your settings for each browser and device you use. Moreover, such methods will not work with respect to certain non-cookie online tracking technologies.

The procedures for changing your settings and cookies differ from browser to browser. If necessary, use the help function on your browser or click on one of the links below to go directly to the user manual for your browser.

There are also software products available that can manage cookies for you. You can also use www.ghostery.com to accept or refuse each cookie used on our Website.

To find out more about cookies, including how to see what cookies have been set and how to manage or delete them, visit www.allaboutcookies.org.

12. Retention of Your Personal Data

We keep personal data only for as long as required to fulfil the purposes for which it was collected.  In general, we retain personal data for a period of time corresponding to a statute of limitation, for example to maintain an accurate record of customer and supplier dealings. However, in some circumstances we may retain personal data for other periods of time, for instance where we are required to do so in accordance with legal, tax or accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required in accordance with our document retention policy.

13. Your Rights

We will take steps in accordance with applicable legislation to keep personal data accurate, complete and up-to-date. You are entitled to have any inadequate, incomplete or incorrect personal data corrected (that is, rectified). You also have the right to request access to your personal data as well as to obtain additional personal data about the processing. In the event the lawful ground (see Lawful Grounds for Processing above) for processing your personal data is your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing before withdrawal. Further, you are entitled to object to the processing of your personal data or to have your personal data erased, under certain circumstances.

As from 25 May 2018, the following rights also apply solely to processing of personal data, which is subject to the GDPR.  Each right may only apply in certain circumstances, and subject to exemptions under either EU or Member State law:

  • Data portability.
  • Right to erasure.
  • Right to restriction of processing.
  • Right to lodge a complaint with the supervisory authority.
  • Right to object to processing (including profiling) based on legitimate interest lawful grounds.
  • Right to object to direct marketing  (including profiling).

Please contact us as indicated in How To Contact Us or using the email-address: DataPrivacy@agilefinancial.io if you wish to exercise any of your rights, or if you have any enquiries or complaints regarding the processing of your personal data.

14. Data Security

Agile Financial Insights LLC takes reasonable precautions to protect personal data from loss, misuse, unauthorized access, disclosure, altercation, and destruction.  Unfortunately, while we work hard to ensure the security of your personal data while it is on our systems, no security measures are perfect and data transmitted over the Internet cannot be guaranteed to be 100% secure. We cannot and do not ensure or warrant the security of any personal data you transmit and you do so at your own risk.

15. Links to Other Websites

Our Websites may provide links to other websites for your convenience and information. These websites may operate independently from Agile Financial Insights LLC. Linked websites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not owned or controlled by Agile Financial Insights LLC, we are not responsible for the websites’ content, any use of the websites, or the privacy practices of the websites.

16. Changes to Our Privacy Notice

This Privacy Notice may be amended from time to time. Please review it periodically. Changes to this Notice will be announced on this Website in advance.

17. How to Contact Us

To exercise any of your rights described at Your Rights or to contact us please use the email-address: DataPrivacy@agilefinancial.io or if you have any questions or comments about this Privacy Notice, Agile Financial Insights LLC privacy practices, or if you would like us to update personal data or preferences you provided to us, please write to us at:

In the US: 
Global Privacy Officer
Agile Financial Insights LLC
6 Oregon Hollow Road, Armonk, NY 10504

In Europe:
Agile Financial Insights LLC
Willow House, Middle Wallop, Stockbridge, SO20 8EG

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