This Privacy Notice applies to the FX Connect website (this “Site”). This Privacy Notice applies to any personal information we may collect from you through this Site, independent of the device (i.e., mobile, computer) used to access this Site.
Privacy on the Site
State Street Bank and Trust Company (“State Street”) operates this Site to provide you with tools and resources to help you learn more about FX Connect, FX Connect Trade Services and related products and services. When you visit our Site we want you to feel confident that we are committed to maintaining the privacy of your personal information. By visiting this Site, you agree to the terms of this Privacy Notice (“Privacy Notice”), as they may be amended from time to time, and to State Street’s collection, use, processing and disclosure of your information as described below. State Street may change this Privacy Notice at any time without prior notice to you. Any changes or updates will be effective immediately upon posting to the Site.
What information we collect
We collect and process the personal information you provide to us when you contact State Street through the Site with a request. State Street also may collect your IP address and information regarding the computer or mobile device (“Device”) used to access this Site, such as its operating system, unique identifier and model name, as well as its user configurations and settings. And as discussed in detail below, we may also collect information relating to your use of the Site.
We may combine the information that we collect through the Site with personal or other information that we obtain from third parties (such as social media networks or marketing partners) or that we collect from you in other contexts (such as when you email us, call us, or attend one of our events). If the information collected is about you or relates to you, or is combined with such information, State Street will treat it as personal information.
Sensitive personal information
State Street recognizes that certain jurisdictions have enacted laws that require higher protection of certain sensitive personal information. "Sensitive personal information" includes categories of personal data identified by European and other data privacy laws as requiring special treatment. This may include personal identity numbers, racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union or profession or trade association, physical or mental health, biometric or genetic data, sexual life or criminal record (including suspected criminal activities). As a general rule, State Street does not require such sensitive personal information from you.
In the limited cases where we do seek to collect such information, we will seek to do so in accordance with applicable data privacy law requirements. If you choose to provide us with unsolicited sensitive personal information, you consent to us using the information, subject to applicable law as described in this Privacy Notice.
Cookies and online tracking
What are cookies?
Cookies are text files containing small amounts of information downloaded to your computer or device when you visit a site. Cookies are then sent back to the originating site on each subsequent visit, or to another site that recognizes that cookie. Cookies are useful because they allow a site to recognize a user’s device. You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu. For a video about cookies visit www.google.co.uk/goodtoknow/data-on-the-web/cookies.
Cookies do a lot of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and they generally improve the user experience. They can also help to ensure that the advertisements you see online are more relevant to you and your interests.
What types of cookies are there and which ones does the Site use?
There are four types of cookies explained below. We do not use any cookies on Site; however, while on our Site you may visit other sites and encounter them there.Strictly necessary cookies
These cookies are essential in order to enable you to move around a site and use its features, such as accessing secure areas of a site. Without these cookies, services you have asked for cannot be provided.Performance Cookies
These cookies collect information about how visitors use a site, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is anonymous and is only used to improve how a site works.Functionality cookies
These cookies allow a site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a site may be able to provide you with local information by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.
These cookies cannot track your browsing activity on other websites. They don’t gather any information about you that could be used for online advertising on other sites or remembering where you’ve been on the Internet outside of a site.
These cookies are used to deliver online advertisements on other websites that are more relevant to you and your interests. They are also used to limit the number of times you see such advertisements as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with a site operator’s permission. They remember that you have visited a site and this information is shared with other organizations such as advertisers. Quite often they will be linked to site functionality provided by the other organization.
'Do Not Track' disclosure
Do Not Track (DNT) is a technology standard that is currently under development that will allow you to restrict tracking when browsing from site to site on the web. When you choose to turn on the DNT setting in browsers that support this feature, the browser sends an automated browser signal to the websites and other web services (such as analytics services, advertising networks and social platforms) you encounter while browsing to prohibit tracking.
At this time, State Street does not recognize automated browser signals regarding tracking mechanisms, such as “do not track” requests.
How we use and share personal information
The information that we collect enables State Street to contact you regarding your inquiries or requests and further other purposes which we describe to you at the point where the information is collected. The purposes for which your information may be processed include but are not limited to the following:
- To fulfill your requests, including sending you white papers, newsletters and other supplements.
- To contact you for marketing purposes in line with the applicable laws. (See the section below entitled “Marketing communications and your choices.”)
- To operate our business in a prudent manner in accordance with industry standards and applicable law, which may include, in addition to supporting the Services, responding to inquiries and requests; preventing fraud; and monitoring and archiving communications.
State Street may disclose or share personal information to its affiliates for various purposes, as permitted by law, including in order for its affiliates to provide services.
State Street may also share personal information with government agencies, exchanges, or other self-regulatory organizations and law enforcement authorities as required or permitted by law, rule, regulation or legal process, including, without limitation, for governmental reporting or to enforce any rights State Street may have against you as necessary. Personal information about you that is collected on the Site, can become subject to the legal systems and laws in force in each state or country (a) where it is held, received or stored by you or us, (b) from where it is accessed by you or us, or (c) through which it passes. In addition, if you have an account with FX Connect or FX Connect Trade Services, because your account(s) may include information about more than one individual and about your business relations with State Street and its affiliates, statements released to comply with legal process may contain information regarding your relationship with these individuals and with us and our affiliates.
State Street may disclose your personal information (i) at the request of a bank or other regulatory agency or in connection with an examination of us by bank or other examiners; (ii) to our internal or external auditors or attorneys; (iii) when State Street believes disclosure is necessary or appropriate to prevent physical harm or financial loss in connection with an investigation of suspected or actual illegal activity; or (iv) if disclosure is necessary to protect the vital interests of a person.
State Street may disclose or share personal information to nonaffiliated third parties with whom it has contracted to perform services on its behalf. State Street requires its third-party servicers to agree to comply with appropriate privacy and security standards or to undertake to provide similar and appropriate levels of protection as State Street when processing personal information. In addition, State Street may share personal information and other information collected through the Site with a successor entity in the event of a merger, acquisition or similar transaction.
Marketing communications and your choices
State Street uses information collected on the Site and information obtained from third-party sources (such as social media networks) to market business services to our institutional customers. Specifically, we may collect, use and/or share your information with our affiliates and service providers in order to provide specific information that you request, thought leadership materials, industry information, invitations to events and webinars, and other communications or solicitations that we believe will be of interest to you. We target and tailor such communications based on your interaction with the Site and our emails; your inquiries; your participation in events or webinars; relevant social media activity; and other third-party data. No client proprietary information, and no information about any of the individuals or entities that your firm may service, will be collected, used or shared for purposes of delivering these communications to you.
By using the Site or voluntarily submitting your contact information on the Site, you consent to the use and sharing of your information for such purposes. You may, however, opt out of receiving such marketing communications by clicking here to send an email request, or by following the opt-out instructions contained in each communication.
How we transfer and store personal informationState Street is a global organization; personal information we collect may be transferred internationally throughout the world to countries where State Street does business, which may not have the same data protection laws as the country in which you reside. We have internal policies and procedures in place in an effort to achieve an equivalent level of protection across our organization. The transfer of personal information to other countries is based on a business need or to comply with applicable laws. Personal information stored or processed in a foreign jurisdiction may be accessed under a lawful order made in that jurisdiction.
By providing your information to State Street in the course of your access and use of the Site, you agree that your personal information, for the purposes explained in this Privacy Notice, may be transferred to and stored in other countries where State Street does business, which may not have the same data protection laws as the country in which you reside.
How we protect your personal information
We use security measures, in compliance with applicable law, to protect personal information from unauthorized access or use. Yet you should understand that the open nature of the Internet is such that information and personal information may flow, without security measures, over networks connecting you to our systems and may be accessed and used by people other than those for whom the data is intended.
To safeguard against unauthorized access to personal information by third parties, all electronic personal information held by State Street is maintained on systems protected by secure network architectures that contain firewalls and intrusion detection devices. The servers holding personal information are “backed up” (i.e., recorded) on a regular basis in an effort to avoid any inadvertent erasure or destruction of such personal information and are stored in facilities with appropriate security and fire detection and response systems.
This Site may, from time to time, contain links to and from the sites of third parties. If you follow a link to any of these sites, please note that these sites have their own privacy notices or practices and that we do not accept any responsibility or liability for these notices, practices or sites. Please check these policies before you submit any personal information to these sites.
As a person who provides State Street with personal information, you may inquire as to the nature of the personal information stored at and/or processed by State Street. You will be provided reasonable access to your personal information held by State Street and, where appropriate, with the ability to review and correct inaccuracies. State Street will cooperate in providing such access. All such requests for access may be made by sending a request in writing to email@example.com
To help protect your privacy and provide security, State Street takes reasonable steps to verify your identity before granting access to information. State Street shall respond to such reasonable requests made by you within such time period as required under applicable law after your identity has been confirmed and you have clarified the specific personal information that you require. If you demonstrate that the purpose for which the personal information is being processed is no longer legal or appropriate, the personal information will be deleted, unless the law or applicable data retention requirements require otherwise.
How to contact us
If you have questions or comments about this Privacy Notice, or about how your data is processed, please contact firstname.lastname@example.org
Effective date: April 15, 2015