At State Street Global Advisors (“SSGA”) we are committed to handling your Personal Data (defined below) responsibly and would like to let you know that we recognize and respect your right to privacy. This notice explains how SSGA and any fund or product sponsored, managed, or otherwise affiliated with SSGA (the “Funds”) (together “we”, “our”, “us”) collect, use, share or otherwise process Personal Data in connection with your relationship with us. For a list of the SSGA entities and Funds acting as a controller for the purposes of GDPR, please see annex I.
We may provide supplemental notices from time to time, for example where we collect or use your sensitive personal data, which should be read together with this notice. We will publish the current notice on our websites (the “Sites”) which will apply each time you share Personal Data with us. We reserve the right to amend or update this notice at any time.
We may collect your contact details (such as your address, email address and telephone number) or other information (such as your job title, identifying information required for anti-money laundering and related matters, your IP address, and information regarding the computer or mobile device ("Electronic Device") used to access our Sites, such as its operating system, unique identifier, and model name, as well as its user configurations and settings etc.) from which you can be identified (“Personal Data”). We may collect and use, for example, details you provide:
We may combine the information that we collect 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, we will treat it as Personal Data.
Any Personal Data which you provide to us or our agents is at your sole discretion. However, we may not be able to engage with you (fully or at all) if you do not provide requested Personal Data. Please do let us know if your Personal Data changes during our relationship. Please note that if your Personal Data is anonymised, it is no longer Personal Data.
In order to effectively manage our relationship with you, we will collect, use, process, or arrange processing of this Personal Data if and to the extent that we have a lawful basis to do so; that is:
We will also use your Personal Data and the Funds and their service providers (or any of their affiliates, agents, employees, delegates or sub-contractors) will use your Personal Data to:
We may use or disclose your Personal Data if we are required to do so by law or if we reasonably believe that we need to do so to protect our rights or to comply with a judicial or regulatory requirement or to pursue our legitimate interests. If we need to use your Personal Data for a reason which is not reasonably compatible with the original purpose, we will notify you and explain the basis on which we are permitted to so use your Personal Data.
SSGA uses information collected 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 us such as on our Sites and with our emails; your inquiries; your participation in events or webinars; relevant social media activity; and other third-party data. If you do not wish to receive this information from us, please manage your preferences accordingly. You can also unsubscribe by clicking on the unsubscribe link in any of our emails or by letting your SSGA contact know.
We may disclose or share Personal Data:
SSGA is a global organization and part of the global State Street group; Personal Data 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 relevant legal safeguards, internal policies and procedures in place in an effort to achieve an equivalent level of protection across our organization. To find out more about the safeguards that SSGA has in place please contact Jill Stoller (Chief Privacy Officer) at JStoller@StateStreet.com. The transfer of Personal Data to other countries is based on a business need or to comply with applicable laws. Personal Data stored or processed in a foreign jurisdiction may be accessed under a lawful order made in that jurisdiction.
By providing your information to SSGA in the course of your access and use of our Sites or the Services, you agree that your Personal Data, for the purposes explained in this privacy notice, may be transferred to and stored in other countries where SSGA does business, which may not have the same data protection laws as the country in which you reside.
We use security measures, in compliance with applicable law, to protect Personal Data from unauthorized access or use. Yet you should understand that the open nature of the Internet is such that information and Personal Data 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 Data by third parties, all electronic Personal Data held by SSGA is maintained on systems protected by secure network architectures that contain firewalls and intrusion detection devices. The servers holding Personal Data are "backed up" (i.e., recorded) on a regular basis in an effort to avoid any inadvertent erasure or destruction of such Personal Data and are stored in facilities with appropriate security and fire detection and response system.
When you contact SSGA with questions about our Sites or the Services, we must confirm your identity on the phone before discussing your information. The questions and answers you select when logging into our Sites for the first time are used for this identification process.
Our Sites 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 Data to these sites.
We will retain your Personal Data for as long as required and for as long as necessary to provide our Services, products and information or as permitted / required by applicable law. This period may extend beyond the termination of our relationship with you.
Any person who has sent us Personal Data has the right to:
In the interests of security, we may request specific information from you to help us confirm your identity when you are exercising your rights.
If you have provided your consent to the collection, processing and transfer of your Personal Data, you have the right to fully or partly withdraw your consent. If you choose to withdraw your consent, we will no longer process your Personal Data for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. You may also unsubscribe from any direct marketing at any time.
You will not generally have to pay a fee in relation to the exercise of the above rights but please note that a reasonable fee may be levied on excessive or manifestly unfounded requests or in such cases, we may refuse to comply with such excessive or unreasonable requests.
If you have questions or comments about this privacy notice, or about how your data is processed, please contact: Jill Stoller (Chief Privacy Officer) at JStoller@StateStreet.com
Last updated: 25 May 2018
|No.||Controller entity||DPO contact|
|1||State Street Global Advisors Limited||Jill Stoller|
|2||State Street Global Advisors Ireland Limited||Jill Stoller|
|3||State Street Global Advisors GmbH||Werner Wegl|
|4||State Street Unit Trust Management Limited||Jill Stoller|
|5||Managed Pensions Fund Limited||Jill Stoller|
|6||State Street Global Advisors Luxembourg SICAV||Jill Stoller|
|7||State Street Global Advisors Liquidity Plc||Jill Stoller|
|8||SSGA SPDR ETFs Europe I Plc||Jill Stoller|
|9||SSGA SPDR ETFs Europe II Plc||Jill Stoller|
|10||State Street ICAV||Jill Stoller|
|11||Windwise Qualified Funds Plc||Jill Stoller|
|12||State Street Global Advisors Trust Company||Jill Stoller|
|13||SSGA Funds Management, Inc.||Jill Stoller|
|14||State Street Master Funds||Jill Stoller|
|15||State Street Institutional Investment Trust||Jill Stoller|
|16||State Street Navigator Securities Lending Trust||Jill Stoller|
|17||Elfun Government Money Market Fund||Jill Stoller|
|18||Elfun Tax-Exempt Income Fund||Jill Stoller|
|19||Elfun Income Fund||Jill Stoller|
|20||Elfun Diversified Fund||Jill Stoller|
|21||Elfun International Equity Fund||Jill Stoller|
|22||Elfun Trusts||Jill Stoller|
|23||SPDR Series Trust||Jill Stoller|
|24||SPDR Index Shares Funds||Jill Stoller|
|25||SSGA Master Trust||Jill Stoller|
|26||SSGA Active Trust||Jill Stoller|
|27||The Select Sector SPDR Trust||Jill Stoller|
|28||State Street Institutional Funds||Jill Stoller|
|29||State Street Insurance Series Funds Inc.||Jill Stoller|
|30||SPDR S&P 500 ETF Trust||Jill Stoller|
|31||SPDR Dow Jones Industrial Average ETF Trust||Jill Stoller|
|32||General Electric RSP U.S. Equity Fund||Jill Stoller|
|33||General Electric ESP Income Fund||Jill Stoller|
|34||WindWise Seeding Fund SPC, Ltd||Jill Stoller|
|35||International Private Equity Fund, L.P.||Jill Stoller|
|36||International Private Equity Fund II, L.P.||Jill Stoller|
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