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Our Commitment to You
VanEck is strongly committed to safeguarding the privacy and confidentiality of the Personal Data you have entrusted to us. This Online and Customer Privacy Notice applies to the operations of Van Eck Associates Corporation, its subsidiaries and funds sponsored or managed by VanEck (together “VanEck”, “we” or “us”). It covers VanEck's processing of Personal Data relating to visitors of our website, our customers, shareholders, suppliers and other individuals, who are not our employees. The processing of Personal Data relating to visitors of the website of VanEck Asset Management B.V., a subsidiary of Van Eck Associates Corporation, is governed by a separate policy that can be accessed via https://vanecketfs.nl/privacy.
Our websites may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your Personal Information. Please check these policies before you submit any Personal Data to such third party websites.
We have strict policies and procedures governing how we deal with your Personal Data. Each of our employees is responsible for respecting and protecting the Personal Data to which the employee has access.
Our management oversees privacy governance including policy, dispute resolution, education, communications activities and reporting to our Board of Directors on privacy matters. Please see Contact Us for more information.
2. Personal Data that we collect
We only collect the Personal Data that we determine to be required for the purposes set out in Principle 2, Identifying Purpose.
VanEck's websites are not directed at children under the age of 13, and VanEck does not knowingly collect personal data from any child under the age of 13. If we learn that we have collected or received personal data from a child under 13 without verification of parental consent, we will delete that information. Please instruct us accordingly.
3. Purposes for which we use your Personal Data
When we collect your Personal Data, we may use or disclose it for the following purposes. Below each purpose we note the "legal ground" that allows such use of your Personal Information. An explanation of the scope of the "legal grounds" can be found in Annex B hereto.
4. Consent and Your Choices
Most of our processing is permitted by "legal grounds" other than consent (see section 2 above). In relation to Direct Marketing, where we are required to do so, we will obtain your consent before using your Personal Data for this purpose. If you prefer not to receive our Direct Marketing communications, you can have your name deleted from our Direct Marketing and/or shared information lists. If you want to change your privacy preferences, please see Contact Us.
In relation to processing of criminal convictions data and politically exposed person data for the purposes of complying with our anti-money laundering obligations and to combat fraud we consider that our processing is permitted by the substantial public interest ground (to prevent or detect crime).
5. Sharing your Personal Data (and transfers outside your country)
6. Retention of Personal Data
Our retention periods for personal data are based on business needs and legal requirements. We retain your Personal Data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain business emails preparing a commercial transaction according to statutory retention periods or where required for the purpose under best practices applying to these business correspondence, as applicable from jurisdiction to jurisdiction. Also in other cases, we retain Personal Data to comply with regulatory requirements regarding the retention of such data. When Personal Data is no longer needed, our policy is to either irreversibly anonymize the data (and we may further retain and use the anonymized information) or securely destroy the data.
7. Accuracy and security of your Personal Data
We are committed to maintaining the accuracy of your Personal Data and ensuring that it is complete and up-to-date. If you discover inaccuracies in our records, or your Personal Data changes, please notify us immediately so that we can make the necessary changes. Failure to notify us of changes to your Personal Data may negatively impact the way we communicate or provide services to you. Where appropriate, we will advise others of any material amendments to your Personal Data that we may have released to them. If we do not agree to make the amendments that you request, you may challenge our decision as described in Contact Us.
Safeguarding your Personal Information
We use physical, electronic and procedural safeguards to protect against unauthorized use, access, modification, destruction, disclosure, loss or theft of your Personal Data in our custody or control.
We have agreements and controls in place with third party service providers requiring that any information we provide to them must be safeguarded and used only for the purpose of providing the service we have requested the company to perform.
Security over the internet
No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with data protection legislative requirements.
All information you provide to us is stored on our or our subcontractors' secure servers and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of.
9. Your Rights
If you have any questions in relation to our use of your personal information, you should first contact us as per the Contact Us section below. If you reside in the EEA or your data is processed by one of our European affiliates, under certain conditions (in particular where VanEck has directed the use of your Personal Data from one of its European subsidiaries), you may have the right to require us to:
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.
If you are not satisfied with our use of your personal information or our response to any exercise of these rights you have the right to complain to the data protection regulator in the country where the VanEck entity with which you deal is established.
10. Collection of Information Using Cookies and Other Tools
VanEck or our service providers may use "cookies," web server logs, web beacons, or other electronic tools to collect information that is related to you but that does not personally identify you, such as:
A cookie is a small text file placed on your computer. Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. Likewise, most mobile devices allow you to disable the ability for geo-location information to be collected from your mobile device. The help function on most browsers and mobile devices contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or disable the collection of geo-location data. You need to set each browser, on each device you use to surf the Web. Thus, if you use multiple browsers (e.g., AOL, Safari, Internet Explorer, Firefox, etc.), you should repeat this procedure with each one. Similarly, if you connect to the Web from multiple devices (e.g., work and home), you need to set each browser on each device. However, if you disable cookies or refuse to accept a request to place a cookie, it is possible that some parts of the Sites, such as certain areas of the Sites for which you need to log in, will not function properly, and the advertising you receive when you visit the Sites may not be advertisements tailored to your interests.
VanEck does not process or respond to web browsers' “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who visit the Sites. For information about online behavioral advertising networks and how to "opt out" of advertising cookies placed by the Network Advertising Initiative's ("NAI") member networks, and thereby limit the tracking of your online activity and the targeted advertising you may receive, please click here. Note that even if you opt out of cookies placed by the NAI member networks, you may still receive online advertising. You can also prevent website tracking by changing the settings in your web browser settings as described above to disable cookies permanently or to alert you when cookies are being sent so you can refuse them at that time.
11. Contact Us
If you have any questions or concerns about our privacy practices or the privacy of your Personal Information, please let us know.
To unsubscribe from marketing material we send you, please follow the instructions at the bottom of the email you have received. Alternatively, you may:
If after contacting us you do not feel that we have adequately addressed your concerns, you may contact the data protection regulator in the country where the VanEck entity with which you deal is established.
Notwithstanding the above, nothing on VanEck's websites should be construed as a solicitation or offer or recommendation to buy or sell any security or to make any transaction.
Last Updated: August 2018
ANNEX A: Definitions
Direct Marketing is our communication with you such as mail, telemarketing or email, using your contact information, to inform you about products and services that we think may be of interest and value to you. This does not include communications regarding products or services that you currently have, including improved ways to use the products, or additional features of the products as well as transactional information.
Personal Data is information about an identifiable individual. It includes information that you have provided to us or was collected by us from other sources. It may include details such as your name and address, age and gender, personal financial records, identification numbers and personal references, to the extent permitted by local laws.
VanEck means Van Eck Associates Corporation, its subsidiaries and funds sponsored or managed by VanEck.
ANNEX B: Table of Legal Bases
Use of personal information under EU data protection laws must be justified under one of a number of legal "grounds" and we are required to set out the grounds in respect of each use in this policy. An explanation of the scope of the grounds available is set out below. We note the grounds we use to justify each use of your information next to the use in the "Uses of your personal information" section of this policy.
These are the principal legal grounds that justify our use of your information:
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