VANECK Privacy Policy

Scope

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Last Updated: March 11, 2025

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Information We Obtain Directly from You

VanEck may obtain information from or about you through the Services, including but not limited to information you provide when you:

• visit our Site and/or submit feedback, comments, or other information through the Site;
• request, register for, subscribe to, order, or download any product, service, newsletter, or online account;
• contact VanEck with questions or requests for information;
• enter a sweepstakes, contest, or other promotion, or complete a survey or poll; or
• interact with us online or at an in-person event, such as industry events and conferences.

This information may include:

• Contact and registration information, such as name, address, phone number, email address, login credentials, or other information you provide in connection with the Services.
• Professional information, such as the name and address of the company you work for or the firm you represent, as well as your title.
• Identity verification information and other information pursuant to applicable law.
• Information you provide in connection with your use of the Services.
• Marketing and communications data, such as your marketing preferences and records of your subscriptions to our newsletters and other related offerings.
• Audio and visual recordings of calls you have with us or presentations and webinars you participate in.
• Feedback you provide to us, such as about our Sites and Services.
• Additional information that we may collect (and that you may provide voluntarily) which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information We Obtain from Third Parties

We may also collect information about you from third parties, such as publicly available sources (e.g., LinkedIn and other social media platforms), our service providers and business partners, and your financial advisors using the Services. Investment professionals may provide us information regarding their clients, investors, and similar individuals in connection with the Services. We may use the information we obtain from third party sources to supplement the information that we collect directly from you in order to derive your possible interests and to provide more relevant experiences for you and improve our Services, analytics, and advertising.

Collection of Information Using Cookies and Other Tools

VanEck, our service providers, and third-party advertising and analytics partners may use "cookies," web server logs, web beacons, or other electronic tools on our Sites to collect information such as:

• IP address;
• browser type;
• operating system;
• computer platform;
• information about your mobile device;
• inferred geo-location data (e.g., state, city, zip); and
• the state or country from which you accessed the Sites.

VanEck, our service providers, and third-party advertising and analytics partners may also use cookies, web server logs, web beacons, or other electronic tools to collect and compile statistical and other information about your use of the Sites and the services provided on the Sites, such as:

• the web pages you visit on the Sites;
• the date and time of your visit;
• the number of and which links you click within the Sites;
• the functions you use on the Sites, including any search terms you may use, event sign-ups, or purchase activity;
• the databases you view and the searches you request on the Sites;
• the data you save on, or download from, the Sites, etc.; and
• the websites you visited immediately before and after visiting the Sites.

Web beacons (also known as pixel tags) enable us and our third-party partners to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement or website brings a user to a given site. Please note that our third-party partners’ use of information collected via cookies and similar technologies is governed by those partners’ privacy policies.

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., Safari, Internet Explorer, Firefox, Chrome, 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 and its third-party advertising and analytics partners may place advertising on the Sites and perform analytics related thereto. When such advertising is placed on the Sites, VanEck, our 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 may see on the Sites or on other websites. Information about your visits to, and activity on, the Sites and other websites, an IP address, the number of times you have viewed an advertisement, and other such usage information may be 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 the Sites, and to learn which banner ads bring users to the Sites. The use and collection of your information by these third-party service providers, and by third-party advertisers and their advertising servers, is not covered by this Privacy Policy.

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.

How We Use Your Information

VanEck uses the information collected through the Services for purposes such as:

• to enhance your experience with the Sites and our Services;
• to save your preferences information;
• to provide you with the services, products, or information that you request;
• to communicate with you (e.g., about updates to your products, or services; to provide information about products or services in which you have indicated an interest);
• to combat fraud or any other criminal activity;
• to fulfill any other purpose for which you provided the information;
• to conduct research and analysis and allow us and our third-party analytics partners to analyze and understand trends and user behavior, and to improve our Services (e.g., analyze and compile statistics about your use of the Sites and other websites, and produce data analytics and reports containing only anonymous and aggregate information that we may disclose with third parties for their own use);
• to provide information, special offers, and promotions to you regarding products and services offered by us, our affiliates, or nonaffiliated third parties;
• to personalize the Services and the services of our third-party ad partners, and provide you with content of interest, including by tailoring the advertisements that are displayed to you, through the Services and elsewhere, to make them more useful and relevant to you; and
• to protect the safety of VanEck and our users, including to ensure compliance with any applicable terms of service and other policies, block suspected spammers, address abuse, and detect and prevent fraud;
• to facilitate our compliance with applicable legal requirements, including any legally-required verification and screening procedures associated with your potential or actual use of the Services;
• to exercise our rights, defend legal claims and comply with law, legal process and internal policies; and
• for other purposes with your consent or as permitted or required by law.

To assist us with the uses described in this Privacy Policy, information we have collected from or about you through the Sites or Services, including your use of the Sites, may be combined with or enhanced by other information about you that we have from other online or offline sources, including from our service providers. We use such combined information in accordance with this Privacy Policy.

Additionally, we may aggregate and/or de-identify information collected through the Services. To the extent permitted by applicable laws, we may use de-identified and/or aggregated data for any purpose, and may also disclose such data to any third parties.

How We Disclose Your Information

VanEck may disclose your information to our affiliates and subsidiaries for their own marketing and other purposes. We may disclose your information to nonaffiliated third parties, including:

• with our vendors who provide services to help us to operate our business (e.g., to deliver the information, products, or services requested by you; to perform other activities related to such information, services, and products, including billing and collection; and to provide you with special offers or promotions from VanEck);
• with our third-party advertising and analytics partners, for which we disclose certain device and browsing habits to present you with more relevant advertising about our Services as you browse the Internet;
• in connection with any proposed or actual sale or other transfer of some or all assets of VanEck, and/or any proposed or actual sale or merger of VanEck or any division of VanEck (including in the event of a reorganization, dissolution or liquidation);
• to comply with legal orders (e.g., a subpoena or court order), government or law enforcement requests, or other legal process;
• to produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings;
• if VanEck determines in its good faith judgment that such disclosure is necessary to provide its services or to protect the rights, interests, safety, or property of its business, employees, suppliers, customers, or others;
• to enforce any legal notices, terms of service, or agreements on or related to the Services;
• to enforce the terms of any other agreement with VanEck;
• to operate VanEck systems properly;
• as otherwise required or permitted by law; and/or
• any other disclosure to which you consent.

Online Analytics and Advertising

As you use our Services, we, our service providers, and third-party ad and analytics partners collect a variety of information through the use of “cookies” and similar technologies, such as web beacons/tracking pixels, to understand how you navigate through and interact with our Services, to learn what content is popular, to enhance the Services and provide you with a more relevant and personalized experience, for authentication and advertising purposes, to save your preferences, and to collect certain usage, device and location information as described above.

Online Analytics

We may use third-party web analytics services on our Services, such as those of Google. These analytics providers use the sort of technology described in the “Collection of Information Using Cookies and Other Tools” section above to help us analyze how users use the Services. The information collected by the technology will be disclosed to or collected directly by these analytics providers, who use the information to evaluate your use of the Services on our behalf. If you’d like to opt out of Google Analytics, please use the Google Analytics Opt-Out Browser Add-on located here: https://tools.google.com/dlpage/gaoptout.

Tailored Online Advertising

We work with third-party online advertising partners to deliver advertisements that are more tailored to you both on our Services and on third-party services.

To engage in these activities, our third-party advertising partners may place cookies, pixel tags and similar technologies on many online services, including ours. They use these technologies to collect information about your activities on across different online services to deliver you more relevant advertising. For example, they may use the information they collect from their cookies on our Services to identify our products and services you might be interested in and to recognize your device so they can show you relevant VanEck advertisements while you are using another online service.

We do not have access to, and this Privacy Policy does not govern, the use of cookies or other tracking technologies that may be placed on devices you use to access our Services by non-affiliated third parties. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your devices to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link or the Digital Advertising Alliance’s Consumer Opt-Out link to opt out of receiving tailored advertising from companies that participate in those programs.

As mentioned above, please note that these opt-outs apply per browser and per device, so you will have to opt out for each device—and each browser on each device—through which you access our Services.

Your Rights and Choices

Marketing Communications

You can unsubscribe or choose not to receive promotional materials from VanEck by following the specific instructions in the e-mail or other communication you receive or by e-mailing us at compliance@vaneck.com. All e-mail requests must include the following information: first name, last name, and e-mail address. Please note that it may take some time to process your request, consistent with applicable law.

Rights Regarding Your Information

Depending on your jurisdiction, you may have the right to make certain requests regarding your “personal information” or “personal data” and (as such terms are defined under applicable law, and collectively referred to herein as “personal information”). Specifically, you may have the right to ask us to:

• Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information.
• Provide you access to and/or a copy of certain personal information we hold about you.
• Correct or update personal information we hold about you.
• Delete certain personal information we have about you.
• Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.

Under applicable law, certain residents may be able to request a list of the specific third parties, other than natural persons, to which we have disclosed personal information.

You may also have the right to opt out of “sales” of your information and “sharing/use of your information for targeted advertising” as described below.

As provided in applicable law, you also have the right to not be discriminated against for exercising your rights. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request. If you would like further information regarding your legal rights or would like to exercise any of them, please email at us at compliance@vaneck.com or 800-263-2333.

Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. If we deny your request, we will provide you with information on how to appeal the decision, if applicable, in our communications with you. To exercise such an appeal right, email us at compliance@vaneck.com.

Please note: your rights and our responses will vary based on your applicable state of residency. You may be located in a jurisdiction where we are not obligated, or are unable, to fulfill a request. In such a case, your request may not be fulfilled.

Notice of Right to Opt Out of Sales of Personal Information and Processing/Sharing of Personal Information for Targeted Advertising Purposes

As explained above, we may provide information to third-party advertising providers for targeted advertising purposes or use third-party advertising analytics partners to assist us in analyzing use of our services and our user/customer base. Under applicable law, the disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information or the processing/sharing of personal information for targeted advertising purposes.

If you would like to opt out of the disclosure of your personal information through cookies and similar tools for purposes that could be considered “sales” for those third parties' own commercial purposes, or “sharing” or processing for purposes of targeted advertising, please visit the following link, which is also available in the footer of our Services: "Your Privacy Choices." Note that you will need to opt out on each device you use to access the Services.

Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit such requests on your behalf. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.

Additionally, please note that if you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.

To opt out of our disclosure of your information for these purposes other than through online tools such as cookies, you can email us at compliance@vaneck.com.

Additional Information for California Residents

If you are a California resident, the California Consumer Privacy Act ("CCPA") requires us to provide you with the following additional information about: (1) the purpose for which we use each category of "Personal Information" (as defined in the CCPA) we collect; and (2) the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) "share" personal information for "cross-context behavioral advertising," and/or (c) "sell" such personal information.

Please note, the CCPA’s scope excludes personal information covered by certain financial services-specific privacy laws, including the GLBA and California Financial Information Privacy Act (“FIPA”). Our separate Privacy Notice that is provided to investors applies to this excluded data.

Information We Collect, Use, and Disclose

We collect the following categories of personal information:

• Identifiers, such as your name and contact information, IP address, and mobile device identifiers; and
• Internet and Electronic Network Data, such as browsing history and use and interaction with our Site.

We use these categories of personal information for the following purposes: provide the Services; communicate with you; marketing and advertising; personalize the Services; improve the Services; business operations; and/or with your consent.

We disclose these categories of personal information with the following categories of third parties: business partners and vendors; affiliated entities; service providers; online advertising and analytics partners; entities for legal purposes; and/or entities for business transactions.

For more information on our practices related to collection, use, and disclosure, please review our Privacy Police above, specifically the following sections: “Information We Obtain Directly from You,” “Information We Obtain from Third Parties,” “Collection of Information Using Cookies and Other Tools,” “How We Use Your Information,” and “How We Disclose Your Information.”

In the 12 months leading up to the date of this Privacy Policy, we may have “sold” or “shared,” or “processed” for “targeted advertising” purposes, the following categories of Personal Information: device and online identifiers, and internet or other electronic network activity information.

Your Choices Regarding “Sharing” and “Selling”

You have the right to opt out of our sale/sharing of your personal information for purposes of targeted advertising and related activities through the use of cookies and pixels by clicking the “Your Privacy Choices” link in the footer of our Site. Please note that you will need to exercise your choice on each browser and each device you use to access the Services. Also, if you have certain settings selected in your browser (including pop-up blockers) you may need to re-configure those settings to adjust your settings. If you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.

To opt out of the offline disclosure of your information to third parties for these purposes, please email us at compliance@vaneck.com.

Your CCPA Rights

Please see the "Your Rights and Choices" section of our Privacy Policy above for information about the additional rights you have with respect to your personal information under California law and how to exercise them.

If we ever offer any financial incentives in exchange for your personal information, we will provide you with appropriate information about such incentives.

California’s privacy law, the California Consumer Privacy Act (“CCPA”), also allows residents of the state of California to limit the use or disclosure of their “sensitive personal information” (as defined in the CCPA) if your “sensitive personal information” is used for certain purposes. Please note that we do not use or disclose “sensitive personal information” other than for purposes for which California residents cannot exercise the right to limit under the CCPA.

Shine the Light Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we disclose certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes.

How We Protect and Retain Your Information

We maintain administrative, technical and physical safeguards designed to protect the information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

EEA Residents

Individuals that reside in the European Economic Area (the "EEA") have certain rights in relation to their data. These rights and the corresponding VanEck policies are detailed in a separate VanEck Privacy Policy for EEA residents, which can be accessed here VANECK ONLINE AND CUSTOMER PRIVACY POLICY.

Transfer of Information To Other Countries

Some of the uses and disclosures described in this Privacy Policy may involve the transfer of your information to various countries around the world that may have different levels of privacy protection than your country. When we transfer your information to other countries, we will protect that information as described in this Privacy Policy. If you are located in the European Union ("EU"), United Kingdom (“UK”), or Switzerland, we will comply with applicable legal requirements providing adequate protection for the transfer of information to recipients in countries outside of the EU, UK, or Switzerland.

Links To Third-Party Websites

The Sites may include links to third-party websites. Since we do not control third-party websites and are not responsible for any information you may provide while on such sites, we encourage you to read the privacy policies on those websites before providing any of your information on such sites.

Questions Regarding This Privacy Policy

If you have questions regarding this Privacy Policy, please contact us at compliance@vaneck.com.

Modifications To This Privacy Policy

VanEck reserves the right to change this Privacy Policy at any time by posting revisions on this web page. We will note the date of the most recent revision of this Privacy Policy at the top of the page. We will provide any additional notice of such modifications to the extent required by applicable law. By accessing the Services after we make any such modifications, you are deemed to have accepted such modifications. Please refer back to this Privacy Policy on a regular basis.