Effective Date: July 25, 2018
This Policy describes how we collect, use, and disclose the information that we collect on the Instinet Website and through the emails that link to this Policy (the "Sites"). By visiting or using the Sites, you are agreeing to the terms of this Policy.
This Policy does not apply to information that Instinet, non-US Instinet companies, or Instinet's affiliated companies collect through means other than the Sites.
What Information We Collect
We collect both Personal Information and Other Information in connection with the Sites, as described below. For purposes of this Policy, "Personal Information" is information we can directly associate with a specific person without additional information, such as a full name, email address, or phone number. "Other Information" is any other information relating to a person that is not Personal Information. We may combine Personal Information with Other Information, in which case we will treat the combined information as Personal Information.
We also may combine Personal Information or Other Information that we have about you with additional information that we or third parties collect in other contexts—such as our communications with you via email or phone, your customer records, information you provide to us other than through the Sites, or information about you derived from industry publications or your company's website. In those circumstances, we will treat the combined information in accordance with this Policy.
Personal Information. We may collect various types of Personal Information from or about visitors to the Sites, including:
- your name;
- your job title and organization;
- your status with Instinet (e.g., customer, prospective customer, etc.);
- your contact information, including mailing address, email address, or phone number;
- your state, region, or country;
- any other information associated with your Instinet account that you provide to us or update through the Sites, including your username and password;
- the Instinet services you use or information you request;
- your preferences about participating in our events, including information about attendance and meal preferences;
- your preferences for how we communicate with you; and
- any other information you choose to provide.
We collect this information through forms that you may fill out on our Sites, including when you communicate with us through the "Request for Information" form on the Website, sign up for news release subscription services, request product demos, or request to attend an Instinet hosted or sponsored event.
Other Information collected automatically through the Sites. We also collect Other Information automatically through the Sites. This may include information such as your IP address and domain name, your Internet service provider, the date and time of your visit, your use of the Sites during your current session and over time (including the pages you view and the files you download), the URLs from the websites you visit before navigating to the Sites, your computer's operating system and browser type, your software and hardware attributes, and your general geographic location (e.g., your city, state, or metropolitan region). We may also collect information about how you interact with communications from us, like emails, including whether you opened the communication or clicked on any content. We collect such information using various technologies, including:
- Server Logs. When you use the Sites, we automatically receive and record certain information from your computer (or device) and browser. To obtain such information, we may use server logs or applications that recognize your computer or device and gather information about its online activity.
- recognize your device so you do not need to give the same information several times during one visit;
- recognize that you may already have given a username and password so you do not need to enter your credentials for every web page requested; and
- measure how many people are using our online services, so that we can make them faster and easier to use.
- Pixel Tags. The Sites, including the emails you receive from us, may use an application known as a "pixel tag" (also called a "clear gif," "image tag," or a "web beacon"). A pixel tag is an electronic tracking mechanism that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include Personal Information. For example, pixel tags may be used by an email sender to determine whether an email recipient has opened a particular email and how much time they spent reading it.
We also may partner with certain third parties to collect, analyze, and use some of the Personal Information and Other Information described in this section. For example, we may allow our affiliate Nomura or third parties to set cookies or use web beacons or other tracking mechanisms (such as tags or scripts) on the Sites. The information collected by third parties using these technologies may be used for a variety of purposes, including analytics and targeted interest-based advertising. For more information about such activities, including how you may opt out of some processing of your data, please see the section below entitled "Third-Party Analytics and Interest-Based Advertising."
In addition, if you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Services may not operate correctly. Additional information on deleting or controlling cookies is available here.
How We Use Information
We may use Personal Information and Other Information for a variety of purposes, including:
- to respond to your questions or comments, or to provide you with requested information;
- to schedule a demo or to sign you up for events;
- to send you updates, marketing, or other communications about topics that may interest you, including about our products and services;
- to provide access to the password-protected Sites relevant to you, fulfill the terms of any agreement you have with us, or otherwise complete a transaction you initiate;
- to engage in analysis and research about the Sites, our products and services, and our communications (including emails) with you, including merging Personal and Other Information with information we may already have or may collect about you;
- to provide targeted or customized advertising or messaging to you, including as described in the "Third-Party Analytics and Interest-Based Advertising" section below;
- to support and improve our existing products and services or create new products and services;
- to count and recognize visitors to the Sites and analyze how visitors use the Sites;
- to compile and share aggregated information; and
- for any of the "Legal Purposes" described below in the section entitled "How We Share Information with Third Parties."
How We Share Information with Third Parties
We may share Personal Information and Other Information with third parties for a variety of purposes, as described below.
Affiliates. We may share Personal Information and Other Information with our corporate affiliates for any of the purposes described in this Policy.
Third-party service providers. We use third-party service providers to help us manage and improve the Sites, including our email communications. These service providers may collect and/or use your Personal Information or Other Information to assist us in achieving the purposes discussed in this Policy. We may also allow third-party service providers to create aggregated, statistical data based on their work for us and use and disclose that data for their own business purposes. For example, we may use a vendor to manage our emails and other communications, and that vendor may generate aggregated and statistical reports for use in its own business. We also partner with certain third parties to collect, analyze, and use some information as described below in the section entitled "Third-Party Analytics and Interest Based Advertising."
Business partners. We also may share your Personal Information or Other Information with our business partners to fulfill your requests for services or meet the terms of any agreement that you have with us or our business partners.
Legal purposes. We also may use or share your Personal Information or Other Information with third parties when we believe, in our sole discretion, that doing so is necessary:
- to comply with applicable law or a court order, subpoena, request from government or law enforcement, or other legal process;
- to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
- to establish, protect, or exercise our legal rights or defend against legal claims; and
- to facilitate the financing, securitization, insuring, merger, acquisition, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.
De-identified or aggregated information. We may share, or allow third parties to create and share, de-identified and/or aggregated information for any lawful purpose, including to provide reports on trends in usage of our Sites or communications.
Third Party Analytics and Interest-Based Advertising
We work with certain third parties to collect Other Information and to engage in analytics, auditing, research, and reporting. These third parties may use tracking mechanisms such as web logs and pixel tags, and they may set and access cookies on your computer or device in order to collect information about your online activities across different websites or services over time, including on websites and mobile applications that are not owned or operated by Instinet. The information collected by third parties using these technologies may be used to engage in analysis, auditing, advertising, research, and reporting.
We also partner with third parties to provide targeted advertising services that are customized based on your online activities over time and across unaffiliated websites ("Interest-Based Advertising").
You may opt out of the use of your data for interest-based advertising purposes by members of the Network Advertising Initiative ("NAI") by opting out here, or by companies participating in the Digital Advertising Alliance's ("DAA") WebChoices tool by opting out here. To help preserve the choices that you make in the DAA's WebChoice page, you can install the DAA's "Protect My Choices" extension that is available here. Please note that the opt-out will apply only to the specific browser or device from which you opt out, and therefore you will need to opt out separately on all of your browsers and devices. If you delete or reset your cookies, change browsers, or use a different device, any opt-out cookie or tool may no longer work and you will have to opt out again.
The use of online tracking mechanisms by third parties is subject to those third parties' own privacy policies. Some browsers have a "do not track" feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser "do not track" signals, but you may opt out of interest-based advertising of companies within the NAI and for companies participating in the DAA by visiting the opt-out pages described above.
Links to Third-Party Websites
Security and Retention
Instinet has implemented administrative, technical, and physical safeguards for our Sites to protect your information against loss or unauthorized access, use, disclosure, alteration, or destruction. However, no website is 100% secure, and we cannot absolutely guarantee the security of your information.
We retain your Personal Information and Other Information for as long as reasonably necessary to accomplish the purposes in this Policy or as required by law.
Your Choices and Access to Information
If you would like to learn more about the Personal Information that Instinet has about you, or you would like to update or change that information, please contact us at the email or physical address in the "Questions or Comments" section below.
If you no longer want to receive communications from us, please email us at email@example.com with your request. If you unsubscribe from these communications, but are an Instinet customer, you may still receive non-marketing messages from us with information, alerts, or updates about the products or services you use.
Transfer of Information to the United States
The Personal Information and Other Information that we collect through or in connection with the Sites may be transferred to and processed in countries other than your country of residence, including the United States, the UK, and Japan, for the purposes described above. Instinet may subcontract the processing of your data to, or otherwise share your data with, affiliates and third parties in the United States or other countries. The data protection laws in these countries may be different from, and less stringent than, those in your country of residence. By accepting this Policy, using the Sites, or providing information to us, you expressly consent to such transfer and processing.
The Sites are not directed to children under the age of 13, and Instinet does not knowingly collect Personal Information or Other Information through the Sites from anyone it knows is under the age of 13.
Your California Privacy Rights
California law gives residents of California the right, under certain circumstances, to request information from us regarding the manner in which we share certain categories of personal information with third parties for their direct marketing purposes. To request such information, please contact us at the information provided below.
Changes to this Policy
Questions or Comments
If you have any questions or comments regarding our privacy practices or this Policy, please contact us by email at firstname.lastname@example.org or by mail at: c/o Legal and Compliance Department, Instinet, LLC, 309 West 49th Street, New York, NY 10019