Effective Date: July, 2020
Last Reviewed: July 2023
At State Street Global Advisors (“SSGA”) we are committed to handling your personal information or personal data (“Personal Data”) responsibly and transparently. This Global Privacy Notice (“Notice”) is intended to comply with the relevant transparency requirements under the applicable privacy or data protection laws. This Notice explains how SSGA and any fund or product issued, sponsored, managed, or otherwise affiliated with SSGA (the “Funds”) (together “we”, “our”, “us”) collect, use, share or otherwise process your Personal Data in connection with your relationship with us. The Notice applies to any Personal Data we may collect from you through our websites or applications, accessed using your device (e.g., mobile, computer) or various other offline means, such as when you attend our events, or when you otherwise interact with us as described below.
If you wish to contact the State Street entity that is data controller for the service relevant to you, see How to exercise your rights or contact us.
Please note in certain jurisdictions there might be exemptions to the rights we describe below pursuant to applicable privacy laws and regulations. We may amend this Notice from time to time to keep it up to date with legal requirements and the way we operate our business. Please check these pages regularly for the latest version of this Notice.
This Notice contains the following sections:
Subject to the laws or regulations applicable to the relevant jurisdiction, we may collect the following categories of Personal Data about you or your device:
Category |
Examples |
A. Identity information |
first name, middle name, last name, alias username or similar identifier, marital status, title, date of birth, gender, state or national identification number (such as a driver license or social security number), passport number, internet protocol, signature, physical characteristics or description or other similar identifiers. Some information included in this category may overlap with other categories. |
B. Demographic information |
Age, race, color, national origin, citizenship, marital status, sex (including gender). |
C. Contact information |
Billing address, delivery address, email address or telephone numbers. |
D. Biometric information |
Identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, keystroke. |
E. Contractual information |
Information collected as part of the products and services we provide to you. |
F. Commercial information |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
G. Financial information |
Bank account and payment card details.
|
H. Internet or another similar network activity |
Browsing history, search history, information on a consumer's interaction with a website, application, advertisement, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites or applications. |
I. Sensory data |
Audio, visual, or similar information. |
J. Professional or employment-related information |
Education, current employment, employment history. |
K. Inferences drawn from other personal information |
Profile reflecting a person's household, individuals associated with your account(s), information regarding your relationship with these individuals, or information about your business relations with us. |
We collect your Personal Data in a variety of ways and from various sources. For example, we may collect your Personal Data:
The Personal Data that we collect from you may include sensitive Personal Data. We recognize that certain jurisdictions have enacted laws that require higher protection of certain sensitive Personal Data. Sensitive Personal Data includes categories of information identified by the applicable privacy laws as requiring special treatment or protection. This information may include, but is not limited to, 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 data; or sexual orientation.
We do not collect, use, share or otherwise process sensitive Personal Data or criminal records unless permitted to do so by law. For example, we may collect, use, share or otherwise process your sensitive Personal Data or criminal records to perform Know Your Customer (KYC) checks to comply with applicable Anti-Money Laundering (AML) laws.
We use Personal Data for the following purposes:
If you do not provide us with your Personal Data when requested, it may prevent us from being able to carry out the tasks listed above.
We may use your Personal Data to market to you. Specifically, we may collect, use, or otherwise process your Personal Data and share it with our affiliates and service providers to provide you with 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, via mail, email, online, telephone, in-person, or through third-party partners or vendors. If you do not wish to receive this information from us, please manage your preferences by clicking on the unsubscribe link in any of our emails, letting your relationship manager know, by clicking here or by navigating to the “contact us” section of our website. Alternatively, for SPDR email preferences specifically, they can be requested here.
We use cookies on our websites or applications. Cookies are small files stored on a computer that are designed to hold small amounts of data specific to a user and the websites or applications to help tailor that user’s experience. For more information see our Cookies Disclosure.
We may disclose the categories of your Personal Data described above to our affiliates, service providers, and other third parties for our business purposes. When we do so, we will make sure that your Personal Data is used in a manner consistent with this notice, or enter into a contract that describes the business purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract.
We may disclose your Personal Data to the following categories of third parties:
We do not sell any of your Personal Data including Personal Data of minors under the age of 16 or as defined by applicable laws or regulations.
We operate globally and we may share some of your Personal Data, with organizations (including our affiliates and our service providers) who are outside of the jurisdiction in which the Personal Data was collected. Because we are headquartered in the United States, Personal Data collected in other countries is routinely transferred to the United States for processing. That is, Personal Data collected in one jurisdiction may be transferred, stored, and processed outside the country of origin. For these transfers, we have the relevant legal safeguards in place, including (for example) by way of contractual arrangements based on sets of standard contractual clauses that have been pre-approved by the European Commission (or otherwise consistent with the requirements of the relevant jurisdiction) to ensure adequate protection, or in certain circumstances we may rely on one of the exceptions to the rules that allows us to perform these transfers. This reflects our commitment to protecting your personal data regardless of where your personal data resides. Personal Data stored or processed in a foreign jurisdiction may be accessed under a lawful order made in that jurisdiction.
We are committed to protecting the security of your Personal Data. We use reasonable technical and organization measures, in compliance with applicable law, to protect your Personal Data from unauthorized access, unlawful processing and against accidental loss, destruction or damage.
We will retain your Personal Data for as long as necessary to fulfill the purpose for which it was collected, such as providing our services, or as required by applicable laws or regulations. This period may extend beyond the termination of our relationship with you.
Depending on the jurisdiction, and subject to certain exceptions, you may have specific rights regarding your Personal Data. This section describes such rights and how you may exercise them.
If we are relying on your consent to use or share your Personal Data, you have the right to fully or partially withdraw your consent, subject to certain exceptions defined in applicable laws and regulations. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
Please click here to access the U.S. Consumer Privacy Notice.
California residents please click here for more information.
This Notice sets out how the following entities in Australia collect, hold, use, store and disclose “personal information” for the purposes of the Privacy Act 1988 (Cth):
Please contact us at privacyoffice@statestreet.com if you have any concerns about the accuracy, handling or retention of personal information.
For other details (including authorized personal information protection organization in Japan) relating to State Street entities in Japan, please click here.
The primary point of contact for all issues arising from this Notice is our Chief Privacy Officer or Data Protection Officer. If you wish to exercise your rights, or have questions or comments about this Notice or about how your Personal Data is processed, please contact our Chief Privacy Officer or Data Protection Officer by email or via our website at: