We collect Personal Information relating to California residents in a variety of contexts. For example, we collect Personal Information relating to California residents: (i) who are prospective consumers of our services for their personal, family or household purpose with whom we do not yet have a relationship; (ii) who obtain our products and services on behalf of institutional or other commercial purposes or are individuals associated with our institutional-investor customers; (iii) who represent businesses that we interact with (e.g., our service providers, vendors, business partners, counterparties and third-party professional services providers); (iv) who visit our locations or facilities in California; and (v) who visit our websites. The specific Personal Information that we collect, use and disclose relating to a California resident will depend on our specific relationship or interaction with that individual.
In the past 12 months, we have collected the following categories of Personal Information relating to California residents:
- Identifiers, such as name, contact information, online identifiers, Social Security numbers and other government identification (ID) numbers;
- Personal Information, as defined in the California customer records law, such as name, contact information, signature, government ID numbers, insurance and financial account information, and education and employment information;
- Protected classifications under California or federal law, such as sex and marital status;
- Commercial information, such as transaction and transaction history;
- Internet or network activity information, such as browsing history and interactions with our website;
- Geolocation data, such as device location;
- Audio, electronic, visual and similar information, such as call and video recordings;
- Professional or employment-related information, such as work history and prior employer; and
- Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.
The purposes for which we use the Personal Information that we collect depend on our relationship or interaction with a specific California resident. Nonetheless, we may use Personal Information to operate, manage and maintain our business; to provide our products and services; and to accomplish our business purposes and objectives. For example, we use Personal Information to personalize, develop and market our products and services to retail and institutional investors; provide our products and services to institutional investors; conduct research and data analysis; maintain our facilities and infrastructure; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process and internal policies; maintain business records; and exercise and defend legal claims.
In the past 12 months, we have disclosed the following categories of Personal Information relating to California residents to third parties for our business purposes:
- Identifiers, such as name, contact information, online identifiers, Social Security numbers and other government ID numbers;
- Personal Information, as defined in the California customer records law, such as name, contact information, signature, government ID numbers, insurance and financial account information, and education and employment information;
- Protected classifications under California or federal law, such as sex and marital status;
- Commercial information, such as transaction and transaction history;
- Internet or network activity information, such as browsing history and interactions with our website;
- Geolocation data, such as device location;
- Audio, electronic, visual and similar information, such as call and video recordings;
- Professional or employment-related information, such as work history and prior employer; and
- Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.
In the past 12 months, however, we have not “sold” Personal Information relating to California residents within the meaning of the CCPA. For purposes of this Disclosure, “sold” means the disclosure of Personal Information for monetary or other valuable consideration.