Kelly Strategic Management, LLC
PLEASE NOTE: BY ACCESSING OUR WEBSITE, SUBSCRIBING TO OUR NEWSLETTER AND/OR REQUESTING THAT WE CONTACT YOU, YOU ARE CONSENTING TO OUR COLLECTION AND PROCESSING OF YOUR PERSONAL DATA. IF YOU DO NOT CONSENT TO THESE TERMS, SIMPLY DO NOT VISIT OUR WEBSITE, SUBSCRIBE TO OUR NEWSLETTER, OR REQUEST THAT WE CONTACT YOU.
Personal Data We Collect and Process
We collect your personal data any time you visit our website, request that we contact you, sign up for our newsletter, or provide personal information to us in order to receive our services. We collect, among other things, information relating to your first and last name, your email address, your organization name, your country of residence, and your title (when appropriate). From time to time we may also collect personal data through the use of survey forms, contact forms, or when you request copies of our research documents and whitepapers or download content from our website. We collect and process your personal data in connection with your on-going relationship to Kelly ETFs such as through correspondence, telephone calls, or other forms of contact.
We also collect data we receive automatically from your web browser or mobile devices, which may include the name of the website from which you entered our website, if any, as well as the name of the website you visit when you leave our site. This information may include the internet protocol (“IP”) address of your computer or proxy server that you use to access the internet, your internet provider name, your web browser type, the make and model of your computer or mobile device, and your operating system. We may monitor your activity on our website for any lawful purpose; however, you may visit our website anonymously.
Our Reasons for Collecting Your Data
Your personal data is collected so that we may provide you with the information you request. The information and data we collect may be used, without limitation, in any one or more of the following ways: including:
- Processing of contact and newsletter subscription requests
- Improving user experiences with our website and online content
- Improving customer service and support
- Monitoring the use and visits to our website
- Conducting statistical analysis and market research
- Response to and evaluation of questions and/or complaints
- Maintaining appropriate business records
- Establishing, exercising, or defending against legal claims
- Establishing and ensuring our compliance with data protection regulations and laws
- Communicating with you through our direct marketing activities
- Improving and maintaining our website, products, and services
Your personal data – whether public or private – will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever without your consent except as stated below or unless sharing your personal data is necessary to deliver a product or service you have requested from us. We reserve the right to collect and use any non-personal data made available to us by your use of our website. We further reserve the right to aggregate such data for our internal analytics, which help us improve our website and service, and we may share – or sell – our data aggregations with and to others. At no time is your personally identifiable data included in such data aggregations.
Who May Access Your Data
From time to time, we may disclose your personal data to recipients in connection with the purposes stated above, including:
- Kelly ETFs Personnel;
- Third-Parties who we engage to provide services to us, such as information technology service providers, which may collect and process your personal data confidentially on our behalf;
- Third-Party financial institutions and licensors of our services; and/or
- Auditors, or other regulatory authorities as requested or required by law.
Cookies and Re-Targeting Tools
We collect your data in order to provide you with our services, but also to improve the service we provide. Your help in this regard is appreciated, and we continually work to protect your data privacy rights, including, among other things, the following:
Lawfulness, fairness, and transparency – we only collect and process personal data in a manner that is lawful, fair, and transparent to you.
Purpose limitation – we only collect personal data for the reasons and in the ways stated above, and we do not process personal data in any way that is incompatible or at odds with those purposes.
Minimization – we only collect personal data that is adequate, relevant and limited to what is necessary to achieve our stated purposes.
Accuracy – we attempt to keep your personal data accurate and up to date, and from time to time we may request that you confirm the accuracy of your data.
Storage Limitation – we keep your data no longer than is necessary to achieve the stated purposes and/or long enough continue providing you with the service or information you have requested from us.
Integrity and Confidentiality – we take reasonable and appropriate steps to ensure the security of your personal data and to protect against unauthorized processing or accidental loss or destruction of your data.
Accountability – we document our activities to show how we protect your data.
Portability – we respect the fact that your data is your data. If you want us transfer your personal data to you or to someone else, contact us and we will work with you to send the data where you want it in the format needed.
Right to be Forgotten – if you want us to delete some or all of your information, simply let us know and we will honor your request as quickly as possible.
Withdrawal of Consent
You may withdraw your consent at any time by simply emailing us at Invest@KellyETFs.com.
You may limit us or our affiliates from marketing their products or services to you based on the information that we collect and share with them. Your choice to limit marketing offers will apply until you tell us to change your choice. If you have already made a choice to limit marketing offers from our affiliates, you do not need to act again until you receive the renewal notice.
To limit marketing offers or our use of your personal data, contact us by sending an email to Invest@KellyETFs.com, and we will work to implement your requested limitations.
Feel free to contact us at any time for any reason using the following information: