Your privacy is important to us at SEI (“SEI,” “we,” “us,” or “our”), and we are committed to safeguarding, preserving, and respecting your privacy rights. This online privacy notice (the “Notice” or “Policy”) describes how we collect, use, disclose, and secure the personal information we gather about you through our website, https://www.seic.com, or when you otherwise interact with our business (collectively, the “Services”).
For purposes of this Notice, personal information means any data that is classified as personal information, personal data, personally identifiable information, or similar terms under applicable data privacy and security laws and regulations. It does not include data excluded or exempted from those laws and regulations, such as deidentified, anonymized, or aggregated data. Nothing in this Notice will constitute an admission or evidence that any particular data privacy or information security law or regulation applies to SEI generally or in any specific context.
Please read this Notice carefully. We recommend printing and retaining a copy for your future reference. By accessing, browsing, downloading, or otherwise using the Services, you confirm that you have read, understood, and agreed with this Notice. If you do not agree to this Notice, you may not use the Services.
This Notice applies regardless of how the Services are accessed and will cover any technologies or devices by which we make the Services available to you.
We may provide you with additional privacy notices and terms where we believe it is appropriate to do so. It is important that you read this Notice together with any other privacy notice or terms we may provide on specific occasions, so that you are fully aware of how and why we are using your data. This Notice supplements these other notices and is not intended to override them.
Your use of our Services, and any dispute over privacy, is subject to this Policy and our Terms of Use incorporated by reference into this Policy.
If you have any questions or concerns about our personal information policies or practices, you can contact us via the methods described in the “Contact Us” section below.
SEI obtains personal information that is necessary to complete product and service transactions. In order to complete these transactions correctly, SEI collects various types of personal information, which may include these items.
We collect information voluntarily provided to us, such as when you complete a form or submit information to us or when a third party submits information to us on your behalf. Your personal information can also be collected indirectly from vendors, suppliers or other financial institutions to perform a service or transaction request. We also collect information automatically when you interact with our Services—for example, through our use of cookies and related tracking technologies.
We may send one or more Cookies to your computer or other device. We may also use other similar technologies such as tracking pixels, tags, or similar tools when you visit our Services.
Cookies are small files created by websites, including our Services, that reside on your computer’s hard drive and that store information about your use of a particular website. When you access our Services, we use Cookies and other tracking technologies to:
You can manage your Cookies preference as described in the “Managing Your Cookies” section below.
Some Cookies operate from the time you visit the Services until the end of that particular browsing session. These Cookies, which are called “Session Cookies,” expire and are automatically deleted when you close your Internet browser.
Some Cookies will stay on your device between browsing sessions and will not expire or automatically delete when you close your Internet browser. These Cookies are called “Persistent Cookies” and the length of time they will remain on your device will vary from Cookie to Cookie. Persistent Cookies are used for a number of purposes, such as storing your preferences so that they are available for your next visit and to keep a more accurate account of how often you visit the Services, how your use of the Services may change over time, and the effectiveness of advertising efforts.
It may be possible to block Cookies by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including Essential Cookies), you may not be able to access all or parts of the Services.
You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org.
At this time, our website does not respond differently based on a user’s Do Not Track signal.
We use personal information we collect about you or that you provide to us in the following ways:
In the course of using our Services or website, you may consent to the sharing of your personal information with various third parties. Where we rely on your consent to share your personal information, we will disclose the categories of data and third party recipients at the time of obtaining your consent either directly or through SEI’s business client.
From time to time, SEI enters into arrangements with companies whose expertise is essential for our Services to function properly. We disclose to these service providers only such personal information as is reasonably necessary to perform these functions, and any such third parties will be under an obligation to us to maintain the confidentiality of your personal information and only process it for the specific services under contract. This may include information used to provide our Services, process payments, or provide analytics and support for our systems. For more information, please see the Notice to California Residents section, below.
We may provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons, solely for the purpose of processing that information on our behalf.
SEI reserves the right to cooperate with local, provincial, state, federal and international officials in any investigation requiring either personal information or reports about lawful of unlawful user activity on this website or our systems. We also reserve the right to share your personal information to establish, exercise, or defend our legal and property rights, including providing information to others for the purposes of fraud prevention. We may also share your personal information with any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
If SEI is ordered by a legal process or government to provide data about one or more individual users, we will notify those users of our compliance with that order, to the extent permitted by law.
SEI reserves the right to share your personal information to third parties as part of any potential business or asset sale, merger, acquisition, investment, round of funding, or similar type of transaction.
In the event of bankruptcy, insolvency, or dissolution proceedings, we may share your personal information with third parties as part of the sale or reorganization process.
We respect your rights in how your personal information is used and shared. If at any time you would like to unsubscribe from receiving future emails, you can email us at dataprotectionofficer@seic.com, use the link below to manage your marketing email preferences, or follow the instructions at the bottom of each email and we will promptly remove you from all correspondence. Please note, however, that there may be some categories of email from which you cannot opt-out and we may still need to contact you regarding other matters.
California residents have are entitled to certain rights and disclosures under the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”).
We have collected the following categories (as defined by the CCPA) of Personal Information from users within the last 12 months for the purposes listed below.
| Category | Examples | Collected | Retention Period |
|---|---|---|---|
| A. Identifiers | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | Yes | SEI as a Controller: Based on legitimate interest. SEI as a Processor: Based on instructions from the Controller |
| B. Personal Information | A name, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories. | Yes | SEI as a Controller: Based on legitimate interest. SEI as a Processor: Based on instructions from the Controller |
| C. Protected Classification Characteristics Under California or Federal Law | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | Yes | SEI as a Controller: Based on legitimate interest. SEI as a Processor: Based on instructions from the Controller |
| D. Commercial Information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Yes | SEI as a Controller: Based on legitimate interest. SEI as a Processor: Based on instructions from the Controller |
| F. Internet or Other Similar Network Activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | Yes | SEI as a Controller: Based on legitimate interest. SEI as a Processor: Based on instructions from the Controller |
| G. Geolocation Data | Physical location or movements. | Yes | SEI as a Controller: Based on legitimate interest. SEI as a Processor: Based on instructions from the Controller |
| I. Professional or Employment-Related Information | Current or past job history or performance evaluations. | Yes | SEI as a Controller: Based on legitimate interest. SEI as a Processor: Based on instructions from the Controller |
| K. Inferences Drawn of the Consumer | Inferences drawn from Personal Information identified above to create a profile about a consumer reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | Yes | SEI as a Controller: Based on legitimate interest. SEI as a Processor: Based on instructions from the Controller |
| L. Sensitive Personal Information | Information revealing a government identification number; account log-in, credit, or debit card information in combination with any required security or access code, and precise geolocation information. | Yes | SEI as a Controller: Based on legitimate interest. SEI as a Processor: Based on instructions from the Controller |
We collect your personal information directly from you, from your interaction with our website or Services, and from third parties which collect the personal information directly from you. For more information, please see the “Information We Collect” section, above.
Your personal information is used for the following purposes:
In the preceding 12 months, we have disclosed the following Personal Information about California residents for business purposes:
We do not sell your personal information to third parties for money. But, the use of certain analytical and tracking tools may constitute the sale or sharing of information under the CCPA. In the preceding 12 months, we used analytical tools that appear to constitute a sale of the following categories of information:
We do not knowingly sell or share the personal information of consumers under 16 years of age.
Where we are required to collect and or process your sensitive personal information, we will provide you with clear notice of this collection and processing. Additionally, we will only use the sensitive personal information for the specific purpose for which it was collected.
We do not collect, process, or disclose sensitive personal information, as defined under the CCPA, for purposes other than those specified in Section 7027 of the CCPA regulations.
Covered Consumers have the right to know whether we are processing their personal information and to request that we disclose their personal information we collect, use, and disclose to third parties. There are two types of Rights to Know requests that you can make:
1. Right to Know (Abbreviated Request): If you make a Right to Know (Abbreviated Request), you will receive the following information about you:
2. Right to Know (Specific Pieces of Information Request): If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:
We will provide this information to you free of charge, unless we determine that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.
We will provide this information to you in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data without hindrance.
There are certain exceptions to a consumer’s Right to Know. We will state in our response if an exception applies.
Covered Consumers have the right to request that we and our service providers delete any personal information about you which we have collected from you upon receipt of a verifiable request. This right is subject to certain exceptions. We will state in our response if an exception applies.
Covered Consumers have the right to request that we correct inaccuracies in any personal information that we collect or process about them upon receipt of a verifiable request. When submitting a correction request, we request that you provide all of the information reasonably necessary to confirm the accuracy of the correction request. This right is subject to certain exceptions. We will state in our response if an exception applies.
Covered Consumers have the right to tell us not to disclose or transfer their Personal Information to a third party in exchange for something of value or for certain third party marketing purposes. This is referred to as the right to “opt out of the sale or sharing of personal information” or the “do not sell my information” right. It also allows you to opt out from our processing of your personal data for targeted advertising purposes.
We do not sell your personal information to third parties for money. However, we use certain third party analytical cookies or other technologies that may be considered “sales” or “sharing” of data under applicable laws. For more information, and to exercise your right to opt out, please complete the SEI Data Subject Access Request Form.
Please note that opt-out choices may be stored via cookies. If you clear cookies, if your browser blocks cookies, or if you view the page from a different browser or device, your opt-out choice may no longer be logged or recognized.
We will not discriminate against you for exercising any of your privacy rights.
Covered Consumers can submit an opt-out request through the mechanisms identified in the applicable section above. You may submit all other request under this section by completing the SEI Data Subject Access Request Form.
We will respond to these consumer requests, if applicable, within 30 days of receipt of the request and without undue delay. If we need to extend this period, we will notify you of the delay and explain the reasonably necessary justifications for our delay.
When we receive a request through the link described above, we must verify that the person requesting information or deletion is the Covered Consumer about whom the request relates in order to process the request. To verify a Covered Consumer’s identity, we may request up to three pieces of personal information about you when you make a request to compare against our records. We may also request that you provide a copy of a government photo ID and / or sign a declaration under the penalty of perjury from the consumer whose personal information is the subject of the request.
You will not be required to create an account with us to submit a verifiable request. However, you may be required to access an existing account to the extent accessing the account is necessary.
We will only use personal information provided in your request to verify your identity and will delete any information you provide after processing the request. We reserve the right to take additional steps as necessary to verify the identity of Covered Consumers where we have reason to believe a request is fraudulent.
California residents may choose a person or a business registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, we require that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with us. Failure to do so may result in us denying your request.
This section of our Privacy Policy is applicable to persons located in the European Union (“EU”), a European Economic Area member state (“EEA”), or the United Kingdom (“UK”), as well as to persons whose personal information is processed in or transferred from the EU, EEA, or UK. You are entitled under the EU General Data Protection Regulation and UK General Data Protection Regulation (collectively, the “GDPR”) to the information in this section of our Policy.
You are entitled by law to access, correct, amend, or delete personal information about you that we hold. A summary listing these rights appears below. Please note that these rights are not absolute and certain exemptions may apply to specific requests that you may submit to us.
To exercise these rights, please complete the SEI Data Subject Access Request Form. For your protection, we may need to verify your identity before responding to your request. In the event that we refuse a request, we will provide you a reason as to why.
You have the right to obtain from us confirmation as to whether or not we are processing personal information about you, and if so, the right to be provided with the information contained in this notice. You also have the right to ask us for copies of your personal information. When making a request, please provide an accurate description of the personal information to which you want access. Where requests are repetitive or manifestly unfounded or excessive, we may charge a reasonable fee based on administrative cost.
You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
You have the right to ask us to erase your personal information if:
However, this right is not absolute. Even if you make a request for deletion, we may need to retain certain information for legal or administrative purposes, such as record keeping, maintenance of opt-out requirements, defending or making legal claims, or detecting fraudulent activities. We will retain information in accordance with the “How Long Is Your Personal Information Kept” section below.
If you do exercise a valid right to have your personal information deleted, please keep in mind that deletion by third parties to whom the information has been provided might not be immediate and that the deleted information may persist in backup copies for a reasonable period (but will not be available to others).
You have the right to ask us to place a restriction on our use of your personal information if one of the following applies to you:
You have the right to ask that we transfer the personal information you gave us from one organization to another, or give it to you (i.e. data portability). This applies to personal information we are processing to service a contract with you and to personal information we are processing based on your consent.
If we obtain your written consent to collect and process your personal information, you can subsequently withdraw such consent as to any further processing of such information.
If you believe your rights under the GDPR have been violated, the GDPR gives you the right to file a complaint with your supervisory authority. A list of supervisory authorities is available here: EEA and EU Data Protection Authorities (DPAs); UK Information Commissioner’s Office (ICO).
To the extent that we engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or which significantly affects you, you have the right not to be subject to such decision-making.
You have the right to object to the processing of your personal information that is based on legitimate interests or your consent (rather than when the reason for using it is to perform an obligation due to you under a contract with us). If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or we can demonstrate the processing is for the establishment, exercise, or defense of legal claims. You can object to the processing of your personal information by contacting us using the information in the “Contact Us” section below.
SEI collects your personal information to provide our products and services to you; otherwise, we may not be able to process the transactions you request. We will only process your personal information when we have a lawful basis for doing so. If you are in the UK or a country in the EU or EEA, you are entitled to an explanation of the legal bases we rely on to process your personal information. The legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it, which is discussed below.
Depending on the situation, we may be the controller or the processor for personal information collected from residents of the EU, EEA, or UK. If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information for any specific processing activity, please contact us using the “Contact Us” section below.
Our Services are operated in the United States. Personal information about you provide while in the EU, an EEA member state, or the UK may be transferred to the United States. The United States does not have an adequacy decision or adequacy regulation. The GDPR permits such transfers to third countries when necessary for the performance of a contract between you and us, if we obtain your explicit consent to such transfer, or if it is in our legitimate interest to transfer the personal information. The laws in the United States may not be as protective as the GDPR or the laws of other jurisdictions where you may be located. If we transfer personal information from the EU, EEA, UK, or another country with cross-border transfer obligations, we will provide an appropriate safeguard, such as using standard contractual clauses.
To obtain a copy of the safeguard(s), please contact us using the information provided in the “Contact Us” section below.
If you are a Canadian resident, you have the right to know what personal information we have about you and to correct any inaccuracies. To exercise these rights, please contact us using the information in the “Contact Us” section below.
Your request will be investigated as soon as possible and you will be provided with a written response.
We will retain your personal information until it is no longer necessary to accomplish the purpose for which it was collected. We may retain your personal information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations; to protect you, other people, and us from fraud, abuse, and unauthorized access; as necessary to protect our legal rights; or for certain business requirements.
We will delete your personal information when it is no longer necessary for the purpose for which it was collected, or upon your request, subject to exceptions as discussed in this Policy or under applicable law, contract, or regulation.
The security of your personal information is important to us. We take various reasonable organizational, administrative, and technical measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. If required by law to do so, we will notify you and/or the relevant supervisory authority in the event of a data breach.
However, we cannot and do not guarantee complete security, as it does not exist on the Internet.
SEI’s Services may contain links to third-party websites. When we provide links, we do so only as a convenience and do not endorse any products or services and are not responsible for any content of any third-party website or any links contained within. It is important to note that this Statement only applies to SEI’s Services. We are not responsible and assume no responsibility for any personal information collected, stored, or used by any third party as a result of you visiting third-party websites. We also advise that you carefully read the privacy notice of any third-party websites you choose to visit.
Protecting the privacy of the very young is especially important. Our Services are not intended for children under 18 years of age, and we do not knowingly collect personal information from children under 18. In the event that we learn that we have collected personal information from a child under age 18 without verification or parental consent, we will immediately delete that information. If you believe that we might have any information from or about a child under 18, please contact us using the information provided in the “Contact Us” section below.
This Statement may change from time to time. We will post any changes to this Statement on this page, and you should check these terms when you use the Services. Your continued use of the website constitutes acceptance of the most current version of this Statement
To exercise your rights, please complete the SEI Data Subject Access Request Form. Once we received this form, we will respond as soon as possible.
For other inquiries, you can contact us by sending an email to DataProtectionOfficer@seic.com