Effective January 1, 2020
Your privacy is important to us. We understand and respect the privacy of the non-public personal information we receive from our clients. The purpose of this Privacy Notice is to explain the practices of Fund Evaluation Group, LLC, its affiliated entities, and our website www.feg.com (together “FEG” or “we”) with respect to the collection, use, disclosure, and safeguarding of your personal information (personal information). Instances of “you” or “your” in this policy refer to individuals whose personal information is processed by FEG, including clients with direct or indirect relationships (such as through an intermediary); potential clients; employees, officers, and agents (together “Representatives”); and beneficial owners of an organization or entity in connection with:
This Privacy Notice sets out the purposes for which we collect, use, and disclose (collectively “process”) personal information and how we protect that information. It also sets out individuals’ rights in relation to the processing of their personal information. There may be additional terms, conditions, and commitments that also govern how we collect, use, and disclose your personal information which should be read in conjunction with this privacy notice.
In order to conduct business with you, FEG sometimes needs to collect your personal, non-public information, from a variety of sources.
Personal information is any information relating to an individual which can be used either alone or with other sources of information to identify that individual. personal information does not include information where the identity of the individual or the specific detail of the information has been removed and is therefore anonymous. The nature of the information that we collect depends on the services we provide and our relationship with you. We grouped the personal information that we may possess into the following categories (note, however, that the examples provided within each category are not exhaustive):
We may collect personal information about you in a number of ways, including:
We may also create or derive personal information such as creating records of your interactions with us, subject to applicable law.
Unless indicated that the provision of specific personal information is optional, any personal information we specifically request is necessary for us to provide you or your organization or entity with the products and services requested. If you do not provide the personal information requested, we may not be able to provide those products and services.
In connection with one or more of the purposes outlined above, FEG may disclose your personal information to:
FEG’s website and/or its service providers may use a variety of technologies to collect information to help FEG and its service providers understand how the website is used. Information collected from your web browser (including small files stored on your device that are commonly referred to as “cookies”) allows the website to recognize your web browser and helps to personalize and improve your user experience and enhance navigation of the website. This information also allows FEG to recognize, measure, track, and analyze usage. You can change your cookie preferences by changing the setting on your web browser to delete or reject cookies. Note, however, that if you delete or reject cookies, some website pages may not function properly.
FEG’s website may contain links that are maintained or controlled by third parties, each of which has privacy policies which may differ (in some cases significantly) from the privacy policies described in this notice. Please read the privacy policies of such third parties and understand that accessing their website is at your own risk. This Privacy Notice is not applicable to third-party websites that we do not own or control or to any third-party websites where FEG advertisements are displayed.
California residents should be aware that this section does not apply to personal information covered by certain sector-specific privacy laws, including the Gramm-Leach-Bliley Act (GLBA) or other information subject to a California Consumer Privacy Act (CCPA) exception.
Your rights under the CCPA (only for natural persons residing in the State of California) include the right to:
You may discuss or exercise your rights by contacting us directly at 888-268-0333 (toll free) or firstname.lastname@example.org
Although you have the right to request that your personal information be deleted at any time, applicable laws or regulatory requirements may prohibit us from doing so. In addition, if you invest in an FEG fund through a financial intermediary, FEG may not have access to your personal information.
In some cases, FEG may need to request specific information from you to help us confirm your identity and ensure your right to access the personal information requested, or to exercise any of your other rights. This is to ensure that personal information is not disclosed to anyone who does not have authority to receive it. We may also require further information to help us to locate the personal information processed in relation to you, including, for example, the nature and location of your relationship with us.
FEG aims to respond to all legitimate requests within 45 calendar days. If we think it may take us longer than 45 calendar days (such as in cases where the request is particularly complex or you have made a number of requests), we will notify you and keep you updated of our progress.
California law requires that FEG describe certain disclosures of personal information where we receive valuable consideration. California law treats such disclosures as “sales,” even if no money is exchanged. We do not sell information to third parties as defined under California law.
FEG has internal procedures designed to maintain accurate records concerning your personal information. Should you ever believe that our records contain inaccurate, incomplete, or out-of-date information about you, please notify us. We will respond to requests to correct information in a timely manner.
FEG restricts access to non-public personal information to those employees who need to know that said information in order to provide our products and services to you. We maintain physical, electronic, and procedural safeguards to protect your non-public personal information.
In the event that you end your relationship with us, we will continue to adhere to the policies and practices described in this policy statement.