PRIVACY POLICY

This Privacy Policy covers the information practices of the Global Investment Manager Database™ (hereinafter referred to as ”the Site”). The data controller of this Site is Mercer Investment Consulting LLC., whose registered number is 140786 and whose registered office is C T Corporation System, 306 W Main St, Suite 512, Frankfort, KY 40601 (“Mercer”).

Mercer believes strongly in protecting your privacy and the confidentiality of your personal information. We acknowledge that you may have privacy and security concerns with respect to the information we collect, use, and disclose to third parties for the purpose of allowing us to offer and provide our products and services to you. In order to comply with privacy legislation, we have developed this Privacy Policy. Any combination of information, in the possession of or likely to come into the possession of Mercer, that can be used to identify, contact, or locate a discrete individual (“Personal Information”) and will be treated in accordance with this Privacy Policy. This includes any expression of opinion about such individual. Any information which cannot be used to identify a discrete individual (such as aggregated statistical information) is not Personal Information.

Please note that while the majority of information on the Site is not personal in nature, some of the sections contain information about individuals that can be classified as Personal Information.

PURPOSE FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

Mercer collects, uses and discloses your Personal Information (including individuals associated with you, all of whom are referred to as “you” in this Privacy Policy) in its normal course of business for the following purposes:

• Establishing and maintaining communications with you;
• Where you have requested a service from Mercer, assisting you in the completion of your application, the assessment of your eligibility for any such requested service, the processing and maintenance of the service, as well as any applicable renewal of such service;
• Responding to your inquiries about applications, accounts and other services;
• Making proposals for future service needs;
• Allowing our affiliated companies to notify you of certain products or services offered by our affiliated companies;
• Processing transactions through service providers;
• Sharing with financial institutions where we have joint marketing agreements;
• Meeting legal, security, processing and regulatory requirements;
• Protecting against fraud, suspicious or other illegal activities; and
• Compiling statistics for analysis of our sites and our business.

WHAT INFORMATION WE COLLECT

The information gathered by Mercer from this Site falls into two categories: (1) information voluntarily supplied by visitors to this Site and (2) tracking information gathered as visitors navigate through this Site.

Information voluntarily provided by you

When using this Site, you may choose to provide us with information to help us serve your needs. The Personal Information that we collect will depend on how you choose to use this Site.

• Where you request information
  
  If you request further information from us, we require you to submit your name, e-mail address, the name of your organization, and the country in which you are based so we may send you the material you have requested, and to enable us to identify if you are an existing client of Mercer.
  
  
• Where you register with us
  
  If you register with the Site, we may ask you for your name, e-mail address, country, telephone number as well as information about your position and organization and such other information as is reasonably necessary. Any Personal Information that you send us will be used for the purpose indicated on the Site or in this Privacy Policy.
  
  
• Where you submit content as an Investment Manager
  
  We may collect and store information, personal or otherwise, that an investment manager voluntarily supplies to Mercer either on the Site, via e-mail, or in any other way. Some examples of this type of information include information about staff such as their names, telephone numbers, e-mail addresses, qualifications, responsibilities and prior experience. The Site may also contain information about an investment manager that has been obtained from third parties or other sources, and may combine that with information that was directly entered into the Site by the investment manager. The vast majority of the information on the Site is entered by each investment manager, who is then able to review, correct and delete any Personal Information that is held within the Site relating to that manager.
  
  
• Information Provided by an Organization on an Individual’s Behalf
  
  The Site collects Personal Information that may relate to an individual who was not the individual who entered the information. Organizations entering Personal Information into the Site are responsible for ensuring that the consent of the appropriate individual(s) is obtained, and that any other requirements of local data protection and privacy laws are observed.
  
  

Website Navigational Information

As you navigate the Site, we may also collect information through the use of commonly-used information-gathering tools, such as cookies and web beacons (collectively “Website Navigational Information”). Website Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Site (such as the web pages viewed and the links clicked).

• Cookies
  
  Like many companies, we may use cookies on this Site. Cookies are pieces of information shared between your web browser and a website. Use of cookies enables a faster and easier experience for the user. A cookie cannot read data off your computer's hard drive.
  
  There are different kinds of cookies with different functions:
  
  
  1. Session cookies: these are only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page. They do not collect any information from your computer.
     
     
  2. Persistent cookies: a persistent cookie is one stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.
     
     
  3. First-party cookies: the function of this type of cookie is to retain your preferences for a particular website for the entity that owns that website. They are stored and sent between Mercer’s servers and your computer’s hard drive. They are not used for anything other than for personalization as set by you. These cookies may be either Session or Persistent cookies.
     
     
  4. Third-party cookies: the function of this type of cookie is to retain your interaction with a particular website for an entity that does not own that website. They are stored and sent between the Third-party’s server and your computer’s hard drive. These cookies are usually Persistent cookies.
     
     
  Except as described in this Privacy Policy, we do not use third-party cookies on our Sites, although we do use third party provided web beacons (please see the section on Web Beacons below).
  
  The major browsers have attempted to implement the draft “Do Not Track” (“DNT”) standard of the World Wide Web Consortium (“W3C”) in their latest releases. As this standard has not been finalized, Mercer’s Sites are not compatible with DNT.
  
  For information on all of these categories of cookies, and for more information generally on cookies please refer to aboutcookies.org.
  
  We use cookies for the following purposes:
  
  Where strictly necessary
  
  These cookies are essential in order to enable you to move around the Site and use its features, such as accessing secure areas of the Site. Without these cookies, services you have asked for, such as obtaining a quote or logging into your account, cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
  
  Performance and Statistics
  
  These cookies collect information about how visitors use a Site, for instance which pages visitors go to most often, and if they get error messages from web pages. They also allow us to record and count the number of visitors to the Site, all of which enables us to see how visitors use the Site in order to improve the way that our Site works, and to provide information to current and prospective subscribers as to usage of the Site.. These cookies do not collect information that identifies a person, as all information these cookies collect is anonymous and is used to improve how our Site works.
  
  Functionality
  
  These cookies allow our Site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, a Site may be able to remember your log in details, so that you do not have to repeatedly sign in to your account when using a particular device to access our Site. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customize. They may also be used to provide services you have requested such as viewing a video or commenting on an article. The information these cookies collect is usually anonymized. They do not gather any information about you that could be used for advertising or remember where you have been on the internet.
  
  Please consult your web browser's ‘Help’ documentation or visit aboutcookies.org for more information about how to turn cookies on and off for your browser.
  
  
• Web Beacons
  
  The Site may also use web beacons (including web beacons supplied or provided by third parties) alone or in conjunction with cookies to compile information about users’ usage of the Site and interaction with e-mails from Mercer. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Site tied to the web beacon, and a description of a Site tied to the web beacon. We use web beacons to operate and improve the Sites and e-mail communications. We may use information from web beacons in combination with other data we have about our clients to provide you with information about Mercer and our services. We will conduct this review on an anonymous basis.
  
  
• IP Addresses
  
  When you visit the Site, Mercer collects your Internet Protocol (“IP”) addresses to track and aggregate non-Personal Information. For example, Mercer uses IP addresses to monitor the regions from which users navigate the Site. IP addresses will be stored in such a way so that you cannot be identified from the IP address.

DISCLOSURE OF INFORMATION TO OTHERS

The information that is entered into the Site is used by Mercer staff in our offices around the world for the purposes of researching investment managers and as a source of comparative data for manager search or selection exercises for our clients. It is Mercer’s policy not to disclose any non-public Personal Information to non-affiliated third parties except to clients and other organizations as part of the normal course of Mercer’s business of consulting to institutional investors or as otherwise permitted by law. Any contract requirements that are more restrictive than our policy are overriding.

Within Mercer, access to non-public Personal Information in the Site is restricted to those employees who have a need to know that information in connection with providing consulting services to institutional investors or for marketing purposes

Mercer may also disclose Personal Information to certain third party entities responsible for the hosting of this Site or other sites incorporating the Personal Information supplied by you. We do not disclose any Personal Information about you to any third parties except as stated in this Privacy Policy, as otherwise permitted by law, or authorized by you.

Third parties to whom we disclose information are required by law and contractual undertakings to keep your Personal Information confidential and secure, and to use and disclose it for limited purposes, in compliance with all applicable legislation.

Affiliate Sharing

In the normal course of performing services for our clients, Personal Information may be shared within Mercer and its affiliates which includes Marsh & McLennan Companies and its subsidiaries, for research and statistical purposes, system administration and crime prevention or detection. Information that you want to submit through the Site may be collected, stored, and processed in the United States or in other countries. We may transfer your information internationally to Mercer and its affiliates’ offices or third party service providers. Such transfers and other processing of the information will be in accordance with this Privacy Policy.

Service Providers

Because a number of the service providers we use are located in the United States, including certain Mercer affiliates, your Personal Information may be processed and stored inside the United States, and the U.S. government, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your Personal Information under US laws.

Mercer's web hosting suppliers comply with the US-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union. Where some other service provider is not Safe Harbor self-certified, we shall ensure that your Personal Information is adequately protected using other measures.

Business Transactions

As we continue to develop our business, we might sell or buy assets. In such transactions, user information, including Personal Information, generally is one of the transferred business assets. Also, if either Mercer itself or substantially all of Mercer’s assets were acquired, your Personal Information may be one of the transferred assets. Therefore, we may disclose and/or transfer your Personal Information to a third party purchaser in these circumstances

Other Legally Required Disclosures

Mercer preserves the right to disclose without your prior permission any Personal Information about you or your use of this Site if Mercer has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of Mercer, employees, other users of this Site, or the public; (b) enforce the terms and conditions that apply to use of this Site; (c) as required by a legally valid request from a competent governmental authority; or (d) respond to claims that any content violates the rights of third-parties. We may also disclose Personal Information as we deem necessary to satisfy any applicable law, regulation, legal process or governmental request

In this Privacy Policy, the purposes identified above and in “Collection, Use and Disclosure of Personal Information” will be referred to as the “Identified Purposes.”

CALIFORNIA’S “SHINE THE LIGHT” LAW

California Civil Code Section 1798.83 requires any operator of a website to permit its California-resident customers to request and obtain from the operator a list of what personal information the operator disclosed to third parties for direct marketing purposes, for the preceding calendar year; and the addresses and names of such third parties. Mercer does not share any personal information collected from this site with third parties for their direct marketing purposes.

CONSENT

Your knowledge of and consent to Mercer’s collection, use and disclosure of your Personal Information is essential. We rely on the following actions by you as indications of your consent to our existing and future Personal Information practices:

• Your voluntary provision of Personal Information to us directly or through your employer for the purpose of accessing the site or related service or product (including information previously provided to Mercer);
  
  
• Your express consent or acknowledgement contained within a written, verbal or electronic application; and
  
  
• Your verbal consent solicited by Mercer (or our agent) for a specified purpose.
  
  

Where Mercer relies on consent for the fair and lawful processing of Personal Information, the opportunity to consent will be provided when the Personal Information in question is collected.

Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw this consent at any time. Refusing to provide certain Personal Information or withdrawing consent for Mercer to collect, use or disclose your Personal Information could mean that we cannot provide access to the Site, or other requested services or information for you.

If you wish to withdraw your consent please refer to the Questions or to Withdraw Consent section below.

However, there are a number of instances where Mercer does not require your consent to engage in the processing or disclosure of Personal Information. Mercer may not solicit your consent for the processing or transfer of Personal information for those purposes which have a statutory basis, such as:

• The transfer or processing is necessary for the performance of a contract between you and Mercer (or one of its affiliates);
  
  
• The transfer or processing is necessary for the performance of a contract, concluded in your interest, between Mercer (or one of its affiliates) and a third party;
  
  
• The transfer or processing is necessary, or legally required, on important public interest grounds, for the establishment, exercise, or defense of legal claims, or to protect your vital interests; or
  
  
• The transfer or processing is required by applicable law.
  
  

LIMITING COLLECTION AND RETENTION OF PERSONAL INFORMATION

Mercer will collect, use, or disclose Personal Information that is necessary for the Identified Purposes or as permitted by law. If we require Personal Information for any other purpose, you will be notified of the new purpose, and subject to your consent (where appropriate), that new purpose will become an Identified Purpose.

Mercer will collect Personal Information by fair and lawful means. We will normally retain Personal Information as long as necessary for the fulfillment of the Identified Purposes. However, some Personal Information may be retained for longer periods as required by law, contract, or auditing requirements.

SAFEGUARDS

We have in place physical, electronic and procedural safeguards appropriate to the sensitivity of the information we maintain regarding Clients and Participants. Safeguards will vary depending on the sensitivity, format, location, amount, distribution and storage of the Personal Information. They include physical, technical, and managerial measures to keep Personal Information protected from unauthorized access. Among such safeguards are the encryption of communications via SSL, encryption of information while it is in storage, firewalls, access controls, separation of duties, and similar security protocols. However, due to the nature of the Internet and related technology, we cannot absolutely guarantee the security of Personal Information, and Mercer expressly disclaims any such obligation. Furthermore, the security of your data or any Personal Information on the Site is dependent on the security of your transmission as well as your procedures in safeguarding access to your data, log-ins, and passwords.

EXTERNAL LINKS

Mercer websites may include links to other websites whose privacy policies we do not control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your web browser), use of any Personal Information you provide is governed by the privacy policy of the operator of the website you are visiting. That policy may differ from ours. If you can't find the privacy policy of any of these websites via a link from the website's homepage, you should contact the website directly for more information.

ACCURACY, ACCOUNTABILITY, OPENNESS AND CUSTOMER ACCESS

Our knowing about changes to some of your Personal Information (e.g. email address) may be key to effectively communicating with you at your request. If any of your details change you can update us by e-mailing us by visiting the Contact Us page on the GIMD homepage. Please keep us informed of changes to your Personal Information.

You have the right to access your Personal Information and request rectification of any Personal Information in the file that may be obsolete, incomplete or incorrect.

If you have any questions about this Privacy Policy or want to access your Personal Information, you can obtain so by visiting the Site www.mercergimd.com or writing to:

Software Contract Administration
Mercer
155 North Wacker Drive
Suite 1500
Chicago
Illinois 60606, USA.

Your Personal Information will be stored and can also be accessed at the Mercer office with which you do business. For a complete list of our offices, click here.

A copy of this Privacy Policy (and any significant changes) can be obtained from our Web site at www.mercergimd.com. Mercer is responsible for all Personal Information under its control and has designated a privacy officer who is accountable to Management for Mercer’s compliance with this Privacy Policy.

QUESTIONS OR TO WITHDRAW CONSENT

You may exercise your right to withdraw your consent to applicable uses or disclosures of your Personal Information (which may limit or terminate the products and services that Mercer provides to you) by writing or sending an email to us at the above address. We will need to validate the identity of anyone making such a request to ensure that we do not provide your information to anyone who does not have the right to such information.

Normally we will respond to access requests within 30 days.

COMPLAINTS

If you have any queries relating to this Privacy Policy, or if you have a problem or complaint, please contact us by selecting the Contact Us option from the Site’s home page.

CHANGES TO THIS PRIVACY POLICY

If there is any material change to your rights under this Privacy Policy, Mercer will provide you with notice of such change 30 days prior to the changes going into effect. As part of this notice, Mercer may post a notice of the change on the site in a clear and conspicuous manner for the 30 day notice period. Mercer may also communicate the change via email or postal mail if this is the way that Mercer normally corresponds with you. Please note that your continued use of the Site or Services once this 30 day period is over indicates your agreement to the changes which were the subject of the notice.