COOKIE POLICY FOR EUROPEAN UNION


Effective from May 25, 2018

How we use Cookies and similar technologies

BNY Mellon (“we” or “us”) use cookies, web beacons and similar technologies (“Cookies”) to store information, enhance your browsing experience and improve the functionality of our websites and web-based applications (“Websites”). The information set out in this notice is provided in addition to our privacy notice, and should be read alongside the BNY Mellon privacy notice.

What this Cookie Notice covers

This Cookie Notice sets out:
  • how you can manage Cookies;
  • what is a Cookie;
  • the Cookies used on our Websites;
  • how we use those Cookies;
  • third party sites;
  • third party advertising; and how to opt-out;

Managing Cookies

You can help control the way Cookies operate within our Websites or through your browser settings.

Managing Cookies settings from within your browser

Most browsers are initially set to accept Cookies, an option you change via your internet browser settings. It may also be possible to configure your browser settings to enable acceptance of only specific Cookies or to notify you each time a new Cookie is about to be stored on your device enabling you to decide whether to accept or reject the Cookie. You can also disable Cookies by configuring your browser setting to reject all Cookies. Please refer to the help section of your browser for instructions on how to manage your Cookies settings, or follow the links below:

Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
Mozilla Firefox: http://support.mozilla.com/en-US/kb/Cookies
Google Chrome: http://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647
Safari: http://support.apple.com/kb/PH5042
Opera: http://www.opera.com/browser/tutorials/security/privacy/
If you do not wish to accept Cookies from our Websites please either disable them or refrain from using our Websites. As noted above, if you disable Cookies, you may experience reduced functionality.

What is a Cookie?

A Cookie is a small file placed on your device when you visit certain websites. Cookies provide a way for the Websites to recognise users and keep track of the users’ preferences (such as login, language, font size and other display preference) over a period of time, so users don’t have to keep re-entering them whenever they come back to the websites. Cookies perform essential functions to improve a user’s browsing experience.

You do not need to have Cookies turned on to visit most of our Websites. However, having Cookies turned on should allow for a better, personalised experience, and is required for certain parts of the Websites’ functionality.

Who sets Cookies?

Cookies may be set by our Websites or by another site prior to or during your visit to our Websites.

These are known as ‘first party’ and ‘third party’ Cookies.

First party Cookies belong to the website domain that appears in the browser address bar.

Third party Cookies belong to website domains different from the one shown in the address bar. Some web pages can feature content from third-party domains (such as banner ads). Other sites may also set Cookies on your device during a visit to one of our Websites. These sites will be approved partners of ours listed in the below cookie list.

How long do Cookies last?

Cookies can be placed either for an individual “session” or on a “persistent” basis.

“Session” Cookies are temporary and will expire at the end of a browser session; that is, when you leave a website. Session Cookies allow a website to recognize you and carry information as you navigate between pages during a single browser session and allow you to use the website efficiently.

“Persistent Cookies” remain in the Cookie file of your browser even after you leave a website and after the browser is closed. These Cookies remain valid until their set expiry date (unless deleted by the user before the expiry date). These Cookies allow a website to collect and analyze (on an anonymous basis) traffic and use of the website, monitor the system and improve operating performance. For example, they enable a website to recognize you on your return, remember your preferences and provide tailored services to you. For more information about Cookies, how they work, why they are so useful and how to disable them, please visit www.allaboutcookies.org.

Cookies on our Websites

Below we describe the Cookies we deploy on our Websites, organised by the categories defined by the International Chamber of Commerce. This list (together with the rest of this notice) is reviewed every 3 months and is subject to change from time to time.

We will not set any cookies other than those that are Strictly Necessary without your consent. When we add new Third Party cookies we will seek your consent again, and we will always ask you to refresh your consent every 365 days.

We use Google Analytics Cookies to obtain an overall view of user habits and volumes, and to help improve the overall experience on our Websites. Google Analytics is a third-party web analysis service provided by Google Inc. (“Google”), which uses performance Cookies and targeting Cookies. The information generated by these Cookies about your use of our Websites (including your IP address) will be transmitted to and stored by Google Inc. on servers in the United States.

Google will use the information its Cookies collect for the purpose of evaluating your use of a website on behalf of the website provider, compiling reports on website activity and providing other services relating to activity and internet usage. Google will not associate your IP address with any other data held by Google. You may refuse the use of any Cookies by selecting the appropriate settings on your browser as described above, and you can prevent Google’s collection and use of data (Cookies and IP address) by downloading and installing the browser plug-in available under https://support.google.com/analytics/answer/181881?hl=en. This creates an opt-out Cookie which prevents the further processing of your data. For more information about Google Analytics Cookies, please see Google’s help pages and privacy policy.

Third Party Sites

Our Websites may contain links to third party sites (including social media bookmarking buttons which enable you to share certain content on our Websites). Please review the Cookie and Privacy policies of these sites to understand how they may use Cookies and your information.

Third Party Advertising

We may use third party advertising companies to serve ads on our behalf across the Internet. This enables us and these third parties to target advertisements to you for products and services in which you might be interested. To measure and track the effectiveness of such ads and to personalise advertising content to you, these companies will use Cookies and other tracking technologies, e.g. by setting a Cookie on your device when you click on one of our ads or visit a webpage associated with our campaigns. These companies may also use and measure information about your visits to our Websites as part of this same process. Third-party Cookies and tracking technologies are governed by each third party’s specific privacy or Cookies policy, not our Cookie Notice.

When accessing any third-party/external sites via links provided, you will leave our Websites. These third party sites are not controlled or endorsed by BNY Mellon, and BNY Mellon is not responsible for the contents, operation or security of these sites.

Opting-out of third party advertising

You have the ability to opt out of many third-party advertisers. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Websites or other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject Cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.

COOKIE POLICY FOR ALL OTHER LOCATIONS

At Newton, we take the issue of privacy very seriously. We would like to assure visitors to our Website of the security, privacy and confidentiality that they would expect from a leading financial services institution.

Information collected

General

We do not collect any personal information from anyone who is merely visiting or browsing our Website. However, personal information may be requested from visitors who choose to respond to online surveys or to send Newton an email message.

Email and product inquiry

Visitors to our Website are invited to send email messages to Newton in order that we may respond to enquiries regarding Newton or our products or services. These contact details are available from the ‘Contact us’ page on this Website.

Use of cookies

A cookie is a small piece of information about an internet session that may be created when a visitor accesses a website. Our Website uses cookies to facilitate easier navigation within the site and provide a higher level of convenience for the visitor. Your internet browser is likely to accept cookies by default, however you can set your browser to reject cookies and delete them from your system at any time. The cookies used by Newton do not retrieve any information from the visitor’s personal computer. For more information, please read our Cookie policy.

Use of information collected

Improved customer service

Newton uses the information collected from visitors to our Website to address the specific needs of those visitors and to provide better customer service, including the supply of the latest information regarding Newton products.

Record of communications

The information collected is also used to maintain a record of communications between Newton and our Website visitors, and to comply with any applicable legal or regulatory requirements.

Access to information collected

Employees

Selected Newton employees have access to the information collected in order to respond to each visitor’s needs and provide that visitor with information regarding specific products in which they may have an interest. Newton employees are instructed to use strict standards of care when handling the personal/confidential information of Newton customers, and the handling of such information is dealt with in The Bank of New York Mellon’s Code of Conduct, which applies to its subsidiaries. Newton employees who do not conform to The Bank of New York Mellon’s confidentiality rules are subject to disciplinary sanctions.

Third parties

Newton does not transmit any personal information collected through its Website to any third-party marketers. However, Newton does offer the opportunity to its Website visitors to link to the web pages of third parties who provide products and services not supplied by Newton. Once the visitor leaves the Newton site, Newton does not receive any further information from the visitor.

Visitors

Visitors having specific questions regarding any information they have sent to Newton through our Website should send an email to  contact@newtonim.com

Information for Residents of the United States

Protection of Social Security Numbers

In this section, “We” refers to the family of companies owned by The Bank of New York Mellon Corporation.

Like all financial services companies, we collect a variety of information about individuals, including but not limited to our customers and employees. In many cases that information includes individuals’ Social Security numbers. We use records of Social Security numbers for many purposes, especially to comply with federal and state laws such as tax laws and anti-money-laundering laws.

Our policy is (i) to comply with all laws restricting the use and disclosure of Social Security numbers, (ii) to protect the confidentiality of Social Security numbers, (iii) to prohibit the unlawful disclosure of Social Security numbers, and (iv) to limit access to Social Security numbers to our employees, and in certain cases to non-affiliated parties that provide services to us, based on their responsibilities. To safeguard Social Security numbers, we maintain physical, electronic, and procedural safeguards that are designed to comply with applicable legal standards. Our employees are prohibited from disclosing Social Security numbers for unauthorised purposes.

We may share Social Security numbers among our affiliated companies or with non-affiliated parties for administrative purposes, such as to process transactions, verify identities and service accounts. We disclose Social Security numbers as required or permitted by law, such as to the Internal Revenue Service or to credit bureaus. When necessary, we disclose Social Security numbers to regulatory agencies, law enforcement agencies, courts and parties to lawsuits.

We may share Social Security numbers among our affiliated companies or with non-affiliated parties for administrative purposes, such as to process transactions, verify identities and service accounts. We disclose Social Security numbers as required or permitted by law, such as to the Internal Revenue Service or to credit bureaus. When necessary, we disclose Social Security numbers to regulatory agencies, law enforcement agencies, courts and parties to lawsuits.

We may share Social Security numbers among our affiliated companies for marketing purposes, but only in compliance with legal restrictions, including required opportunities to opt out of such sharing. We do not, without consent of the individual involved, share Social Security numbers with parties not affiliated with us to enable them to market their own products or services.