We are pleased that you have elected to visit our website (the “Website”). Intelligent Research Group (“Company,” “we,” “us” or “IRG”) and its Affiliates and Brands respect your privacy and are committed to safeguarding your Personal Information (defined below). The website name itself (i.e. “Portfolio Management Research”) is a brand label of IRG. “Affiliates” are companies that are controlled or owned by us, or companies that control us, or are under common control with us, or manage us or our brand label.

The Company has implemented this Privacy Policy to govern the use of Personal Information that is provided to, collected by, or shared through the Website, including any Personal Information you send to us. This Privacy Policy does not govern Personal Information collected in the course of conducting research, surveys, interviews, or lead generation by or on behalf of the Company, its clients, partners, Affiliates, or connected companies, (collectively, “Research”). The Research Terms and Conditions (“Research Terms”) include additional privacy information that governs the use of Personal Information collected through or in conjunction with Research. In the event of a conflict between the terms of this Privacy Policy and the privacy terms in the Research Terms, the privacy terms in the Research Terms shall take precedence, but only as applied to the processing of Personal Information related to the specific Research activities giving rise to the conflict.

We may modify or update this Privacy Policy may be from time to time without prior notice so please review it periodically. We will provide you with notice as required by applicable law if material changes are made. Unless indicated otherwise, such changes are effective immediately upon publication of the revised Privacy Policy. You can tell when the Privacy Policy was last modified by checking the “updated” date.

We may collect a range of Personal Information through our Website. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you.

The types of Personal Information we collect may include:

• Contact Information – If you submit an inquiry, register for an account, request a free demo, or provide information on our Website we may collect your contact information. This may include your name, address, email address, demographic information, and phone / mobile number or social media profile information (e.g., LinkedIn profile).
• Usage Information – When you use our Website, our servers may automatically record information, including your Internet Protocol address (IP Address), geolocation of your device, browser type, referring URLs (e.g., the site you visited before coming to our Website), domain names associated with your internet service provider, or other information regarding your interaction with the Website.
• Communication Information – We may collect the contents of your communications with us, whether via e-mail, social media, telephone or otherwise, and inferences we may make from other Personal Information we collect. Where permitted by applicable law, we may collect and maintain records of calls and chats with our agents, representatives, or employees via message, chat, post, or similar functionality,

• Directly From You – For example, if you voluntarily choose to contact us, create an account, request information from us, link or login with your social media accounts, or complete one of our Surveys.
• From Third Parties – For example, we may work with business partners, subcontractors, advertising networks, analytics providers, and search information providers, who may provide us with Personal Information about you.
• Online Tracking Technologies – We may use cookies and similar technologies such as pixels, web beacons, and local storage to collect Personal Information related to online activities. For additional information regarding our use of these technologies, see the Cookies and Device Identification Data section below.

To the extent permitted by applicable law, we may use your Personal Information to:

• provide you with materials, information, and services such as our Website to you;
• respond to your inquiries or otherwise contact you in connection with our provision of services;
• inform you of future research opportunities that you may be eligible to participate in;
• provide notice of and/or resolve any problems that may arise in connection with our services;
• better understand the needs and interests of our customers;
• analyze the success of our products, services, and Website;
• operate and manage the Website’s functionality;
• improve, enhance, and personalize the Website experience and customize the content on our Website,
• protect or enforce our legal rights;
• comply with any legal and/or regulatory obligations;
• fulfill customer or respondent requests or provide support and maintain the Website;
• to protect the security and integrity of the Website and investigate potentially unlawful activity;
• develop new services and research opportunities;
• communicate with you about Company-related and/or industry-related events, or opportunities that may be of interest to you;
• meet our contractual requirements; and
• the extent necessary for any other lawful purpose for which your Personal Information may be processed.

• Affiliates. We may share your Personal Information with our affiliates, which are companies controlled or owned by us, or companies that control us, or are under common control with us, or that manage our brand label (“Affiliates”), but your Personal Information will not be shared by us or our Affiliates with third parties without your express consent.
• Business Clients. We will not share or disclose your Personal Information to our or our Affiliates’ clients, for whom we conduct research, except in anonymized form, without your prior express consent.
• Service Providers. From time to time, we may hire third parties to assist us with certain functions and services, such as data processing, hosting surveys, computer software and website maintenance and development, transaction processing, promotional and marketing services, customer service, professional, legal or accounting services and/or business and sales analysis (“Service Providers”). The Company may share your Personal Information, without restriction and consistent with applicable law, with our Service Providers. In such situations, the Company requires that Service Providers agree to maintain the confidentiality of your Personal Information and to comply with the safeguards described in this Privacy Policy. Our Service Providers only have access to the Personal Information needed to perform their functions and are prohibited from sharing or using such information for any other purposes. Furthermore, in compliance with privacy laws, we also provide our opt-out lists to non-affiliated third-party companies so that communications sent by those companies on our behalf do not get sent to addresses appearing on our opt-out lists.
• Disclosure for Marketing Purposes. The Company does not sell or share users’ Personal Information, including but not limited to e-mail addresses, with third parties for marketing or for their own proprietary purposes (including our clients) unless the Company first obtains your express consent. We may disclose aggregated statistics about visitors to the Website, along with anonymous information concerning individual users of the Website.
• If the Company changes ownership. We may also share your Personal Information as required to allow for a change in ownership of the Company, any of our Affiliates, and/or of any business(es) to which the Website relates, and the related transfer of user information to the new owner. In the event of any such change of ownership, your Personal Information will continue to be protected by the terms of this Privacy Policy unless and until you are notified of a change. Where legally required, we will give you prior notice prior to such a transfer.
• Lawful Access, Legal Action and Investigations. Your Personal Information may be disclosed to non-affiliated third parties as either required by, or to comply with, applicable laws and regulations. We may disclose Personal Information if we believe it is necessary to investigate, prevent, or take action regarding suspected illegal activities or fraud, situations involving the physical safety of any person, violations of our Privacy Policy, or otherwise in accordance with applicable law. For example, we may disclose your Personal Information to comply with investigations by regulatory authorities or enforcement agencies in the United States of America or elsewhere, or to protect against or prevent actual or potential fraud. Furthermore, we may disclose your Personal Information if it has a reasonable good faith basis to believe that it is required to do so by law, compelled by court order or legal process, or is reasonably necessary and/or appropriate to: (i) protect the rights, property and/or safety of the Company or any other person or entity; or (ii) prevent or take action concerning any alleged: (a) illegal activity or (b) breach of this Privacy Policy.

When you access the Website, we may automatically receive some information about your use of the Website. The type of information that may be automatically collected by us includes such things as the date and time of access of the Website, the Internet protocol (IP) address of the computer that you are using, the domain and host from which you access the Internet, your browser software and operating system, the referring website address, and the specific activities you are engaged in while visiting the Website.

The Website may make use of “cookies” - small data files which we may send to your computer on the basis of the information that we have collected about your visit. They contain information allowing us to recognize when you are visiting the Website and to keep track of your preferences. The Website may also use “web beacons”: small strings of code that provide a graphic image that surveys visitors’ internet activity. Using cookies and web beacons, we also may automatically collect information about your online activity on our Website, such as the web pages you visit, the links you click, and the searches you conduct on our site. Cookies are stored in your computer’s browser or on your hard disk and can then be retrieved by the website.

We may also use third-party advertising companies to target and show you advertisements when you visit the Website. On occasion, the Company permits third-party advertisers and ad networks to place their own cookies on our Website to track visitors’ activities on the Website. This enables such companies to recognize visitors so that when those visitors visit a third-party website, advertising can be delivered that is tailored to their individual interests (whether for our products or services or for the products or services of others), based on what has been learned from the visitors’ activity on our Website. This practice is called “interest-based advertising,” and the practices of these third-parties are not covered by this Privacy Policy. We encourage you to review their privacy statements for more information.

We offer you choices about the collection of information on our Website. The Company adheres to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. If you decide you do not want to receive personalized ads from third party advertisers and ad networks, please visit www.AboutAds.info/choices, where you can learn more about opting out from receiving interest-based advertising from third-party advertisers and ad networks.

The Website may also use analytics tools such as Google Analytics, a web analytics tool that helps website owners understand how visitors engage with their website. To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ sites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.

If you want to delete any cookies that were already sent to your computer or personal device, please refer to your web browser’s “Help” facility. In addition, most web browsers can be set to prevent you from receiving new cookies, notify you before accepting cookies or disable cookies altogether. Details about this can normally be found in the “Help” facility provided with your browser. Please note that if you disable cookies you may not be able to take advantage of some of the Website’s interactive functionality. Certain web browsers provide users with an option by which you may have your browser send a “Do Not Track” signal to the website that you are visiting, advising the recipient website that you do not want to have your online activity tracked. However, the way browsers communicate such “Do Not Track” signals is not yet uniform and accordingly, we do not take any action in response to such signals at this time. In the event a final standard is developed and accepted, we may reassess how we should respond to such signals.

We will retain your Personal Information for as long as necessary to fulfill the purposes described in the “Use of Your Personal Information” Section, or for any longer period required by law or a business need. Once it is no longer necessary to retain your Personal Information, we will destroy, erase, or anonymize your Personal Information. Once anonymized, such information cannot be used to identify you.

Depending on where you live in the United States, you may have the following rights with respect to your Personal Information:

• Access: You may have the right to know what Personal Information we have collected about you and to access such data.
• Data portability: You may have the right to receive a copy of your Personal Information in a portable and readily usable format.
• Deletion: You may have the right to delete your Personal Information that we have obtained, subject to certain exceptions.
• Correction: You may have the right to correct inaccuracies in your Personal Information.
• Opt out of certain processing: You may have the right to opt out of the processing of your information for purposes of (a) targeted advertising, (b), the sale of your Personal Information; or (c) profiling in furtherance of decisions that produce legal or similarly significant effect concerning you.

If you wish to exercise any of the privacy rights afforded to you in this Section, please see the “Exercising Your U.S. Privacy Rights” section below. Depending on where you are located, you may have a right to lodge a complaint with the appropriate regulatory agency if you believe that we have violated any of the rights concerning your Personal Information. We encourage you to reach out to us first, so we have an opportunity to address your concerns directly.

You will not be discriminated against in any way solely by virtue of your exercise of the rights listed in this Privacy Policy which means we will not deny goods or services to you, provide different prices or rates for goods or service to you, or provide a different level or quality of goods or services to you. To exercise your rights, please submit a request to us by contacting us using the the Contact Us page. For clarity, your eligibility for participation in Research will be assessed according to the Research Terms, not your decision to exercise any privacy rights you may have.

Verification: We may need to verify your identity in order to respond to a rights request. If you are an authorized agent making an opt-out request on behalf of an individual, we may also need to verify the identity and authority of that agent. If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of the individual. In general, we may ask you to provide Personal Information that we already maintain about you or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive Personal Information to verify your identity.

Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. Personal Information collected from an individual to determine whether a request is a verifiable consumer request may not be used or disclosed for any other purpose except as required by law.

We will respond to rights requests within the time required by applicable law. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Making a verifiable consumer request does not require you to create an account with us.

If we cannot verify your identity or confirm the Personal Information that relates to you, we may deny the request and inform you of the reason in writing. We may also deny certain requests, or only fulfill some in part, as permitted or required by law. For example, if you request to delete Personal Information, we may retain Personal Information that we need to retain for legal purposes.

If your request is denied, please send us an email to privacy@portfoliomanagementresearch.com with the Subject Line “Appeal” and attach the communication from Us explaining why we were unable to fulfill your request as well as your response to the reason we provided for not fulfilling your request. You may contact the appropriate data protection authority or other government agency regarding any complaints you may have with respect to the exercise of your rights.

The Company maintains reasonable standards of confidentiality and security for the Website and the Personal Information collected from the Website. Based on the risk or sensitivity of the Personal Information, we use appropriate physical, technical, and organizational safeguards to protect the security, availability, and integrity of Personal Information. However, despite these efforts, it is not possible to guarantee complete security and it is possible that someone may intercept or access communications, transmissions and/or Personal Information. You acknowledge that the security of the Personal Information you provide through the Website to us cannot be guaranteed. To the fullest extent permitted at law, the Company shall not accept responsibility for misuse or loss of, or unauthorized access to, your Personal Information.

From time to time, the Website may contain links to other websites and/or social media sites or pages, and other websites that are not controlled and/or maintained by us (collectively, “Other Websites”). Please be aware that these Other Websites may have different privacy policies which may subject you to different privacy practices. Please review the privacy policies of such Other Websites for information concerning their privacy practices. The Company is not responsible for the contents or privacy practices of any linked website or any link on a linked website.

If you sign up to receive text/SMS messages, emails, push notifications, or other electronic communications (“Electronic Communications”) from us about the Website or our services, you may opt out of receiving any future Electronic Communications from us at any time by using our “unsubscribe” link in any electronic communication you receive, by unsubscribing here, or by contacting us using the the Contact Us page. Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law.

The Company does not knowingly collect or maintain any Personal Information from children under the age of 16, and no part of any of the Website is designed with the purpose of attracting such children. If we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information. We do not sell or share the Personal Information of children under the age of 16.

The Website and our services are intended only for users in the United States and its territories and possessions, but if you access the Website or use our services from any country outside the United States, the various communications will necessarily result in the transfer of information across international boundaries, and by visiting the Website or using our services, you consent to these transfers as required or permitted by applicable law.

The purpose of this section is to provide information and additional provisions that apply regarding the Company’s processing of Personal Data of persons located in the European Union (“EU”), European Economic Area (“EEA”), and United Kingdom (“UK”) in accordance with the EU General Data Protection Regulation 2016/679 and the UK General Data Protection Regulation (collectively referred to herein as the “GDPR”), where Personal Data has the definition set forth in the GDPR. THIS SECTION ONLY APPLIES TO YOU IF YOU ARE LOCATED IN THE EU, EEA, UK, or Switzerland. In the event of a conflict between this section and the remainder of the Privacy Policy, this section shall control for those persons located in the EU, EEA, UK, or Switzerland. Terms used but not defined herein have the same meanings set forth under the GDPR.

The Company may process your Personal Data as described in the “Use of Your Personal Information” Section above because it is necessary to: (a) fulfill a contract between you and us; (b) comply with our legal obligations; and/or (c) pursue our legitimate business needs.

The Company does not process Personal Data for the purpose of marketing our own products and services without first obtaining your express, opt-in consent or having a legitimate interest for doing so. You have the right to object to the processing of Personal Data for marketing purposes at any time by contacting us at privacy@portfoliomanagementresearch.com.

“Sensitive Personal Data” is any data that reveals your racial or ethnic origin, political opinions, religious, moral or philosophical beliefs, trade union membership, political views, the processing of genetic data, biometric data for the purpose of identifying a person, and data concerning health or a person’s sex life and/or sexual orientation. We only collect and process your Sensitive Personal Data according to your express consent, which may be freely withdrawn at any time by contacting us at privacy@portfoliomanagementresearch.com. Unless we ask for your express consent, please refrain from sending us any Sensitive Personal Data.

The Company does not make any automated decisions on your behalf or about you without first obtaining your express consent. In the event we secure your consent to do so, you have the right to object to the processing of Personal Data via automated decision making at any time by contacting us at privacy@portfoliomanagementresearch.com.

Personal Data that we collect or receive may be transferred to and/or processed by third parties that are located outside of the EU, EEA, UK or Switzerland, some of which the relevant data protection authorities may not consider to have an adequate level of protection for Personal Data. The Company will only transfer data subject’s Personal Data to third parties located outside of the EU, EEA, UK, or Switzerland when it has ensured appropriate safeguards for such Personal Data through use of the standard contractual clauses or other approved methods by the EU, EEA, UK, or Switzerland.

If you are located in the European Union, European Economic Area, United Kingdom, or Switzerland, you may have the following rights with respect to your Personal Information:

• Request access to your Personal Information.
• Request correction of your Personal Information.
• Request erasure of your Personal Information. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your Personal Information.
• Request restriction of processing of your Personal Information.
• Request the transfer of your Personal Information to you or to a third party.
• Withdraw consent at any time where we are relying on consent to process your Personal Information.

To exercise your rights, please submit a request to us privacy@portfoliomanagementresearch.com. Depending on where you are located, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning your Personal Information. We encourage you to first reach out to us so we have an opportunity to address your concerns directly before you do so.

This Privacy Policy shall be governed by the laws of the State of New Jersey of the United States of America, without regard to its conflict of law provisions. Please click here to review the terms relating to Disputes and Governing Law for the Website.

If you have any questions or complaints concerning this Privacy Policy or our handling of your Personal Information you may contact us using the Contact Us page.