AND INFORMATION SECURITY POLICY
SEI Investments is
committed to protecting the confidentiality and integrity of the information to
which it has been entrusted by its clients, as well as SEI's proprietary
information, including its products, the information systems and technology
infrastructure, and the services it provides (collectively, "Information").
The Privacy and Information Security Policy ("Policy") outlines the
principles that govern all SEI business units and regulated direct or indirect
subsidiaries of SEI Investments (collectively, SEI) with respect to the
collection, sharing, and protection of Information. SEI will adopt and
implement procedures to achieve the corporate Policy goals: to obtain, maintain
and disseminate Information appropriately; to ensure the security and
confidentiality of Information; and, protect against anticipated internal or
external threats or hazards to the security or integrity of the Information.
Information takes many
forms and includes records stored on computers and magnetic or optical media,
data transmitted across networks or by fax, and information printed out or
written on paper. It can also consist of work knowledge or concepts and can be
represented in material objects. Specifically, SEI may obtain "Nonpublic
Personal Information," information about an individual obtained in
connection with providing a financial product or service to the individual for
personal, family or household purposes. Nonpublic Personal Information may
include, but is not limited to, name, address, social security number, account
number or balance, debit card usage, and insurance policy coverage and may be
provided to SEI directly by the individual or obtained from transactions with
SEI or others.
3. Use of Nonpublic Personal Information
SEI uses the Nonpublic
Personal Information it collects in a variety of ways depending on the nature
of the customer's relationship including, but not limited to, delivering
various financial services; processing, servicing and maintaining accounts and
transactions; responding to customer requests; resolving disputes; and
generally fulfilling SEIôs obligations to the customer. In addition, the
information may be used to verify a customer's identity as required by the USA
4. Disclosure of Nonpublic Personal Information
SEI does not disclose
any Nonpublic Personal Information to third parties, except as permitted or
required by law, rules or regulations. SEI may disclose Nonpublic Personal
Information to other financial institutions with which it has a joint marketing
agreement or similar arrangement. Nonpublic Personal Information may be
disclosed to affiliated and nonaffiliated third parties to enable them to
provide business services for SEI, including marketing services, for us, such
as helping to evaluate requests for products or services, performing general
administrative activities and/or assisting in processing transactions. The
affiliated and nonaffiliated third parties are required to protect the
confidentiality and security of this information and to use it only in
accordance with SEI's instructions. In the event that a customer decides to
close an account or otherwise becomes an inactive customer, SEI will continue
to follow its privacy and information security practices.
This website uses
cookies, messages given to a Web browser by a Web server. The browser then
stores the cookie in a text file. This website uses two types of cookies:
Session cookies which are temporary cookies that are automatically deleted whenever you close all open Web browser windows. Session cookies are used to ensure that you are recognized when you move from page to page within the site and that any information you have entered is remembered. Session Cookies do not collect information from the users computer. They typically will store information in the form of a session identification that does not personally identify the user.
Persistent cookies that remain permanently on the cookie file of your computer. These persistent cookies contain the user id used to access the site along with encrypted identification values associated with the User ID in conjunction with the particular device (e.g. the PC, mobile device or other computer from which you accessed the website). These persistent cookies are used to provide enhanced security measures, personalize your experience on the site, monitor overall web site performance and provide overall site usage reporting. Cookies placed on your device do not contain any personal information, such as an email address or name.
Although your browser may permit you to reject cookies, cookies are required to login and navigate within this website. If you should choose to disallow cookies you will be required to respond to challenge questions each time you log on.
We protect your account information from unauthorized access, to the best of our ability, by placing it on the most secure portion of our website. Thatís why you have to enter a unique user name and password as well as either registering your device with us or answering 2 additional personal knowledge base questions each time you want to access this secure website. We also utilize a site authentication feature (personalized image and description), which allows you to verify you are visiting the valid website. Your password should never be shared with anyone. None of our other clients can access your data, and only a restricted set of our employees can access your data in order to provide service to you. When you access password protected portions of our site using a web browser, Secure Sockets Layer (SSL) technology is used to protect your communications through server authentication and data encryption. We upgrade and maintain our technology on an ongoing basis. Although this website may link to some external sites, we are not responsible for the privacy practices of those websites.
6. Vermont and California Residents Only
practices described above comply with federal law. Vermont and California laws
place additional limits on sharing Nonpublic Personal Information about their
residents. If a customer is a Vermont or California resident, SEI will
automatically limit the disclosure of Nonpublic Personal Information to
affiliated and nonaffiliated third parties as permitted or required by
applicable law or regulation.
7. Information Security
SEI maintains physical,
electronic and procedural safeguards to protect Information. SEI is committed
to the following principles to ensure the confidentiality and protection of
Information: maintaining Information security, taking into consideration
business requirements, risk mitigation, industry practice, and legal and
regulatory requirements; protecting all forms of Information; implementing
security measures that are effective, consistent and cost justified; effective
implementation by management and staff for adherence to policies and
procedures; monitoring advances in security technology to ensure that SEI is
providing an appropriate level of privacy and safety; and, appropriate
reporting of deviations from the policies and procedures or security breaches.
SEI employees are required to protect the confidentiality of Information and
observe policies and procedures in accordance with their job function.
Employees may only access Information when there is an appropriate reason to do
so, such as to administer or offer SEI products and services and may be subject
to disciplinary rules for noncompliance with policies and procedures. SEI may
conduct business in various locations where the laws conflict with SEIôs
established policies and/or procedures. In such instances, SEI will make
appropriate modifications to comply with local law.
8. Administrative Responsibilities
Several individuals are
responsible for defining, maintaining and publishing the procedures necessary
to implement the privacy and information security principles, including without
limitation the Chief Information Officer, the Information Security Team and the
Corporate Privacy Coordinator. The Operational Risk Committee will oversee the
coordination of privacy and information security activities within the
organization and review the activities from a business and regulatory
perspective. The Board or the Legal & Regulatory Oversight Committee of the
Board will review the Policy at least annually.