Cowen appreciates your visits.
Here are some principles to keep in mind as you read through this Policy:
- This Policy does not apply to information that you may provide to us, or that we may obtain, other than through the Sites and our social media accounts, such as over the phone, by email not sent through our website, mail, or in person.
- This Policy also does not apply to any websites or online properties operated by third parties, such as social media platforms or job recruitment sites where certain of our employment opportunities are posted (“Third Party Sites”).
- If you are an individual who is a current or former investor in or customer of one of Cowen’s financial products or services and you are based in the United States, please refer to our U.S. Customer Privacy Notice for additional information about the personal information we collect and process in connection with our relationship with you.
- If you are a California resident or are based in the European Economic Area (“EEA”) or a jurisdiction with substantially similar privacy laws, applicable law may provide you with additional rights regarding your personal information. To learn more about your rights, please refer to the “Additional Protections Under California Law” or “Additional Protections for Individuals Based in the EEA or Similar Jurisdictions” sections below.
- Please read this Policy in its entirety to understand how we handle your information.By accessing the Sites, you agree to and accept this Policy. This Policy replaces all previous privacy policies regarding information collected through the Sites and may be amended from time to time (see the “Changes to this Policy” section below). Your continued use of the Sites after we make changes is deemed to be acceptance of those changes, so please check periodically for updates.
I. Information We May Collect
We collect different categories of information about you (including personal information) from different sources, including User-Provided Information and Site Usage Information (each described below), as well as information provided to us about you from third party social media platforms. As used in this Policy, “personal information” means information that can be used to identify you as an individual or allow someone to contact you, as well as information attributed with such information.
We collect personal information you provide to us, such as your name, email address, company name, job or other title, postal address, telephone number, financial information, user name, password, other account information, job history and employment or internship application information (such as education information, standardized test scores, work authorization and nationality), interests, preferences and demographic information, and any other information included in your communications with us or that you provide through the Sites (collectively, “User-Provided Information”). For example, User-Provided Information may be collected on the Sites to the extent you enroll, register or access your account(s) online, conduct a transaction, create an account, register for our conferences, publications or announcements, or submit a comment or question to us using a “start a conversation” or similar feature on the Sites.
Site Usage Information
As is the case with many online properties, during your use of the Sites, our servers will automatically record details about your visit, including, but not limited to, your IP address, and we may associate that information with your domain name or that of your internet access provider. We may also capture certain “clickstream data” pertaining to your usage of the Sites. Clickstream data includes, for example, device ID and other information about your computer or device, browser and operating system and their settings (such as screen resolution, the size of a browser window or language settings), whether you have Java enabled, what version of Flash you are using, the referring page that linked you to the Sites, the pages or content you see or click on during your visit and when and for how long you do so, items you download, the next website or other online property you visit when you leave the Sites, and any search terms you have entered on the Sites or a referral service or website or other online property. Collectively, this is what we refer to as “Site Usage Information,” and it may include personal information.
Among other things, this information enables us to generate analytics reports on the usage of the Sites. To opt out of your Site usage being included in our Google Analytics reports, you may follow instructions at this link: https://tools.google.com/dlpage/gaoptout/.
II. Cookies and Other Tracking Technologies
We may deploy, or our service providers or partners may deploy on our behalf, various tracking technologies on the Sites to collect additional information about your visits to the Sites. These technologies enable us to assign a unique number or persistent identifier to you, your household or device and relate your Site Usage Information to other information about you, including your personal information. These technologies also enable us to recognize you when you access the Sites using different web browsers and different computers or devices, to distinguish you from other users of the Sites, to help us measure how users interact with Sites content and for purposes of security and monitoring of the Sites.
- Cookies are small text files that may be placed on your web browser when you visit the Sites or when you view advertisements online. Cookies allow your browser to remember some specific information which the web server can later retrieve and use. Cookies assign a unique numerical identifier to your browser. Cookies on the Sites are used primarily for administrative or functional purposes, such as to improve your experience with the Sites. If you would like to modify your browser to notify you when you receive a new cookie or to disable cookies altogether, you are free to do so. The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. Rejecting cookies may, in some cases, inhibit or preclude your use of the Sites or their features.
- A pixel tag (also known as a “clear GIF” or “web beacon”) is a tiny image – typically just one pixel – that can be placed on a website page or in our electronic communications to you in order to help us measure the effectiveness of our content by, for example, counting the number of individuals who visit us online or verifying whether you’ve opened one of our emails or seen one of our Sites.
The type of information collected by these tracking technologies includes, for example, information about your location (which may be based on your IP address), language and other Site Usage Information discussed above.
The cookies currently deployed on the Sites include the following:
Strictly Necessary Cookies
|Cookie Notice Acceptance||This cookie tracks that a user acknowledged the cookie notice banner and hides the banner from future view as long as the cookie is set.||12 months|
|Dismiss Global Banner||From time to time Cowen may share important messages via a sitewide banner. If a user dismisses the banner, this cookie prevents the banner from being displayed again. ||12 months|
|CIM Acknowledgement||This cookie tracks a user’s acknowledgement of the informational statement if they access the website page dedicated to Cowen Investment Management LLC.||12 months|
|Google Analytics||These cookies are used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request and used to calculate visitor, session and campaign data for analytics reports.||10 minutes to 24 months|
By using the Sites, you consent to our use of tracking technologies as described in this Policy.
WE COMPLY WITH U.S. FEDERAL SECURITIES LAWS WITH REGARD TO THOSE PAGES OF THE SITES USED TO FURNISH ELECTRONIC PROXY MATERIALS. WE DO NOT USE TRACKING TECHNOLOGIES ON THESE PAGES.
III. How Does Cowen Use Personal Information Collected on the Sites?
We or our service providers may use the personal information we collect from and about you, including User-Provided Information, Site Usage Information and/or any information collected through social media sites, to perform the following business functions:
- To provide, administer, develop and enhance the Sites and our offerings;
- To fulfill your transactions, administer your account with us, authenticate account information and otherwise to conduct business with you;
- For marketing purposes, such as to contact you about products, services or other offerings we believe may be of interest to you;
- To respond to your requests and other communications;
- To evaluate, process and communicate with you regarding your applications for opportunities (such as jobs or internships) for which you have applied through the Sites and for subsequent opportunities;
- To conduct research, analytics and data analysis;
- To maintain our infrastructure and facilities, undertake quality and safety assurance measures, conduct risk and security control and monitoring, detect and prevent fraud, and perform accounting, audit and other internal functions, such as internal investigations;
- To facilitate corporate transactions;
- In order to comply with legal and regulatory obligations and requests and/or to exercise, enforce and defend our rights;
- Other purposes disclosed when personal information is submitted to us; and
- Other legitimate business purposes as deemed required and otherwise permitted by law.
To perform the above functions, we may match information collected from you through different means or at different times, including personal information, and use such information along with information obtained from other sources (including third parties like data aggregators and sales lead generators) and publicly accessible information (such as information available publicly on the internet). This information includes, for example, demographic information and updated contact information. We or the service providers may also use your information to assess the level of interest in, and use of, the Sites, our emails and our other messaging campaigns both on an individual basis and in the aggregate.
IV. How Does Cowen Share Personal Information Collected on the Sites?
We may share the information we collect on the Sites with others for a variety of reasons. In addition to the kinds of information sharing you might expect, such as sharing what you voluntarily post to public areas on the Sites with other users of the Sites, we may share your information (including any of the types listed in the “Information We May Collect” section above):
- With third parties in order to provide services to us or on our behalf;
- With our affiliates for their marketing and other purposes;
- With our co-sponsor(s) if we obtain your information in connection with an offering or other promotional activity that is jointly offered by us and such third parties;
- With credit bureaus or background check agencies;
- When we believe in good faith that disclosure is necessary to protect our rights or property, protect your safety or the safety of others, investigate fraud or respond to a government, judicial or other legal request, or to comply with the law; and
- In connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business.
In addition, we may share non-personally identifiable Site Usage Information (including aggregate data) with others, for their own use, in a form that does not include your name or contact information.
V. Social Media and Third Party Sites
We maintain a presence on several social media and live streaming platforms, such as LinkedIn, YouTube and Twitter, and we may also incorporate some third party social media features onto the Sites. Through these platforms and features, we receive some personal information and some Site Usage Information about you, and this Policy applies to that information as well.
In addition to social media platforms, the Sites may contain links or widgets to other Third Party Sites, such as job recruitment sites where certain of our employment opportunities are posted. However, we are not responsible for Third Party Sites, so their posted privacy policies will govern the collection of your information on them, and use and disclosure by third parties of that information. Please be sure to review the privacy policies for any Third Party Sites you visit.
We endeavor to protect the security and integrity of sensitive personal information collected via the Sites. However, due to the inherent nature of the internet as an open global communications vehicle, Cowen cannot guarantee the confidentiality or security of any information, during transmission through the internet (including email) or while stored on our system or otherwise in our care. If you correspond with us by email, text message, or using web forms like a “start a conversation” feature on the Sites, you should be aware that your transmission might not be secure. A third party could view the information you send in transit by such means. Cowen accepts no responsibility or liability for the security of your information while in transit over the internet.
If you create an account on the Sites, you are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any activity that occurs using your account credentials, whether or not you authorized such activity. Please notify us of any unauthorized use of your password or account or any other breach of security.
Other more secure means of communication with Cowen remain available; please contact us for more information about this.
VII. Children’s Privacy
Cowen does not knowingly collect personal information from individuals under the age of 13. We request that individuals under the age of 13 do not access or provide personal information through the Sites. For more information about the Children’s Online Privacy Protection Act (COPPA) please visit the FTC website at www.ftc.gov.
VIII. Do-Not-Track Disclosures
Some web browsers may transmit “do-not-track” signals to the websites with which users communicate. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not change our tracking practices (which are explained in more detail in the “Site Usage Information” section above) in response to “do-not-track” settings in your web browser.
Our third party partners, such as web analytics companies, collect information about your online activities over time and across the Sites. These third parties may not change their tracking practices in response to “do-not-track” settings in your web browser, and we do not obligate these parties to honor these settings.
IX. Wireless Addresses
If the email address you provide to us is a wireless email address, you agree to receive messages from us at such address unless and until you tell us not to send messages to that address, by following the instructions in the “Actions You Can Take With Respect to Personal Data Held by Cowen” section below. You may change your email preferences at any time, but your wireless carrier’s standard rates will apply as long as you are receiving messages at a wireless email address. If you give us a wireless email address, you represent that you are the owner or authorized user of the device on which messages will be received and that you are authorized to approve the applicable charges.
X. Additional Protections For Individuals Based In The EEA Or Similar Jurisdictions
You may be entitled to additional rights related to your personal information if you are based in the EEA or another jurisdiction with substantially similar privacy laws (such as the United Kingdom). These rights are described in Cowen’s Non-U.S. Customer Privacy Notice. Please follow the instructions in the Non-U.S. Customer Privacy Notice or email us at email@example.com if you have any questions concerning your rights or would like to make a request to exercise your rights under the laws of the European Union or a jurisdiction with substantially similar privacy laws.
XI. Additional Protections Under California Law
If you are a California resident, California law may provide you with additional rights regarding your personal information. To learn more about your California privacy rights, visit our Privacy Notice for California Residents or, only in relation to Kyber Data Science LLC and its subsidiaries, the Kyber CCPA Privacy Supplement.
XII. Actions You Can Take With Respect To Personal Data Held By Cowen
Please contact us at firstname.lastname@example.org if you would like to review, update or modify certain of the personal information that is stored in your account within the Client Portal on the Sites, if you have one, or you may be able to do so directly within your account. We may need to ask you to verify your identity and to provide other details before we are able to provide you with any information, correct any inaccuracies, or delete any information. Your rights under this section are subject to our records retention policies and applicable law.
Please contact us at email@example.com if you do not want to receive a particular media notification from us or promotional communications from a particular Cowen business unit. Please clearly indicate the reason for your communication and nature of request, such as whether you are writing to request that you no longer receive a specified media notification or promotional communications from a specified Cowen business unit.
Please understand that it may take us a few days to process any such request and that even if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.
XIII. Changes to This Policy
We may change this Policy from time to time. When we do, we will let you know by posting the updated policy on this page with a new “Effective Date.”
XIV. Contact Us
If you have any questions or comments regarding our privacy practices, please contact us at: firstname.lastname@example.org.
EFFECTIVE DATE: July 29, 2020