Privacy
Russell Investments is committed to protecting and respecting your privacy. This policy (together with our Terms and Conditions) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 1998 (the Act), the data controllers are Russell Investments Limited, Russell Implementation Services Limited and Russell Systems Limited (collectively “Russell Investments”) of 10 Regent Street, London, SW1Y 4PE, United Kingdom.

Information we may collect from you
We may collect and process the following data about you:

• Information that you provide by filling in forms on our website.  This includes information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further services.  We may also ask you for information when you enter a competition or promotion sponsored by Russell Investments and when you report a problem with our site.
• If you contact us, we may keep a record of that correspondence.
• We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
• Details of your visits to our site [including, but not limited to, traffic data, location data, weblogs and other communication data] and the resources that you access.

Cookies
By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set or to reject all cookies. However, you should be aware that if cookies are rejected you will not be able to use some of the online services provided by Russell Investments. For more information on how to configure your browser preferences, please refer to the user guides:

• Microsoft Internet Explorer
• Firefox
• Google Chrome
• Apple Safari

A full list of all cookies Russell Investments uses can be found here .

Cookies for storing your preferences

We use various cookies to store some details you enter and choices you make so that we do not have to ask you for them every time you visit a page that needs them.

Cookie name	Purpose
.ASPXAUTH, ASPSESSIONID********	Stores an encrypted authentication key that allows you to seamlessly login to Russell Investments websites. It expires when you logout or close the browser unless you selected the "stay logged in on this computer" option in which case it will expire after a 1 year or if you clear your cache of browsing history. ASPSESSIONID******** will generate a random set of 8 letters that will change with every session there will be different set for the encrypted authentication.
ASP.NET_SessionId, ASPSESSIONID********, BlueStripe.PVN	Keeps a record of your current Russell Investments session so that we can provide consistent functionality across the site.  It expires when you logout, close your browser or if you clear your cache of browsing history. ASPSESSIONID******** will generate a random set of 8 letters that will change with every session.
countrytabs	This will remember your preference from the www.russell.comcountry selection page so that you do not need to select the country every time that you visit the country of your choice.
browserLanguage	This will remember your language preference dependent on the country that you are in.

Cookies for improving service by measuring traffic
We use SiteCatalyst, a web analytics service provided by Adobe, in order to find out how visitors interact with Russell Investments so we can improve it. Information is collected anonymously and website trends are reported without identifying individual visitors.

Cookie name	Purpose
__utma	Keeps track of the number of times a visitor has been to the site, when their first visit was, and when their last visit occurred. It expires after two years.
__utmb and __utmc	The B and C cookies work together to calculate how long a visit takes. __utmb takes a timestamp of the exact moment in time when a visitor enters a site, while __utmc takes a timestamp of the exact moment in time when a visitor leaves a site. __utmc has no way of knowing when a user closes their browser or leaves a website, so it waits 30 minutes for another pageview to happen, and if it doesn't, it expires.
__utmz	Keeps track of where the visitor came from, what search engine was used, what link was clicked on, what keyword was used, and where they were in the world when the website was accessed.
s_vi	Keeps track of where the visitor came from, what search engine was used, what link was clicked on, what keyword was used, and where they were in the world when the website was accessed.  It expires after six months.
gpv_p3 and s_nr	gpv_p3 takes a timestamp of the exact moment in time when a visitor enters a site, while s_nr takes a timestamp of the exact moment in time when a visitor leaves a site.
s_sq	Keeps track of where the visitor came from, what search engine was used, what link was clicked on, what keyword was used, and where they were in the world when the website was accessed. It expires after six months.

New requirements on cookies
Russell Investments conducted an assessment of all EU websites following the revision of the e-Privacy directive. All websites will be compliant based on guidance provided by the Information Commissioner's Office.

Should you have any questions or would like more information about Russell Investments Privacy policy, please contact us at london@russell.com or +44 (0)207 024 6000.

Further reading

Internet Advertising Bureau
A guide to behavioural advertising and online privacy has been produced by the internet advertising industry which can be found at: 
www.youronlinechoices.eu

International Chamber of Commerce United Kingdom
Information on the ICC (UK) UK cookie guide can be found on the ICC website section: 
www.international-chamber.co.uk/our-expertise/digitaleconomy

*Websites

Site	url	use
Russell.com - UK	www.russell.com/uk	The Russell.com sites contain information on the proposition and services offered in each of the regions.
France	www.russell.com/fr	The Russell.com sites contain information on the proposition and services offered in each of the regions.
Italy	www.russell.com/it	The Russell.com sites contain information on the proposition and services offered in each of the regions.
Netherlands	Dutch www.russell.com/ne English www.russell.com/ne_en	The Russell.com sites contain information on the proposition and services offered in each of the regions.
Nordics	English www.russell.com/no	The Russell.com sites contain information on the proposition and services offered in each of the regions.
Germany	German www.russell.com/de English www.russell.com/de_en	The Russell.com sites contain information on the proposition and services offered in each of the regions.
ClientLink	investment.russell.com	ClientLink is the extranet site for our UK and European Institutional Clients. ClientLink contains fund performance information, regulatory information, and has a comprehensive research library.
Russelllink	www.russelllink.co.uk	RussellLink provides information and tools only directed at FSA regulated independent intermediaries providing services to their clients in the UK, a login is required.
Openworld Investing	www.openworldinvesting.com	Contains information on the OpenWorld® proposition, articles & research, fund information and performace. The site that can be accessed by members of the public, however for detailed fund information and performance, a login is required.

Where we store your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA").  It may also be processed by staff operating outside the EEA who work for us or for one of our group companies.  Such staff maybe engaged in, among other things, the provision of support services to Russell Investments.  By submitting your personal data, you agree to this transfer, storing or processing.  Russell Investments will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers.  Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Uses made of the information
We use information held about you in the following ways:

• To ensure that content from our site is presented in the most effective manner for you and for your computer. 
• To carry out our obligations arising from any contracts entered into between you and us.
• To allow you to participate in interactive features of our service, when you choose to do so.
• To notify you about changes to our service.

Disclosure of your information
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If Russell Investments Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Russell Investments Limited, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting the Privacy Marketing Officer at Russell Investments Limited, 10 Regent Street, London, SW1Y 4PE.

Our site may, from time to time, contain links to and from the websites of our partner networks, and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Access to information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Privacy Marketing Officer, Russell Investments at London@russell.com.