Important information

Please read and accept the disclaimer below to continue.

FOR INSTITUTIONAL CLIENTS ONLY.

This section of the website is for the use of institutional investors resident in the US only, and is not suitable for, or to be relied upon by, other investors. If you are not an institutional investor resident in the US, please leave this section of the website and enter a different section of the website which is appropriate to you, via the homepage.

Please read the following important information regarding the use of this section of the website. This Important Information should be read alongside, and is in addition to, the Legal Terms and Conditions (accessible by clicking on the 'Terms and Privacy' link at the bottom of each page of the website).

You can progress to your chosen area of this website by accepting this disclaimer. By clicking 'Accept' you confirm that you have read and accepted this Important Information for use of this section of the website and the Legal Terms and Conditions in their entirety (each as amended from time to time). If you do not agree to this Important Information or the Legal Terms and Conditions you must not use this section of the website.

This section of the website is for the use of institutional investors resident in the US only, and is not suitable for, or to be relied upon by, other investors, including investors resident in Canada. The information in this section of the website does not constitute either an offer to sell, a solicitation, or an offer to buy in a country in which this type of offer or solicitation is unlawful, or in which a person making such an offer or solicitation does not hold the necessary authorisation to do so. It is also not directed at investors, in those cases where the law prohibits this type of offer or solicitation from being made. Any applications or requests for further information received from persons not resident in a jurisdiction where a particular service or product is registered, may be refused at Insight's discretion.

Information on the pages in this section of the website may not be suitable for all investors. Part of this section of the website contains products that are intended for professional and institutional investors only. It is important that you do not rely upon the content of this website for investment decisions. Please contact a financial adviser before making any investment or financial decisions.

IMPORTANT DISCLOSURES

This website has been prepared by Insight North America LLC (INA), a registered investment adviser under the Investment Advisers Act of 1940 and regulated by the US Securities and Exchange Commission (SEC). Registration with the SEC does not imply a certain level of skill or training. The SEC has not reviewed or approved any calculation or presentation of performance results included in these materials. INA is part of “Insight” or “Insight Investment”, the corporate brand for certain asset management companies operated by Insight Investment Management Limited including, among others, Insight Investment Management (Global) Limited and Insight Investment International Limited.

Opinions expressed herein are current opinions of Insight, and are subject to change without notice. Insight assumes no responsibility to update such information or to notify a client of any changes. Any outlooks, forecasts or portfolio weightings presented herein are as of the date appearing on this material only and are also subject to change without notice. Insight disclaims any responsibility to update such views. No forecasts can be guaranteed.

Nothing on this website is intended to constitute an offer or solicitation to sell or a solicitation of an offer to buy any product or service (nor shall any product or service be offered or sold to any person) in any jurisdiction in which either (a) INA is not licensed to conduct business, and/or (b) an offer, solicitation, purchase or sale would be unavailable or unlawful.

Information shown should not be duplicated, amended, or forwarded to a third party without consent from INA. The information shown is generally intended for institutional investors only and should not be made available to or relied upon by retail investors. This material is provided for general information only and should not be construed as investment advice or a recommendation. You should consult with your adviser to determine whether any particular investment strategy is appropriate.

Assets under management are represented by the value of cash securities and other economic exposures, and are calculated on a gross notional basis. Regulatory assets under management without exposures shown can be provided upon request. Unless otherwise specified, the performance shown herein is that of Insight Investment (for Global Investment Performance Standards (GIPS®), the ‘firm’) and not specifically of INA. See the GIPS® composite disclosure page for important information and related disclosures about firm performance.

Past performance is not a guide to future performance, which will vary. The value of investments and any income from them will fluctuate and is not guaranteed (this may partly be due to exchange rate changes). Future returns are not guaranteed and a loss of principal may occur. Ownership interests in a fund are not insured by the FDIC, are not deposits, obligations of, or endorsed or guaranteed in any way, by BNY Mellon (as further defined below). Neither BNY Mellon nor any of its controlled affiliates (which includes any fund’s general manager/ managing partner/ investment adviser), may directly or indirectly, guarantee, assume, or otherwise insure the obligations or performance of the fund or of any other covered fund in which such fund invests.

Targeted returns intend to demonstrate that the strategy is managed in such a manner as to seek to achieve the target return over a normal market cycle based on what Insight has observed in the market, generally, over the course of an investment cycle. In no circumstances should the targeted returns be regarded as a representation, warranty or prediction that a specific strategy will reflect any particular performance or that it will achieve or is likely to achieve any particular result or that investors will be able to avoid losses, including total losses of their investment.

Certain information shown herein is derived from a representative account deemed to appropriately represent the management styles herein. Each investor’s portfolio is individually managed and will vary from the information shown. The mention of a specific security is not a recommendation to buy or sell such security. The specific securities identified are not representative of all the securities purchased, sold or recommended for advisory clients. It should not be assumed that an investment in the securities identified will be profitable. Actual holdings will vary for each client and there is no guarantee that a particular client’s account will hold any or all of the securities listed.

The quoted benchmarks do not reflect deductions for fees, expenses or taxes, nor reinvestment of interest payments and other forms of income. These benchmarks are unmanaged and cannot be purchased directly by investors. Benchmark performance is shown for illustrative purposes only and does not predict or depict the performance of any investment strategy. There may be material factors relevant to any such comparison such as differences in volatility, security selection, risk profiles and regulatory and legal restrictions between a particular strategy and its associated benchmark.

Asset allocations are subject to change without notice, may not represent current or future decisions, and should not be construed as investment recommendations.

Where provided, portfolio holdings are for informational purposes only and should not be deemed as a recommendation to buy or sell the securities mentioned.

Ratings reflects the credit ratings by nationally recognized statistical rating organization (NRSRO), including Moody’s, S&P and Fitch. If there are multiple ratings for a security, the lowest rating is used unless ratings are provided by all three agencies, in which case the median rating is used. Credit ratings are subject to change. Total may not add up to 100% due to rounding.

Derivatives are specialized instruments that require investment techniques and risk analysis different from those associated with equities and debt securities. Strategies may use both exchange-traded and over-the-counter derivatives, including, but not limited to, futures, forwards, swaps, options and contracts for differences. These instruments can be highly volatile and expose investors to a high risk of loss.  There can be no guarantee or assurance that the use of derivatives will meet or assist in meeting the investment objectives of the strategy.

Information contained herein is derived from sources believed to be reliable. Insight does not guarantee or warrant the accuracy, timeliness, or completeness of the information either collected, sourced or otherwise provided, and is not responsible for any errors or omissions.

Transactions in foreign securities may be executed and settled in local markets. Performance comparisons will be affected by changes in interest rates. Investment returns fluctuate due to changes in market conditions. Investment involves risk, including the possible loss of principal. No assurance can be given that the performance objectives of a given strategy will be achieved.

Insight does not provide tax or legal advice to its clients and all investors are strongly urged to consult their tax and legal advisors regarding any potential strategy or investment.

Information herein may contain, include or is based upon forward-looking statements within the meaning of the federal securities laws, specifically Section 21E of the Securities Exchange Act of 1934, as amended. Forward-looking statements include all statements, other than statements of historical fact, that address future activities, events or developments, including without limitation, business or investment strategy or measures to implement strategy, competitive strengths, goals expansion and growth of our business, plans, prospects and references to future or success. You can identify these statements by the fact that they do not relate strictly to historical or current facts. Words such as “anticipate,” “estimate,” “expect,” “project,” “intend,” “plan,” “believe,” and other similar words are intended to identify these forward-looking statements. Forward-looking statements can be affected by inaccurate assumptions or by known or unknown risks and uncertainties. Many such factors will be important in determining our actual future results or outcomes. Consequently, no forward-looking statement can be guaranteed. Our actual results or outcomes may vary materially. Given these uncertainties, you should not place undue reliance on these forward-looking statements.

Insight and BNY Mellon Securities Corporation (BNYSC) are subsidiaries of BNY Mellon. BNYSC is an SEC registered broker and FINRA member. BNY Mellon is the corporate brand of the Bank of New York Mellon Corporation and may also be used as a generic term to reference the Corporation as a whole or its various subsidiaries generally. Products and services may be provided under various brand names and in various countries by subsidiaries, affiliates and joint ventures of the Bank of New York Mellon Corporation where authorized and regulated as required within each jurisdiction. Unless you are notified to the contrary, the products and services mentioned are not insured by the FDIC (or by any government entity) and are not guaranteed by or obligations of the Bank of New York Mellon Corporation or any of its affiliates. The Bank of New York Mellon Corporation assumes no responsibility for the accuracy or completeness of the above data and disclaims all expressed or implied warranties in connection there with. Personnel of certain of our BNY Mellon affiliates may act as: (i) registered representatives of BNYSC (in its capacity as a registered broker-dealer) to offer securities, (ii) officers of the Bank of New York Mellon (a New York chartered bank) to offer bank-maintained collective investment funds and (iii) associated persons of BNYSC (in its capacity as a registered investment adviser) to offer separately managed accounts managed by BNY Mellon Investment Management firms.

Telephone conversations may be recorded in accordance with applicable laws.
Privacy notice
Effective from March 2026

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all such sharing. Federal law also requires that we tell you how we collect, share, and protect your personal information. Please read this notice (“Privacy Notice” or “Notice”) carefully to understand what we do.

What?

The types of personal information that we collect and share depend on the product or service you have with us. This information can include:

  • Social Security Number and Transaction History
  • Account Balances and Assets
  • Wire Transfer Instructions

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; whether INA shares such information; and whether you can limit this sharing. We share only as permitted by law and for the purposes described below.

FACTS

WHAT DOES INSIGHT NORTH AMERICA LLC (“INA”) DO WITH YOUR PERSONAL INFORMATION?

To limit our sharing

If you are a new customer, we may begin sharing your information 30 days from the date we deliver this notice to you. Sharing prior to that is limited to permissible purposes. When you are no longer our customer, we continue to share your information as described in this notice. You can contact us at any time to limit our sharing.

Questions?

Call 212-527-1800 or 1-888-392-0838 privacy@insightinvestment.com

PLEASE NOTE:

Your opt-out will continue to be effective unless and until you revoke it. You may communicate your opt-out request via mail, email, or phone. If you have previously opted out, you do not need to do so again. If you have joint accounts, your choice will apply to all of your accounts.

Opt-Out Request - Do not allow affiliates to use my personal information to market to me.

Mail to: Insight North America LLC c/o Chief Compliance Officer 200 Park Avenue 7TH Floor New York, NY 10166

Email: privacy@insightinvestment.com

Phone: 212-527-1800 or 1-888-392-0838

 

 

Who we are

Who is providing this notice? Insight North America LLC (“INA”)

What we do

How does INA protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does INA collect my personal information?

We collect your personal information, for example, when you:

  • Open an account and enter into an investment advisory agreement
  • Tell us about your investment or retirement portfolios
  • Give us your address and contact information
  • Direct us to buy securities or direct us to sell your securities

Why can’t I limit all sharing?

Federal law gives you the right to limit only:

  • Sharing for affiliates’ everyday business purposes— information about your creditworthiness
  • Affiliates from using your information to market to you
  • Sharing for non-affiliates to market to you
  • State laws and individual companies may give you additional rights to limit sharing.

What happens when I limit sharing for an account I hold jointly with someone else?

Your choice will apply to everyone on your account.

 

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies. Please see the affiliate list below.

Non-affiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies. INA does not share information with non-affiliates so they can market to you. Qualified custodians and other service providers receive information as needed to service and maintain your accounts (everyday business purposes).

Joint marketing

A formal agreement between non-affiliated financial companies that together market financial products or services to you. INA does not jointly market.

 

Other important information

For purposes of Regulation S P, this Notice applies to individuals who are consumers or customers within the meaning of federal securities and privacy laws. This Notice replaces all previous notices of our consumer privacy policy and may be amended at any time. We will keep you informed of changes or amendments as required by law, including where changes are material.

 

Affiliates

INA may share your information with the affiliated companies such as those listed in the box to the right.

  • The Bank of New York Mellon and certain subsidiaries
  • Insight Investment Management Limited
  • Insight Investment Management (Global) Limited
  • Insight Investment International Limited
  • Insight Investment Management (Europe) Limited
  • Your opt-out will also apply to banks or other companies that may become our affiliates in the future.

 

 

1.1 How to Contact Us for Privacy Requests

You may submit privacy-related requests (access, correction, deletion, portability, and opt-out requests) using any of the following methods:

  • Phone: 212-527-1800 or 1-888-392-0838
  • Email: privacy@insightinvestment.com
  • Mailing Address: Insight North America LLC, c/o Chief Compliance Officer, 200 Park Avenue, 7th Floor, New York, NY 10166

Verification: We may require reasonable verification steps to confirm your identity before processing your request.
Authorized Agents: Authorized agents must provide proof of authorization, and we may require you to verify your identity directly.
Accessibility: We can provide this notice in accessible formats upon request.

 

1.2 Safeguards and Incident Response

We maintain written policies and procedures designed to protect customer information and to detect, respond to, and recover from unauthorized access to or use of customer information. Our incident response program includes assessment, containment, investigation, notification, and remediation steps, and oversight of service providers. We periodically test our incident response program (e.g., exercises/tabletops) and conduct post-incident reviews to improve controls. These safeguards are designed to comply with Regulation S-P and other applicable federal securities laws.


1.3 Breach Notification

If there is unauthorized access to or use of sensitive customer information as defined under Regulation S-P, we will notify affected individuals as soon as practicable, and in no event later than 30 days after becoming aware of the incident, unless an exception applies. The notice will describe the incident, the categories of information involved, and how you can contact us for additional information. This notification timeline reflects Regulation S-P requirements; shorter notification periods may apply under applicable state laws, as described in the State Addenda below.

1.4 Service Provider Oversight and Recordkeeping

We oversee service providers through written policies, due diligence, and monitoring, including requirements to notify us promptly of any actual or reasonably suspected unauthorized access to or use of customer information. We maintain records to document our compliance with safeguards, disposal, incident response, breach notifications, and service-provider oversight requirements.

Disposal Practices: Considered with the Safeguards Rule and Regulation S-P disposal requirements in general,we use secure disposal methods (e.g., paper: secure shredding; media: cryptographic erase; storage devices: secure destruction) appropriate to the medium and sensitivity of non-public personal information.


1.5 Annual Privacy Notice Exception

We rely on the annual privacy notice exception only while our sharing practices and privacy policies remain unchanged and we do not share with nonaffiliates in a manner that requires an opt-out.


1.6 Data Lifecycle and Transparency

  • Data Minimization and Purpose Limitation: We collect and use only the personal information necessary for identified purposes, and limit use to those purposes unless otherwise permitted by law.
  • Retention: We retain personal information consistent with the purposes stated and legal/regulatory requirements. See the “Data Lifecycle and Transparency” section for examples and criteria. Examples include client onboarding records (e.g., 7 years), trade confirmations (per applicable rule), and call recordings (per applicable policy). Retention periods may vary based on account type, product, and applicable legal or regulatory requirements and are governed by INA’s records retention policies.

 

1.7 Security and Privacy Controls

  • Access Governance: Access to systems containing non-public personal information is role-based and reviewed periodically.
  • Encryption and MFA: We use encryption in transit and at rest where appropriate, and multi-factor authentication for administrative and remote access.
  • Training and Awareness: Employees receive privacy and security training, including phishing awareness and secure handling of client information.


1.8 Online Privacy and Cookies

For information about online tracking technologies and cookie preferences, please refer to our website privacy/cookie notice. Where applicable, we respect legally recognized browser-based opt-out signals.


1.9 Affiliates and Joint Marketing

  • We may share information with affiliated companies. The affiliate list is current as of March 2026 and may change over time.
  • Joint Marketing: INA does not jointly market.


1.10 State Addenda

The following state addenda provide additional disclosures and describe rights for residents of specific jurisdictions. These addenda supplement the Privacy Notice and apply where state law is applicable to INA’s activities. Where there is a conflict between this Privacy Notice and a state addendum, the addendum controls to the extent of the conflict. Appeals rights vary by jurisdiction.


1.10.1 California Addendum (CCPA/CPRA)

  • Applicability and GLBA Exemption: This California Addendum applies to personal information of California residents that is not exempt under the Gramm-Leach-Bliley Act (GLBA) and its implementing regulations. Personal information collected, processed, or disclosed pursuant to GLBA is excluded from CPRA.
  • Do Not Sell or Share: INA does not sell or share personal information (including for cross-context behavioral advertising).
  • Categories, Sources, Purposes, and Disclosures (preceding 12 months):
    • Categories collected: Identifiers; customer records information; commercial information; internet/network activity; professional information; inferences. Sensitive Personal Information may be collected where necessary (e.g., certain government identifiers).
    • Sources: Directly from you; from your representatives; and from service providers supporting account servicing and operations.
    • Business purposes: Account servicing, transaction processing, security and fraud prevention, compliance, audits, and operations.
    • Disclosures for a business purpose: To service providers (e.g., qualified custodians, technology and security providers) and professional advisors.
    • Sold: none; Shared: none.
  • CPRA Rights: Right to know/access (categories and specific pieces), delete, correct, data portability, opt-out of sale/sharing (not applicable because we do not sell/share), limit the use/disclosure of Sensitive Personal Information (where applicable), and non-discrimination for exercising your rights.
  • Submitting requests: Use the contact methods in this Notice. We will verify your identity before processing requests; authorized agents may submit requests where permitted by law.
  • Timelines: We will respond within 45 days; we may extend once up to an additional 45 days where necessary and will notify you of the reason for the extension.
  • Children: We do not sell or share personal information of consumers under 16 years of age. Our services are not directed to children.
  • Global Privacy Control (GPC): Where applicable, we honor legally recognized browser-based opt-out signals.

 

1.10.2 Colorado Addendum (CPA)

  • Scope: Applies to personal data of Colorado residents.
  • Rights: Access, correction, deletion, portability, and opt-out of targeted advertising, sale, or profiling.
  • Sensitive Data: Consent required for processing sensitive personal data where applicable.
  • Requests: Use the contact channels listed in this Notice; verification steps may apply.
  • Appeals: You may appeal a denied request within 30 days of our decision; we will respond within 60 days and provide information on further escalation to the Colorado Attorney General if applicable.

 

1.10.3 Connecticut Addendum (CTDPA)

  • Scope: Applies to personal data of Connecticut residents.
  • Rights: Access, correction, deletion, portability, and opt-out of targeted advertising, sale, or profiling.
  • Sensitive Data: Consent required for sensitive personal data processing where applicable.
  • Requests: Direct requests through the methods provided in this Notice.
  • Appeals: You may appeal a denied request within 30 days of our decision; we will respond within 60 days and provide information on further escalation to the Connecticut Attorney General if applicable.

 

1.10.4 Nevada Addendum (NRS 603A)

  • Scope: Applies to certain Nevada residents.
  • Rights: Opt-out of sale of covered information as defined under Nevada law.
  • Requests: You may submit an opt-out request using the contact information in this Notice.
  • Definition: Under Nevada law, “sale” of covered information has a specific definition that may differ from other jurisdictions. We do not sell covered information.
  • Limitations: Certain exceptions may apply under the statute.

 

1.10.5 Utah Addendum (UCPA)

  • Scope: Applies to personal data of Utah residents.
  • Rights: Access and deletion where applicable and opt-out of targeted advertising and sale.
  • Sensitive Data: Notice and choice mechanisms may apply to sensitive personal data.
  • Requests: Submit requests using the contact information in this Notice.
  • Verification: We may require reasonable verification to process requests.

 

1.10.6 Vermont Addendum

We do not disclose non-public personal information to our affiliates for the purpose of enabling them to market their products and services to you. There is no need for you to opt out to prevent that kind of disclosure.
We do not sell or share personal information. We share only as permitted by law and for everyday business purposes, such as processing transactions, servicing accounts, fraud prevention, audits, and compliance.
If we seek to use your information for marketing beyond what the law permits, we will obtain your consent first.
Vermont residents may submit privacy-related requests using the contact methods in this Notice; reasonable verification may be required. Authorized agents may submit requests where permitted by law.

 

1.10.7 Virginia Addendum (VCDPA)

  • Scope: Applies to personal data of Virginia residents.
  • Rights: Access, correction, deletion, portability, and opt-out of targeted advertising, sale, or profiling.
  • Sensitive Data: Consent required where applicable for processing sensitive personal data.
  • Requests: Submit via the contact methods in this Notice; verification may be required.
  • Appeals: You may appeal a denied request within 30 days of our decision; we will respond within 60 days and provide information on further escalation to the Virginia Attorney General if applicable.


1.10.8 Washington Addendum (Applicable Laws)

  • Scope: Applies where Washington law is applicable to INA’s activities.
  • Consumer Health Data: If the Washington My Health My Data Act applies to our activities, we will provide required disclosures and protections. If it does not apply, this addendum may not be applicable. Based on INA’s current business activities, INA does not believe it possesses “consumer health data” as defined under the Washington My Health My Data Act; if that assessment changes, INA will update its disclosures accordingly.
  • Requests: Use the contact methods in this Notice; verification may be required.
Back to top