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Morningstar Direct Privacy Statement

Last updated, March 18, 2022

Overview.

Your privacy is important to us. This Privacy Statement describes how we collect your information when you use Morningstar Direct, how we use and share your information, how we keep it secure, and your rights relating to your personal information. This Privacy Statement should be read in conjunction with our General Privacy Statement and your agreement with us. This Privacy Statement applies to Morningstar Direct users in the United States. If your financial advisor has given your personal information to Morningstar, please contact your financial advisor directly.

If you would like to learn more about Morningstar’s approach to privacy and security, please visit our Privacy Center.

Types of information we collect.

When you use Morningstar Direct or communicate with us, we may collect the following information about you

Personal identifiers, such as your name, your account name, street address, phone number and email address.

Internet, network or device information, including IP address, MAC address, computer name,network name and operating system version.

Geolocation information.

Professional or employment-related information, including your job title or function and industry.

How we use your information.

We use your information as needed to provide you with our Direct product, including to verify your identity, personalize the content you receive, to monitor your compliance with the terms of our license agreement (such as whether an account is shared by multiple users), and to contact you to support your account or provide notices related to our services.

We may also use your information to send you notices about product offerings, to improve the services we offer, to protect our and your information and/or systems, and to enforce our contracts or otherwise fulfill our legal obligations.

How we share your information.

Morningstar won’t sell your personal information. We’ll only share your information with organizations outside of Morningstar in the following cases:

With your consent, including when you ask us to share your information with third-party organizations, such as third party data providers and marketers.

With vendors or other third parties who work on our behalf for the purposes described in this statement.

Where needed to comply with legal and contractual obligations.

We also use and share anonymized customer information for research purposes and to improve our products. When we share your information for these purposes, we remove any information that can identify you.

We’ll take reasonable steps to ensure that any third party that receives your information keeps it safe, including contractually requiring those third parties to keep your information confidential.

Our use of third party service providers.

Morningstar uses a small number of third parties to provide systems and software for its administrative functions, such as sales processing, accounting / finance management and procurement. In such cases, the third parties only process personal information in accordance with our instructions and we are responsible for ensuring such third parties are compliant with all applicable data protection regulations in relation to their processing activities.

How we keep your information secure.

The security of your information is our priority. We maintain a comprehensive information security program that requires that we use physical, technical, and procedural safeguards designed to keep your information safe. It’s important to note that this document is intended for public distribution and that we don’t provide specific details regarding our security controls here. If you would like more information about our practices, you may contact your product relationship manager.

How do we store your information?

Morningstar stores Direct users’ information in the United States. However, from time to time, your information may be transmitted to other countries for use by our staff who need to access your personal

information to perform their roles. We’ll retain your information for only as long as necessary to fulfill the purpose for which it was collected orto comply with legal, regulatory or internal policy requirements.

Your rights

Certain jurisdictions provide their residents rights to access, correct, restrict the sale of, or erase personal information. These rights are not absolute, and they don't always apply in all cases. To learn more about these rights, please visit our Privacy Center.

If applicable, you can send us a personal data access request to exercise your rights here. In response to a request, we'll ask you for additional information to verify your identity, and may ask that you provide further information to help us better fulfill your request. You can also make your personal data access request by calling us toll-free at +1 (888) 293-8609.

It’s important to know that if you request that we erase your personal information and we process that request, we may still retain certain elements of your personal information as permitted by law, including to comply with legal, regulatory or our own policy requirements.

We won’t discriminate against our customers who choose to exercise their rights to access or control their personal information.

However, Morningstar Direct requires your personal information to operate. If you choose not to provide certain personal information or to request that personal information be deleted, you may not be able to use this product.

California customers.

The California Consumer Privacy Act requires that we list the categories of our customers’ personal information that we’ve sold or disclosed for business purposes in the last twelve (12) months.

Sales: In the last twelve (12) months, we haven’t sold our customers’ information.

Disclosures: In the last twelve (12) months, we’ve only disclosed customer information as directed by our customers. We’ve disclosed personal identifiers (for example, name and account information) and commercial information (for example, transaction or investment-related information) to financial service providers and to customers and their agents directly.

Cookies.

We use cookies to set your preferences, help you sign in, and monitor then presentation of our site. If you would like to learn more about how we use cookies, generally, please visit our Cookie Policy.

How we revise this statement.

Our business frequently changes, and we may need to update this statement to reflect those changes. When we make changes to this privacy statement, we’ll revise the "last updated” date at the top of this page. If we make material changes to this statement, we’ll notify you directly as required by law.

Contact us.

If you have concern, complaint, or question about how we handle your personal information, please contact us by using our web form, call us toll-free at +1 (888) 293-8609 or write us at the following mailing address:

Morningstar,Inc.

22 W.Washington St.

Chicago, IL 60602

Attn:Chief Privacy Officer