Policies & Disclosures

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Read our Part 2A of Form ADV Investment Adviser Brochure.

Callan LLC Website Privacy Policy

Effective Date: November 13, 2019

Introduction

Callan LLC (“Callan”, “we”, “us”, or “our”) recognizes the importance of privacy. In this privacy policy (“Privacy Policy”), we describe how we collect, use, and disclose information that we obtain about visitors to our website www.callan.com (the “Site”), our mobile applications, and the services available through our Site and our mobile application (collectively, the “Services”).

“Services” includes the services that we provide to our clients, including fund sponsors and clients of our Independent Adviser Group (IAG), Institutional Consulting Group (ICG), and Trust Advisory Group (TAG), as well as our development and dissemination of research.

Your use of our Site or Services, and any dispute over privacy, is subject to this Privacy Policy, our Terms of Service, and any client agreement you may have with Callan. Any customer agreement between you and Callan supersedes the terms of this Privacy Policy to the extent there are any discrepancies.

Information We Collect

We collect information about you directly from you, from other sources, and automatically through your use of our Site or Services. We may combine the information that we collect from various sources.
  • Information We Collect Directly from You through our Site. We collect certain information (e.g., personnel, structure, etc.) through password-protected portals. The information we collect directly from you includes your name, email address, and phone number. We may also collect information about your company, such as your company’s name and location, industry, personnel structure, and products. We will also collect any other information that you choose to provide to us through our Site.
  • Information We Collect Directly from You through our Mobile Application. If you use our mobile application, you may choose to provide us with profile information such as your name, email address, job title, bio, profile photo, phone numbers, address, and social media handles. If you connect a social media account to the app, we may also receive information from these social media services such as your name, photo, and email address. We collect information that you post in the mobile application, such as comments and photos. We enable app users to message each other through the mobile application. To provide this service, Callan receives the message content.
  • Information We Collect About You from Other Sources. We may collect certain information about you from other sources, such as other employees of your company if they identify you as an executive or key professional or if someone else registers you for an event.
  • Information We Collect Automatically. We or our service providers automatically collect information through your use of our Services using cookies and other technologies. This information may include, without limitation, information about your operating system; settings and system configurations; device IDs; push notification tokens; IP address; device model; the webpages you access within our Services; the website that led you to our Services; the website to which you go after leaving our Services; the number of times you access our Service, including the dates and times you do so; and other Services usage data.
For the avoidance of doubt, Callan does not collect your Personally Identifiable Information (“PII”). For purposes of this Privacy Policy, PII shall mean a person’s first name and last name or first initial and last name combined with any one or more of the following data elements that relate to a person: (a) Social Security number, (b) driver’s license number or state issued ID card number, and (c) a financial account number, or credit or debit card number.

How We Use Your Information

We may use your information for the following purposes:

  • Providing Our Services. To provide our Site and Services to you; to communicate with you, including via email, about your use of our Site and Services; to respond to your inquires; and for other customer service and support purposes.
  • Customized Experience. To tailor the content and information that we may send or display to you, to offer personalized help and instructions, and to otherwise personalize your experiences while using the Services.
  • Marketing and Communications. To communicate with you about your account and use of our Site and Service; to provide you with news and newsletters, research, and other items of interest regarding invest-related topics; to send you push notifications.
  • Surveys. To administer surveys and questionnaires, such as for market research or client satisfaction purposes.
  • Research and Analytics. To analyze how users interact with our Site and Services; to understand financial trends; and for other research, analytical, and statistical purposes.
  • Protecting Rights and Interests. To protect our rights and interests as well as the rights and interests of our users and any other person, as well as to enforce this Privacy Policy and our Terms of Service.

Legal Compliance. To comply with applicable legal or regulatory obligations, including informal requests from law enforcement or other governmental authorities.

How We Disclose Your Information

We may disclose your information with the following entities:
  • Affiliates. We may disclose information to any current or future affiliates, parent companies, or subsidiaries.
  • Service Providers. We may disclose your information to our vendors, service providers, agents, or others who perform functions on our behalf.

We may also disclose your information in the following ways:

  • In Client and Financial Reports. We may disclose information in our client reports. For example, we may aggregate information about your company with information about similar companies to report on financial trends or provide investment manager information to our fund sponsor clients as part of a manager search.
  • Mobile App User Content.  You may also optionally make your profile public and visible to other app users. Our mobile app enables you to post comments and photos that will be viewable by other users.  
  • Business Transfers. We may disclose information to another entity if we are or may be acquired by or merged with another company, if we sell or transfer a business unit or assets to another company, as part of a bankruptcy proceeding, or as part of any other similar business transfer. If the surviving entity involved in such a transfer is not Callan, in accordance with applicable law, the surviving company may use the information we collect about you pursuant to its own privacy policies, which may be different from this Privacy Policy.
  • Protecting Rights and Interests. We may disclose information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Privacy Policy, or as evidence in litigation in which we are involved.
  • Legal Compliance. We may disclose your information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; in response to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.

Aggregate and De-Identified Information. We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, security or other purposes.

Cookies and Other Tracking Mechanisms

We and our service providers use cookies and other tracking mechanisms to track information about your use of our Site or Services. We or our service providers may combine this information with other personal information we collect about you.
  • Cookies. We or our service providers may use cookies to track visitor activity on our Site. A cookie is a text file that a website transfers to your computer’s hard drive for record-keeping purposes. We or our service providers may use cookies to track user activities on our Site, such as the pages visited and time spent on our Site. Most browsers allow users to refuse cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies may not be able to browse certain areas of the Site.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, which are embedded invisibly on web pages. We or our service providers may use clear GIFs (also known as web beacons, web bugs or pixel tags), in connection with our Site to track the activities of visitors to our Site, help us manage content, and compile statistics about usage of our Site. We or our service providers may also use clear GIFs in HTML emails to our users, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

California Do Not Track Disclosure

Our Site does not respond to Do Not Track signals. For more information about Do Not Track signals, please click here.

Third-Party Analytics

We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site and Services. We also may use other analytic means to evaluate our Site and Services. We use these tools to help us improve our Site’s and Services’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Third-Party Links

Our Site and Services may contain links to third-party websites and applications. Any access to and use of such linked websites and applications is not governed by this Privacy Policy but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third-party websites or applications.

Security

We have taken steps to help protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your device and account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Your Choices

You may modify the information that you have submitted by logging into your account or emailing us at [email protected].

We may send periodic emails to you containing links to research or other investment-related content that may be of interest. You may opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt out of receiving emails containing this content, we may still send you electronic notification about your account or any services you have requested or received from us.

Children

Our Site and Services are not designed for children under thirteen (13) years of age. If we discover that a child under 13 has provided us with Personal Information, we will promptly delete such Personal Information from our systems.

Contact Us

If you have questions about this Privacy Policy of the privacy aspects of our Site or Services, please contact us at:
Callan LLC
600 Montgomery Street
Suite 800
San Francisco, CA 94111
[email protected]

Changes to this Privacy Policy

This Privacy Policy is current as of the Effective Date set forth above. We may change this Privacy Policy from time to time, so please be sure to check back periodically. We will post any changes to this Privacy Policy on our Site. If we make any changes to this Privacy Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change(s) on our Site.

© Callan LLC Privacy Policy