Effective Date: December 1, 2015
“Information” refers to anonymous information, aggregate information, and Personal Information, meaning personally identifiable information about an individual, such as a name, address, email address, phone number, or other identifier that permits direct or indirect identification of a specific individual, or as otherwise defined by applicable privacy and data security laws.
“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.
We collect Information about you directly from you, from third parties, 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. We collect certain information (e.g., personnel, structure, etc.) through password-protected portals. The Personal 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, 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 About You from Third Parties. We may collect certain Information about you from third parties, 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 Site using cookies and other technologies. This Information may include, without limitation, information about your operating system; settings and system configurations; IP address; device model; the webpages you access within our Site; the website that led you to our Site; the website to which you go after leaving our Site; the number of times you access our Site, including the dates and times you do so; and other Site usage data.
We may use your Information, including Personal 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.
- 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.
- 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.
- Legal Compliance. To comply with applicable legal or regulatory obligations, including informal requests from law enforcement or other governmental authorities.
We may disclose your Information, including Personal 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, including Personal 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.
- 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.
- 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.
Our Site does not respond to Do Not Track signals. For more information about Do Not Track signals, please click here.
We have taken steps to help protect your Personal 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.
You may modify the Personal Information that you have submitted by logging into your account or emailing us at email@example.com.
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.
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.
600 Montgomery Street
San Francisco, CA 94111