Last Updated: July 2023
Value(s) Management and Investing, Inc. (“VMI”, the “Firm”, “our”, “we”, or “us”) is committed to protecting the privacy of confidential and personal information, including personal data relating to individuals who may be clients, subscribers, members, staff, agents, lawyers, job applicants, service providers, or others inside or outside the Firm.
Personal Information We May Collect
We may collect and store the following information when providing Services to you:
Information You Provide Voluntarily. We collect information that you voluntarily provide to us, including information communicated in connection with initiating or responding to inquiries; event registrations; news, newsletter, blog, event, and other subscriptions; and job-related inquiries and applications. The information you provide may include your name, contact information, title, and information about the organization with which you are affiliated. In relation to career information, the information you provide may also include employment history and qualifications. We only collect and process the personal information we need to allow us to respond to your request and/or provide the particular service you have sought.
Information We Collect Automatically. We may automatically collect information about you when you use our Services such as, but not limited to:
Device Information. We may collect information about devices you use to access the Services and how you use the Services, such as your Internet Protocol (“IP”) address and which website you visited before accessing our Services.
Performance and Log Data. Our servers may automatically record information created by your use of our Services, which may include information such as your IP address, browser type, operating system, command line information, diagnostic information related to the Services (e.g., crash activity reports), the referring web page, pages visited, location, your mobile carrier, device and application IDs, and search terms. For instance, when we send you an email, we may collect certain information including the nature of the email, whether you opened or deleted our email, action you took upon receipt of our email, or your name and contact information.
Information We Receive from Third Parties. We may receive personal information about you from third parties and use such information. This may include your name, email address, contact information, the company you work for, your position, business and home addresses, identification and background information, professional experience and qualifications, previous positions, financial information, such as payment related information and shareholdings, and other personal information. If you connect to us from a social network, such as LinkedIn or Facebook, we will collect personal information from the social network in accordance with your privacy settings on that social network. The social network may provide us with information such as your name, profile picture, network, gender, username, user ID, age or age range, language, country, friends list, follower list, and any other information you have agreed it can share or that the social network provides to us. We will assume that such social network or other third parties are entitled to collect and share such personal information with us.
Sensitive Information. We may collect sensitive information about you when you use our Services. This information may include information such as your social security number, driver’s license number, state identification card number, passport number, financial account and credit card information in combination with any required security or access code, geolocation data, and racial and/or ethnic information. Any use of such information is limited to such purposes described to you at the time of collection.
How We May Use Your Personal Information
If you provide us with personal information, we will retain and use that information for certain limited purposes. For example, we will use your personal information to fulfill or respond to any requests that you make, such as contacting you to answer your questions, sending you related materials, sending any postal mail that you may request, or sending email alerts to you if you subscribe to receive them.
We process your personal information when you contact us, such as with questions, concerns, feedback, disputes, or issues. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of the Services. We also process your personal information to actively monitor, investigate, prevent, and mitigate any alleged or actual prohibited, illicit, or illegal activities in connection with our Services; investigate, prevent, or mitigate violations of our terms, agreements, or policies; and enforce our agreements with third parties and partners. We cannot perform our Services in accordance with our terms, agreements, or policies without processing your personal information for such purposes.
We are committed to ensuring your safety and continued enjoyment of our Services. To do so, we process your personal information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and monitor and verify your identity so that unauthorized users do not access your account with us or your information we otherwise hold. We cannot ensure the security of our Services if we do not process your personal information for security purposes.
We may provide you with third-party services, plugins, cookies and similar tracking technology, and other options to personalize your experience of our Services. Personalizing the Services may enhance your enjoyment and ease of use because we keep track of your preferences (e.g., your language selection, your time zone, etc.). Without processing your personal information for such purposes, you may not be able to access or personalize part or all of our Services.
To continue to provide you with our innovative Services, we collect information about the way you use and interact with our Services for research and development purposes. Research and development help us improve, build upon, and customize our Services. With respect to potential employment, we process your personal information when you seek employment with us to evaluate you as a candidate for the position.
Lastly, we use personal information to engage in routine marketing activities. We process your personal information to inform you about our Services, new legal and policy developments, relevant information in the industries we serve, and our marketing events (including by electronic means, such as email). To do so, we may process your contact information or information about your interactions with our Services to send you marketing communications; provide you with information about events, webinars, or other materials; deliver targeted marketing to you; and keep you updated about our Services. If you wish to opt out of receiving our email alerts or other emails from us at any time, simply follow the instructions for doing so included in the emails. We reserve the right to send you certain communications relating to the Website, such as service announcements or similar administrative or transactional messages, without offering you the opportunity to opt out of receiving them.
Sharing Your Personal Information
VMI does not sell your personal information. Moreover, we will only share or disclose your information as outlined herein.
We may sometimes use other businesses to perform certain services for us, such as maintaining the Website and our mailing lists, delivery of newsletters to subscribers and prospects, sending postal mail, payment processing, and providing marketing assistance and data analysis. We may provide personal information to those businesses when that information is necessary for them to complete a requested transaction or otherwise perform their duties. VMI will take reasonable steps to help ensure that these third-party service providers are obligated to protect personal information on VMI’s behalf. Moreover, we restrict our service provider’s use of information beyond what is strictly necessary to complete the requested service.
We reserve the right to disclose visitor information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against, someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other visitors, or anyone else that could be harmed by such activities. We also reserve the right to disclose visitor information when we believe that the law requires it.
Lastly, we will disclose your information to a person with your express consent or as required to complete the Services.
As noted above, VMI may collect general, non-personal, statistical information about the use of the Website, such as how many visitors visit a specific page on the Website, how long they stay on that page, and which hyperlinks, if any, they “click” on. We collect this information through the use of “cookies” and other tracking technologies, which are discussed in greater detail below. We collect this information to determine which areas of the Website are most popular and to enhance the Website for visitors. We may aggregate visitor data to describe the use of the Website to our existing or potential business partners or other third parties or in response to a government request. We may also aggregate preferences information that we collect from visitors for the same purposes. However, please be assured that this aggregate data will in no way personally identify you or any other visitors to the Website.
Cookies and Other Tracking Technologies
Tracking technologies may record information such as Internet domain and host names; IP addresses; browser software and operating system types; clickstream patterns; and dates and times that our Website is accessed. An IP address is a number that is automatically assigned to your computer whenever you are surfing the Web. Web servers, the big computers that “serve up” Web pages, automatically identify your computer by its IP address.
Links to Other Websites
We intend to take reasonable and appropriate steps to protect the personal information that you share with us from unauthorized access or disclosure. When you transmit personal information from your personal computer, tablet, or any other personal device to our servers, your information is protected by both a “firewall” (a combination of computer hardware and software that helps keep unauthorized visitors from accessing information within our computer network) and industry standard TLS (Transport Layer Security) encryption. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction, or inadvertent disclosure of your personal information.
We do not knowingly collect any personal information from children under 16. If we become aware that an individual under the age of 16 is submitting information without consent from their parent or legal guardian or as permitted under applicable law, we will delete the information as soon as possible from our database. If you believe we are collecting information about an individual under 16, please notify us immediately so that we can take appropriate action.
Your Information Choices
We take reasonable steps to ensure that your personal information is accurate, complete, and up to date. You may access and update your personal information that we hold by contacting us directly in accordance with the Contact Us details below. For your protection, we may need to verify your identity before implementing your request. We will try to implement your request as soon as reasonably practicable.
In your request, please make clear what information you would like to have changed, whether you would like to have your personal information suppressed from our database, or other limitations you would like to impose on our use of your personal information. However, please note that we reserve the right to refuse to act on a request that is unfounded, impracticable, or unreasonable.
The Firm will make reasonable efforts to honor any request you make to forgo contact with you in the future or delete your information. Please note that if you make an opt-out request, the Firm will retain your contact information to make efforts to ensure that you are not contacted in the future.
To the extent required by the CAN-SPAM Act, or other similar domestic and international regulation, commercial email messages will also provide you with an opportunity to opt-out of receiving this information. Please note that changes to your preferences may not be effective immediately.
Notice to California Residents
This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), below is a summary for the last twelve (12) months of the “personal information” categories, as identified and defined by the CCPA (see California Civil Code section 1798.140(o)), that we collect. The sections above discuss the reasons we collect personal information, where we obtain the personal information, and the other entities with which we may share the personal information. Under the CCPA, personal information is defined as any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”).
We generally collect the following categories of personal information in providing our Services:
Identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, software, and identification numbers associated with your devices;
Characteristics of protected classifications under California or federal law, such as gender;
Commercial information such as records of products or services purchased, obtained, or considered by you;
Internet or other electronic information regarding length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information;
Professional or employment-related information;
Your geolocation, to the extent you have configured your device to permit us to collect such information; and
Inferences about your preferences, characteristics, behavior and attitudes.
For more information about the personal information we collect and how we collect it refer to the language detailing our collection and use of information above. We collect personal information for the business purposes described in the “How We May Use Your Personal Information” section above. The CCPA defines a “business purpose” as the use of personal information for the business’s operational purposes, or other notified purposes, provided the use of personal information is reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected or another operational purpose that is compatible with the context in which the personal information was collected. The categories of other individuals or entities with which we may share your personal information are listed in the “Sharing Your Personal Information” section above.
California Privacy Rights
If you are a California “consumer” as defined in the California Consumer Privacy Act of 2018 (“CCPA”), you have discrete rights in relation to your personal information. These rights are not absolute and are subject to certain exceptions more fully set forth in the CCPA. For instance, we cannot disclose specific pieces of personal information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the personal information, your account with us, or the security of our network systems.
Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, delete or opt-out of sales.
Right to Know. You have the right to request in writing: (i) a list of the categories of personal information, such as name, address, email address, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third parties. In addition, you have the right to request: (i) the categories of personal information we have collected about you, (ii) the categories of sources from which personal information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared personal information, and (v) the specific pieces of personal information we hold about an individual.
Right to Access. You have the right to request a copy of the specific personal information we collected about you during the 12 months before your request.
Right to Delete. You have the right to request that we delete any personal information we have collected from you or maintain about you, subject to certain exceptions.
Right to Opt-Out of Selling. California residents have the right to opt-out of having their personal information sold. We do not sell your personal information.
To assert your right to know, access, or delete your personal information, please contact us in accordance with the Contact Us details below and indicate in the subject line “California Privacy Rights.” To confirm your identity, we may ask you to verify personal information we already have on file for you. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.
Rights under the GDPR/UK GDPR
If you are in the European Economic Area or the UK, you have various rights in relation to the processing of your personal information, depending on the relevant situation. These include the following rights:
Right to Access: You have the right to request confirmation as to whether or not your personal information is being processed by VMI and, if so, the right to receive a copy of it.
Right to rectify: You have the right to request the rectification of your personal information if you find that it is inaccurate and the right to have incomplete personal data completed.
Right to delete: You have the right to request we erase or delete your personal Information depending on the circumstances. For example, this right does not apply if the processing is necessary to establish, exercise, or defend legal claims.
Right to restrict: You have the right to request we restrict processing of your personal information.
Right to data portability: For processing carried out by automated means, you have the right to request a copy of your personal information provided to us, in a structured, commonly used, and machine-readable format.
Right to object: You have the right to object, on grounds relating to your particular situation, to the processing of your personal information. For example, you can object at any time to the processing of your personal information for direct marketing communications.
To assert the above rights, please contact us in accordance with the Contact Us details below and indicate in the subject line “GDPR/UK GDPR Privacy Rights.” To confirm your identity, we may ask you to verify personal information we already have on file for you. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.
Value(s) Management and Investing, Inc.
c/o Greenspoon Marder LLP
200 E. Broward Boulevard
Fort Lauderdale, FL 33301