PRIVACY POLICY

Effective Date: April 20, 2020

This “Privacy Policy” describes how HFI Consulting LLC and our subsidiaries and affiliates (collectively, “Cultivate Advisors”, “we”, “us”, or “our”) collect, use, and share your personal information in connection with the https://www.cultivateadvisors.com/ website and any other digital properties that link to this Privacy Policy (collectively, the “Site”), our marketing communications, and any related services, sales, marketing, or events (together with the Site, the “Service”), and the rights and choices available to individuals with respect to their information.


1.  COLLECTION OF PERSONAL INFORMATION

1.1  Personal information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

  • Contact details, such as your first and last name, email address, mailing address, residence, postal code, and phone number.
  • Business data, such as the company you work for, company description, company website, and job title.
  • Profile data, such as your username, profile picture, birthday, industry, social media handles, and password that you set to establish an online account with us.
  • Communications that we exchange, including when you contact us with questions, feedback, or otherwise.
  • Payment and transactional data, such as the information needed to complete your orders and registrations on or through the Service (including name, credit card information, bank account number, billing and shipping information), and information about services you have purchased from us.
  • Marketing data, such as your preferences for receiving communications about our products, services, activities, events, and publications, and details about how you engage with our communications.
  • Other information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

1.2  Personal information from other sources. We may obtain personal information about you from other sources, such as:

  • Data providers, such as information services and data licensors.
  • Public sources, such as social media platforms.
  • Business partners, such as joint marketing partners and event co-sponsors.

1.3  Personal information from third party platforms. If you connect or otherwise sign into the Service through a social media or other third party platform, such as Google, we may collect information from that platform. You may also have the opportunity to provide us with additional information via the third party platform, such as a list of your friends or connections and your email address. You can read more about your choices in connection with linked third party platforms in the “Your Choices” section, below.

1.4  Personal information collected automatically. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your activity over time on our Service and other sites and online services, such as:

  • Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, the website you visited before browsing to our website, and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

1.5  Cookies and similar technologies. Like many online services, we use cookies and similar technologies to facilitate our automatic data collection. For more information, see our Cookie Policy.

1.6  Personal information about others. Users of the Service may have the opportunity to refer colleagues or other contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.


2.  USE OF PERSONAL INFORMATION


We may use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

2.1  To provide our products and services.​ For example, we may use your personal information to:

  • provide you with the content, features, products and services that you request;
  • establish and maintain your account on the Service;
  • process your transactions;
  • communicate with you about the Service (including by sending announcements, updates, security alerts, and support and administrative messages);
  • display your content or share your information with other companies or users;
  • understand your interests, personalize your experience on the Service, and deliver information about products and services relevant to your interests;
  • respond to your inquiries and requests for customer support, including to investigate and address your concerns and monitor and improve our responses; and
  • enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in.

2.2  For research and development. We use personal information to understand and analyze the usage trends and preferences of our users to make our Service and other offerings better and develop new features and functionality.

2.3  To create anonymous data. We may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

2.4 For marketing and advertising. We, our business partners and our third party advertising partners may collect and use your personal information for direct marketing and interest-based advertising purposes.

  • Direct marketing. We may send you Cultivate Advisors-related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described in the “Opt-out of marketing communications” section below.
  • Interest-based advertising. We also contract with third-party advertising companies and social media companies to display ads on our Service and other sites. These companies may use cookies and similar technologies to collect information about you (including the device data and online activity data described above) over time across our Service and other sites and services or your interaction with our emails, and use that information to serve ads that they think will interest you. You can learn more about your choices for limiting interest-based advertising, in the “Advertising choices” section below.

2.5  To comply with laws and regulations. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

2.6  For compliance, fraud prevention, safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of our Service, products and services, business, databases and other technology assets; (b) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Service; and (e) prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

2.6  With your consent. In some cases we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.


3.  SHARING OF PERSONAL INFORMATION


We may share your personal information with the following third parties and as otherwise described in this Privacy Policy or at the time of collection:

3.1  Related companies.  Our subsidiaries and affiliates, for purposes consistent with this Privacy Policy.

3.2  Business transferees.  If we sell all or part of its business or make a sale or transfer of assets or are otherwise involved in a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Cultivate Advisors or our affiliates (including, in connection with a bankruptcy or similar proceedings), we may transfer your personal information to a third party as part of that transaction, including at the negotiation stage.

3.3  Authorities and othersLaw enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate to comply with law or for the compliance, fraud prevention and safety purposes described above.

3.4  Service providersCompanies and individuals that perform services on our behalf that provide services on our behalf or help us operate the Service or our business.  Among other things service providers may help us perform website hosting, maintenance services, database management, web analytics, billing, payment processing, fraud protection, or marketing.

3.5  Advertising partners.  Third party advertising companies that collect information about your activity on the Service and other online services to help us advertise our services, and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms.

3.6  Business partnersOur business partners, such as those that have joined our programs, participate in our events, or jointly offer content, promotions and other service offerings with us.

3.7  Third Party Platforms. Social media and other third party platforms that you connect to the Service.  When you choose to login using or otherwise connect these platforms to the Service, we will share your personal information to facilitate the connection.  Please note, we do not control the third party’s use of your personal information and you should review the privacy policy of the entities that provide these platforms.

3.8  Other Users and the Public The Service may provide you with the opportunity to post or make available content, messages, and other information to other users of the Service or the public.  For example, you may be able to post your content in a forum on the Service or participate in a message board.  We do not control how other users or third parties use any personal information that you make available to them. Please be aware that any information you post publicly can be cached, copied, screen captured or stored elsewhere by others (e.g., search engines) before you have a chance to edit or remove it.

3.9  Professional Advisors.  We may disclose your personal information to our professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.


4.  YOUR CHOICES


You can make the following choices with respect to your personal information.

4.1  Access or update your personal information. If you have registered for an account with us, you may review and update certain account information by logging into your account.

4.2  Opt-out of marketing communications.  You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at [email protected].  You may continue to receive service-related and other non-marketing emails. If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message.

4.3  Third party platforms.  If you choose to connect to the Service through your account on a third party platform like Google, you may be able to use your settings in your account with that platform to limit the information we receive from it.  If you revoke our ability to access information from a third party platform, that choice will not apply to information that we have already received from that third party.

4.4  CookiesMost browsers let you remove and/or stop accepting cookies from the websites you visit.  To do this, follow the instructions in your browser’s settings. For more details, see the “Your Choices” section of our Cookie Policy.

4.5  Advertising choices. You may opt-out of interest-based advertising. For more details, see the “Your Choices” section of our Cookie Policy.

4.6  Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

4.1  Declining to provide information. We need to collect personal information to provide certain services.  If you do not provide the information requested, we may not be able to provide those services.


5.  Security


No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information.


6.  OTHER SITES AND SERVICES


The Service may contain links to other websites and online services operated by third parties.  These links are not an endorsement of, or representation that we are affiliated with, any third party.  In addition, our content may be included on web pages or online services that are not associated with us.  We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information.  We encourage you to read the privacy policies of the other websites and online services you use.


7.  INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION


Cultivate Advisors is based in the United States of America.  If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide personal information to us, please note that any personal information that you provide to us may be transferred to the United States of America.  By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in any applicable terms of service. 


8.  CONTACT US


Please direct any questions or comments about this Policy or privacy practices to [email protected].  You may also write to us via postal mail at:


   HFI Consulting LLC

   Attn: Privacy

   549 West Randolph, Suite 400

   Chicago, IL 60661United States


9.  NOTICE TO CALIFORNIA RESIDENTS


Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with Cultivate Advisors are entitled to ask us once a year for information regarding the personal information we have shared, if any, with third parties for their direct marketing purposes. If you are a California resident and would like to submit such a request, please submit your request in writing to the address listed in the section titled “CONTACTING US” above and include the words “Shine the Light” in your correspondence. The request must include your name, street address, city, state, and ZIP code and an attestation that you are a California resident. We are not responsible for requests that are not labeled or sent properly, or that do not have complete information.


9.  NOTICE TO EUROPEANS


The information provided in this “Notice to European Users” section applies only to individuals in the European Union, the European Economic Area or the United Kingdom (collectively, “Europe”).


Personal information. Except as otherwise specified, references to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.


Controller. The controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation is HFI Consulting LLC, 549 West Randolph, Suite 400, Chicago, IL 60661, United States.


Legal bases for processing. The legal bases of our processing of your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it. However, the legal bases we typically rely on are set out in the table below. We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, contact us at [email protected].


Processing purpose (see the “USE OF PERSONAL INFORMATION” section above for details about each processing purpose)

Legal basis

To provide our products and services

Processing is necessary to perform the contract governing our operation of the Sites or the provision of the Service, or to take steps that you request prior to engaging our services.  Where we cannot process your personal data as required to operate the Service on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interest in providing you with the products or services you access and request. 

For marketing and advertising

Processing is based on your consent where that consent is required by applicable law.

Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business, and showing you tailored relevant content.

For research and development

To create anonymous data

For compliance, fraud prevention and safety

These activities constitute our legitimate interests.

To comply with laws and regulations

Processing is necessary to comply with our legal obligations.

With your consent

Processing is based on your consent.  Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Service. 


Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.


Sensitive personal information. Unless we specifically request it, we ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us.


Retention. We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.


Your rights. European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.
  • Correct. Update or correct inaccuracies in your personal information.
  • Delete. Delete your personal information.
  • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
  • Restrict. Restrict the processing of your personal information.
  • Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.


You may submit these requests by email to [email protected] or our postal address provided in the “CONTACTING US” section above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here


Cross-Border Data Transfer. If we transfer your personal information out of Europe to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. Please contact us at [email protected] for further information about any such transfers or the specific safeguards applied.




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