Last Revised: 5/15/2020
This Policy describes the types of information we may collect from you or that you may provide when you visit the website www.theseidenstrategies.com (the “Site”) and our practices for collecting, using, maintaining, protecting and disclosing that information. This Policy should be read in conjunction with our Site Terms and Conditions into which this Policy is incorporated by reference.
This Policy applies to information we collect on the Site or in email and other electronic messages between you and the Site. It does not apply to information collected by us offline or through any other means, including on any other website operated by a third party.
1. Data Controller: Who we are.
The Seiden Strategies is responsible for this Policy and is a “Controller” for purposes of processing personal data and as defined in the General Data Protection Regulation (“GDPR”). We are responsible for operating and maintaining the Site.
2. Goods and Services: What we offer.
The Site is a platform through which The Seiden Strategies provides information on its products and services, and provides data, material, content or information relating to the fields of finance, including but not limited to securities trading and financial markets, credit management, and managing portfolio risks (collectively, the “Content”).
3. Personal Data: What we collect.
We only collect basic personal data about you or from you, and do not intentionally collect any sensitive data. The personal data we collect may include:
- Your first and last name
- Your company name
- Your email address
- Your mailing addres
- Mobile device ID
- Payment information (i.e., credit card numbers)
- Comments or messages provided in text boxes
- Email correspondence with us
Automatic collection of data. As you navigate through and interact with Our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
- Details of your visits to our Site, including traffic data, location data, and other communication data and the resources that you access and use on the Site.
- Information about your computer and internet connection, including your IP address, operating system and browser type.
The technologies we or our trusted third parties use for this automatic data collection may include:
- Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior. If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of our third-party marketing partners may use Web Beacons to track your interaction with online advertising banners on our Site. This information is only collected in aggregate form and will not be linked to your personal information. Please note that any image file on a webpage can act as a Web Beacon.
- Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the personal information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.
- Third-party Websites and Services. We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on our Site and also on the websites where our marketing communications are appearing. For example, we may collect data where our banner advertisements are displayed on third-party websites.
Do Not Track Disclosure. We do not currently track customers over time and across third party websites to provide targeted advertising and therefore we do not respond to Do Not Track (DNT) signals. The information we collect automatically is statistical data and does not include personal information. Notwithstanding the foregoing, we reserve the right to track customers over time and across third party websites in the future. To the extent we do track customers over time and across third party websites, we will not respond to DNT signals.
4. Purposes: Why we need your personal data.
We use information that we collect about you or that you provide to us, including any personal data:
- To present our Site and its contents to you.
- To provide you with information, products or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and The Seiden Strategies including for billing and collection.
- To notify you about changes to our Site or any products or services we offer or provide though it.
- In any other way we may describe when you provide the information.
- For any other purpose with your informed consent.
5. Processing: What we do with your personal data.
All personal data we process is processed by our staff or trusted third parties in the United States of America and other countries.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal data that we collect or you provide as described in this Policy:
- To our trusted subsidiaries and affiliates.
- To contractors and service providers we use to support our business.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of The Seiden Strategies’ assets, whether as an ongoing concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by The Seiden Strategies about our Site users is among the assets transferred.
- To fulfill the purpose for which you provide the personal data.
- For any other purpose disclosed by us when you provide the personal data.
- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Terms and Conditions available at: www.theseidenstrategies.com
- If we believe disclosure is necessary or appropriate to protect the rights or the property of The Seiden Strategies, our customers or others.
We may otherwise disclose your personal data only for purposes disclosed in this Policy or on the Site, as required by law, or with your informed consent.
6. Organizational and Technical Safeguards: How we protect your personal data.
Processing of personal data happens in strict accordance with The Seiden Strategies’ data governance program, which includes implementing reasonable organizational and technical safeguards to protect personal data from unauthorized use, disclosure, or destruction. Such organizational safeguards include binding our trusted third parties to contracts and requiring the same or better organizational or technical safeguards for your personal data.
We have implemented measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the 100% security of your personal data transmitted to our Site. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
7. Retention: How long we keep your personal data.
We only retain your personal data as required to complete the processing we have disclosed in this Policy.
8. Marketing: What we would also like to do with your personal data.
With your consent, we would like to use your contact information to inform you about our products and services. This contact information is not shared with third parties or used for other purposes, and you can unsubscribe from any such marketing via the unsubscribe option in any such marketing email you receive from us.
9. What are your rights?
You can exercise any of the following rights by directly making changes in our Site or notifying us as described below.
- Access. You can access and verify what personal data our Site currently contains by logging into our Site and visiting your account profile page.
- Correction or Rectification. You may send an email to email@example.com to request that we correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
- Restrict Processing. When applicable, you may restrict the processing of your personal data within our Site by submitting a request via email to firstname.lastname@example.org. When such restrictions are not possible, The Seiden Strategies will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data.
- Object to Processing. When applicable, you have the right to object to some of the processing of your personal data by submitting a request via email to email@example.com. When such objections are not possible, The Seiden Strategies will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data.
- Portability. Upon request, and when possible, The Seiden Strategies can provide you copies of your personal data. When such a request cannot be honored, The Seiden Strategies will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent.
- Withdraw Consent. At any time, you may withdraw your consent to The Seiden Strategies’ processing of your personal data through the Site by notifying us via email at firstname.lastname@example.org. Using the same email address associated with your Site account, simply type the words “WITHDRAW CONSENT” in the subject line of your email.
Upon receipt of such a withdrawal of consent, The Seiden Strategies will confirm receipt, proceed to stop processing your personal data and erase your data in accordance with this Policy.
- Erasure. If you should wish to cease use of the Site and have your personal data deleted from the Site, please notify The Seiden Strategies at the email address below. The Seiden Strategies will confirm receipt and erase your personal data.
- Submit complaints or questions. If you wish to raise a complaint on how we have handled your personal data, you can contact us as described below. If you reside in an European Union member state, you may also lodge a complaint with the supervisory authority in your country.
10. Will this Policy change?
If we make material changes to how we process your personal data, we will notify you by email to the email address specified in your account and/or through a notice on our Site.
11. Contact us.
Questions or concerns about this Policy and our processing of your personal data can be directed to: email@example.com