Effective: February 1, 2020
This Policy applies only to information collected through the Site and therefore does not apply to data we collect in other contexts, such as when you invest with us or communicate with us about your investments. But if you are a client of IR+M, our handling of your nonpublic personal information also may be subject to the terms in our separate financial privacy notice, which can be accessed here. If you are a California resident, you may have additional rights available to you under the California Consumer Privacy Act (“CCPA”), which you can read about in our CCPA addendum below.
What information we collect and maintain about you
We collect personal and other information from you directly when you provide it to us through the website. We may also automatically collect certain information about you and your computer, smartphone, or other device when you use, access, or interact with our Site.
Personal Information. You can visit the Site without submitting any information that we can use to identify you personally. However, if you use certain features on the Site, such as the “Contact Us” feature, or when you submit an application for a position with us, you will be required to provide personal information. Such information could include, for example, your name, email address, phone number, or resume. Our online contact form also contains a “comments” field through which you may submit additional personal information.
Web log data. When you use the Site, we automatically receive and record certain information from your computer (or other device) and your browser. This may include such data as your IP address and domain name, the pages you visit on the Site, the date and time of your visit, the files that you download, the URLs from the websites you visit before and after navigating to the Site, your software and hardware attributes (including device IDs), your general geographic location (e.g., your city, state, or metropolitan region), and certain cookie information (see below). To obtain such information, we may use web logs or applications that recognize your computer and gather information about its online activity.
Web beacons. The Site or the emails that you receive from IR+M may use an application known as a “web beacon” (also known as a “clear gif” or “web bug”). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include personal information. For example, it can allow an email sender to determine whether a user has opened a particular email.
Third-party online tracking. We also may partner with certain third parties to collect, analyze, and use some of the personal and other information described in this section. For example, we may allow third parties to set cookies or use web beacons on the Site or in email communications from us.
How we use your information
IR+M uses the information that we collect for a variety of purposes. These purposes include, for example: to respond to your questions or requests concerning the Site or other services offered by us; to fulfill the terms of any agreement you have with us; to fulfill your requests for our services or otherwise complete a transaction that you initiate; to send you information about our services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications, including promotional emails and advertising; to deliver confirmations, account information, notifications, and similar operational communications; to improve your user experience and the quality of our products and services; to comply with legal and/or regulatory requirements; and to manage our business.
In addition to the purposes above, we use the information that we collect automatically through the Site for such purposes as: counting and recognizing visitors to the Site; analyzing how visitors use the Site and various Site features; improving the Site and enhancing users’ experiences with the Site; creating new products and services or improving our existing products and services; enabling additional website analytics and research concerning the Site; engaging in interest-based advertising (as described below); and managing our business.
IR+M may link information gathered through the Site with information that we collect in other contexts. But in that event, we will handle the combined information in a manner consistent with this Policy.
With whom we share your information
We share your information with other parties for a variety of purposes, as described below.
IR+M does not respond to Do Not Track Signals at this time.
Third-party service providers. IR+M uses third-party service providers that perform services on our behalf, including web-hosting companies, mailing vendors, and analytics providers. These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above.
We may share your information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.
Legal purposes. We also may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary:
- To comply with applicable law or a court order, subpoena, or other legal process;
- To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
- To establish, protect, or exercise our legal rights or defend against legal claims;
- To facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.
Aggregated information. From time to time, IR+M may also share aggregated information about Site users, such as by publishing a report on trends in the usage of the Site. Such aggregated information will not identify you personally.
You may opt out of receiving marketing emails from us by following the instructions in those emails or by emailing us at firstname.lastname@example.org.
We employ physical, technical, and administrative procedures to safeguard the personal information we collect online. However, no website is 100% secure, and we cannot ensure or warrant the security of any information you transmit to the Site or to us, and you transmit such information at your own risk.
The information that we collect through or in connection with the Site is transferred to and processed in the United States for the purposes described above. IR+M also may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Site or by providing any personal or other information to us, you expressly consent to such transfer and processing.
Content on this Site is directed at individuals over the age of 18 and is not directed at children under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13.
Changes to this Policy
IR+M may make changes to the Site in the future and as a consequence will need to revise this Policy to reflect those changes. IR+M will post all such changes on the Site, so you should review this page periodically. If we make a material change to the Policy, you will be provided with appropriate notice.
How to contact us
Should you have any questions or concerns about this Policy, you can contact us at email@example.com or by mail at the following address:
Income Research & Management
100 Federal Street, 30th Floor
Boston, MA 02110
Attention: Privacy Office