Privacy Policy

Privacy Policy and Notice

Effective Date: 9.14.2020

Our website at https://www.crannmoradvisors.com (the “Website”) is owned and operated by CrannMor Advisors, LLC. (“CrannMor,” “we,” “us,” and/or “our”). This Website has been created to provide information about our company and the services we provide (the “Services”) to our clients and Website users (“you,” “your”). This Privacy Policy is CrannMor’s policy with respect to information, including personally identifiable data (“Personal Data”), and other information that is collected from visitors of the Website, including you, and our clients.

If you have questions or complaints regarding our Privacy Policy or related practices, please contact us.

INFORMATION COLLECTED BY US

When you interact with us through the Website or otherwise as our client, we may collect Personal Data and other information from you, as further described below:

Personal Data That You Provide Through the Website: We may collect Personal Data from you when you voluntarily provide such information, such as when you register for access to certain of our Services (including, without limitation, your name, email address, telephone number and mailing address) and/or when you wish to use certain of our Services (including, without limitation, your bank account numbers and other financial information, date of birth and/or social security number) or when you contact us with inquiries or respond to one of our surveys.

By voluntarily providing us with any Personal Data, you thereby consent to our use of it in accordance with this Privacy Policy. If you provide us any Personal Data, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of CrannMor and any authorized third parties referred to herein.

Non-Identifiable or Aggregated Data: When you interact with CrannMor through the Website or any of our Services, we may receive and store certain personally non-identifiable information. Such information, which may be collected passively using various technologies, cannot presently be used to specifically identify you.

As is true of most websites, we may gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. CrannMor may store such information itself, or such information may be included in databases owned and maintained by CrannMor and/or any of its affiliates, agents and service providers. This Website may use such information and pool it with other information to track, for example, the number of visitors to our Website, the number of visitors to each page of our Website, the domain names of our visitors’ Internet service providers, and how our users use and interact with the Services. Also, in an ongoing effort to better understand and serve the users of the Services, CrannMor often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us.

This research may be compiled and analyzed on an aggregate basis. CrannMor may share this non-identifiable and aggregate data with its affiliates, agents and business partners, but this type of non-identifiable and aggregate information does not identify you personally. CrannMor may also disclose aggregated user statistics to third parties.

We may also use a technology called “cookies” in operating our Website. A cookie is a piece of information that the computer or server that hosts our Website gives to your browser when you access the Website. Our cookies may help provide additional functionality to the Website and help us analyze Website usage more accurately. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off.

The use of cookies by any of our affiliates or service providers is not covered by our privacy policy. We do not have access or control over these cookies. Our partners may use session ID cookies to make it easier for you to navigate our site and access or use our Services.


OUR USE OF YOUR PERSONAL DATA AND OTHER INFORMATION

CrannMor expects to use the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, as another example, if you provide Personal Data in order to obtain access to any of our Services, we may use your Personal Data to provide you with access to such Service and to monitor your use of such Service. Furthermore, we also may obtain information about you from third party sources to verify your identity so we can properly process your requests and prevent fraud.

CrannMor and any of its subsidiaries and affiliates (the “Related Companies”) also may use your Personal Data and other personally non-identifiable information collected through the Website to help us improve the content and functionality of the Website, to better understand our users and to improve any of our Services. CrannMor and any of its Related Companies may use this information to communicate with you regarding any Service or to tell you about services we believe will be of interest to you. If at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below. Note however that we may send you, as a user of any of our Services, administrative communications that may be reasonably necessary to such Service, such as payment, corporate or service notifications, among other things. If CrannMor intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to, or at, the time at which such Personal Data is collected.


DISCLOSURE BY US OF YOUR PERSONAL DATA AND OTHER INFORMATION

We may share your Personal Data with third parties only in the ways that are described in this Privacy Policy. We consider this Personal Data to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:


Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or other similar event, Personal Data may be part of the transferred assets, and you will be notified through email and/or a prominent notice on our Website of any change in ownership or uses of your Personal Data, as well as any choices you may have regarding your Personal Data.


Related Companies: We may also share your Personal Data with any of our Related Companies for purposes consistent with this Privacy Policy.

Agents, Consultants and Related Third Parties: CrannMor, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, ID verification, processing applications, processing payments and providing transactions. We may also use third party vendors to help us detect and protect against fraudulent activity. When we employ another company to perform a function, we only provide them with the information that they need in order to perform that function. These companies will be authorized to use your Personal Data only as necessary to provide these services to us or in accordance with their own privacy policies.


Legal Requirements: CrannMor may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary in order to (1) comply with a legal obligation, (2) protect and defend any of CrannMor’s rights or properties, (3) act in urgent circumstances to protect the personal safety of users of the Website or other members of the public, (4) protect users of the Website or other members of the public against fraud or other harm or (5) protect against legal liability.


YOUR ACCESS TO, AND CONTROL OVER, INFORMATION

If your Personal Data changes, or if you no longer desire our Services, you may correct, update, amend, delete or request deletion by making the change in your registered account settings page, to the extent applicable, or by contacting us. You may also contact us if you would like to see what Personal Data we have about you, if any. We will respond to your request to access within 30 days. Please note that some emails are transactional in nature and cannot be opted out of.

We will retain your Personal Data, at a minimum, for as long as needed to provide you any of our Services. We will retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

When you sign up for any of our Services or other communications from us, we may send periodic emails to you regarding our Services or to tell you about other services we believe will be of interest to you. Out of respect for your privacy, you may choose to stop receiving such marketing emails by contacting us.

SECURITY

No method of transmission of any of your Personal Data or other information over the Internet, nor any method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of your Personal Data or other information. If you have any questions about security on our Website or if you feel our Privacy Policy is not being followed, you can contact us here.


EXCLUSIONS

This Privacy Policy does not apply to any Personal Data collected by CrannMor other than Personal Data collected through the Website or any of our Services. This Privacy Policy will not apply to any unsolicited information you provide to CrannMor through this Website or through any other means. This includes, but is not limited to, information posted to any public areas of the Website, such as any bulletin boards (collectively, “Public Areas”), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information will be deemed to be non-confidential, and CrannMor will be free to reproduce, use, disclose, distribute and exploit such Unsolicited Information without limitation or attribution.


CHILDREN

CrannMor does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Website. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on this Website without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to CrannMor through this Website, please contact us, and we will endeavor to delete that information from our databases.


LINKS TO OTHER WEB SITES

This Privacy Policy only applies to the Website. This Website may contain links to other websites not operated or controlled by CrannMor (the “Third Party Websites”). The policies and procedures we described here do not apply to the Third Party Websites. The links from this Website do not imply that CrannMor endorses or has reviewed the Third Party Websites. We suggest contacting those websites directly for information on their privacy policies.


OTHER TERMS AND CONDITIONS

Your access to, and use of, this Website is subject to the [Terms of Use]


CHANGES TO CRANNMOR’S PRIVACY POLICY

We may update this Privacy Policy to reflect changes to our practices. If we make any material changes we will notify you by email (sent to the email address specified to us in writing) or by means of a notice on this Website prior to the change becoming effective. We encourage you to periodically review this webpage for the latest information on our privacy practices.


WHAT ADDITIONAL PRIVACY RIGHTS MAY YOU HAVE?


California Residents

For California residents, the California Consumer Privacy Act (“CCPA”) provides certain rights regarding the information that we collect. In particular, you may have the following rights:


Notification of Personal Information Collection

We collect, use, and process your Personal Data, as described within this Privacy Policy and Notice, for expected internal reasons, legal obligations, servicing a transaction, or providing a Service. In addition, we may use your information to detect security and fraud as well as technical support functions.


Further detail on categories of information and Personal Data collected about you, sources of Personal Data, purposes for collecting Personal Data, as well as third parties to whom we disclose Personal Data, are described within this Privacy Policy and Notice.


Access to Specific Pieces of Information

You may request that we disclose certain information to you about our collection and use of your Personal Data over the past 12 months.

Upon your valid request, we will provide a report outlining specific pieces of Personal Data collected about you, the consumer, that you have requested. You may make this request a maximum of two times within a twelve-month period.


Deletion of Personal Information

You may request that we and our service providers delete any Personal Data that we collect from you. Our obligation to comply with this request is subject to exemptions. If you are interested in requesting deletion of your Personal Data, please note that we may have a legal reason to retain your information, as permitted by the CCPA, in accordance with the original reason provided for collecting and processing Personal Data as described within this document.

We retain Personal Data, at a minimum, as long as necessary to meet legal and regulatory requirements. Retention may be extended if we are required to preserve Personal Information in connection with litigation, investigations and proceedings.


Opt Out of Sale

While, under the CCPA, you may request that we do not sell your Personal Information, because we do not sell any Personal Information, there is no need to opt out of sales.


Anti-Discrimination

We will not discriminate against you for exercising your CCPA rights.

In order to provide a response, CrannMor may ask that you provide clarifying or identifying information to verify your request. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity and confirm that the Personal Data relates to you.

You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request.

Agents who make requests on behalf of individuals will be required to verify their authority to make the request by submitting written authorization from the individual. We will not honor any requests from agents until authorization is verified.

To allow us to process your CCPA request, please submit your request to kmaher@crannmoradvisors.com.

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