Gresham Investment Management LLC, its subsidiaries, including its affiliated investment advisers and funds (together, the “Company”, “us” or “we”), consider your privacy our utmost concern. This privacy notice (the “Notice”) contains information about how the Company collects, uses, and shares Personal Information, as defined by the California Consumer Privacy Act (“CCPA”).
1.1 This Notice applies to our website. This Notice is for California residents only pursuant to the CCPA.
1.2 The CCPA defines Personal Information broadly to mean 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.
1.3 Please note that much of the Personal Information we collect about California residents is not covered by this Notice. The CCPA includes certain exemptions that may apply to our use or collection of your Personal Information and it is possible that not all Personal Information that we collect from you or about you is covered by the CCPA or this Notice. For example:
2.1 We may collect, use, or share Personal Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or a member of your household. The categories of Personal Information we may collect, use, or share include, but are not limited to:
3.1 We may obtain your Personal Information:
4.1 We use your Personal Information for our business and commercial purposes, including:
5.1 We do not currently sell your Personal Information. The CCPA defines the term “sale” very broadly. In the past twelve months, we may have disclosed the following categories of Personal Information to third parties that provide services to us, such as website advertising and analytics services. Such disclosures may be considered a sale for purposes of the CCPA:
5.2 We share your Personal Information for business purposes and in the last twelve months we may have shared the categories of Personal Information listed in Section 2 for a business purpose. For example, we share Personal Information with our affiliates, with entities that provide marketing services to us, and with our business partners, service providers and vendors. We may share your Personal Information with third parties and endeavor to ensure that they use it only for those services requested and keep it confidential.
5.3 We may share any of the Personal Information described in this CCPA Notice with third parties as part of or in connection with a sale, merger, consolidation, change of control, transfer of assets or reorganization of all or part of our business.
5.4 We may additionally share Personal Information in connection with litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving the Company or the clients of the Company, or as otherwise required by law.
6.1 As a California resident, you have the right to know how we have collected, used, and shared your Personal Information in the last twelve months. Specifically, you have the right to request to know:
6.2 In addition, you have the right to request that we delete your Personal Information.
6.3 You have a right to not be discriminated against for exercising these rights.
7.1 You have the right to request that we disclose to you the categories and/or specific pieces of Personal Information that we have collected about you. When you make a request, we will first take steps to verify your identity. Once we have verified your identity, we will provide information from our records for the preceding twelve months. Please note, we may decline your request if we are unable to verify your identity.
7.2 You have the right to request that we delete your Personal Information. When you make a request, we will first take steps to verify your identity. Once we have verified your identity, we will delete your Personal Information from our records unless an exception to your deletion request applies or we are unable to verify your identity. We may deny your request to delete Personal Information in whole or in part if retaining the information is necessary for us or our service providers to:
7.3 To submit a request to know or a request to delete as described above, please call 866-887-1975 or send an email to email@example.com.
7.4 You can block cookies by activating the setting on your browser that allows you to refuse all, or some, cookies. If you block all cookies you may find that parts of our website does not work properly, or you may not be able to access our website at all.
8.1 We only respond to requests that you make which are “verifiable.” To verify your requests, we may require authentication of you or the authorized agent acting on your behalf that is reasonable in light of the nature of the personal information requested. We may need additional information from you to verify your request.
8.2 In order to verify your request, we may need to obtain additional information about you to match the information we already have about you. If you provide us with new personal information that we did not already have about you, we will use it solely for the purposes of verifying your request. We will let you know if we need more information from you to verify your request. Please reply to our requests promptly.
8.3 If we cannot verify your request, we will let you know.
We will occasionally update this Notice to reflect new legislation or industry practice and Company changes. We encourage you to review this Notice periodically to be informed of how we collect, use and share your Personal Information.