Effective September 13, 2018

HoganTaylor, (“we,” “us,” “our,” or “HT”) is committed to protecting the privacy of anyone who visits our websites or registers to use our services or to attend our events. This Privacy and Cookie Policy (the “Notice”) is designed to tell you about our practices regarding collection, use, storage, and disclosure of information we collect via our websites or any of our mobile applications and the consent required for those activities. This Notice applies to any of our websites, applications, products, software, or services that display a link to this Notice (the “Websites”). Please be sure to carefully read this Notice in its entirety before using or submitting information to this Website.

For the avoidance of doubt, this Notice applies to Personal Identifiable Information (PII) collected through this Website, but not to HoganTaylor’s offline business activities.

What Information This Notice Covers

Registration is not required for you to use our Website. If you are merely a visitor, we do not collect any Personal Identifiable Information about you, except to the limited extent through the use of cookies, which are described below. However, there may be circumstances in which you choose to register and receive ongoing updates from HoganTaylor. In these cases, HoganTaylor may contact registrants to invite them to special events, provide them with information about our services, publications and products, or for other marketing purposes.

For example, you may choose to register for:

  • Email alerts
    HT offers an email alert service to website visitors, in which we send subscribers email updates when new information is added to our Website. If you decide to subscribe, we will collect basic contact information about you, such as your name and email address.
  • Surveys
    HT may conduct surveys via our Website. Survey participants may be asked for Personal Identifiable Information (name, contact information, etc.) in addition to the opinions or feedback. The type of information collected in surveys will vary.
  • Thought leadership registration
    HT occasionally requires registration in exchange for our thought leadership: white papers, articles, studies, reports, survey analysis, booklets, etc. Your Personal Identifiable Information may be requested in registration forms and the type of information collected from you will vary. HT reserves the right to distribute certain thought leadership materials only to those who supply the requested information.
  • Event registration
    HT facilitates event registration via our Website or, at times, via third party websites. Personal Identifiable Information may be collected via event registration forms and the type of information collected will vary. HT may share registrant information with third parties in association with the event.Examples of “third parties” include hotels, sponsors or co-sponsors, promoters, event organizers (including via third party websites), speakers, panelists, etc. Please check the details provided at individual events to understand fully how your information will be used and retained.
  • HT Client Portal
    If you have been given access rights to HT Client Portal by your HT contact, we would recommend you take note of the full privacy notice associated with this service. You will have access to the notice once you log onto HT Client Portal.
  • myPortal
    If you have been given access rights to myPortal by your HT contact, we would recommend you take note of the full privacy notice associated with this service. You will have access to the notice once you log onto myPortal.
  • Job Applicants
    If you have applied for employment with HoganTaylor, the Personal Identification Information submitted with your job application will be added to our recruitment system and used for recruitment and other customary human resources purposes.

If you have registered on our Website, your Personal Identifiable Information will be stored in our customer relationship management (CRM) system. Data of registrants who have been out of active use for 24-months will be deleted from our CRM system. Refer to specific privacy statements on the recruitment system, event registration sites, HT Client Portal and myPortal for the applicable retention period for these initiatives.

If you have opted out from receiving future HT thought leadership, event invitations or firm communications your contact details will remain on our opt-out list to prevent you from receiving any further publications or firm communications from HT. Note this does not apply to financial statements.

Controlling your Personal Information

HT does not collect or compile Personal Identifiable Information obtained from our Website for dissemination or sale to outside parties for consumer marketing purposes or host mailings on behalf of third parties.

You are legally entitled to request details of the Personal Identifiable Information we are holding about you. HT provides you the ability to keep your Personal Identifiable Information accurate and up-to-date. If at any time you would like HT to rectify, erase or restrict the processing of your personal information, or you would like to obtain confirmation whether or not your Personal Identifiable Information is processed by HT, access your personal information, exercise your right to data portability or withdraw your consent to processing, please contact us.

Client Personally Identifiable Information

If you are our client, we may collect certain Personally Identifiable Information from you, including, without limitation, Your name, address, Social Security number (SSN), Employer Identification Number (EIN), tax identification number, age, corporate name and structure, internal accounting methods, financial status, assets, income, tax information, retirement and estate plan information, transaction history, account balance, payment history, investment objectives, marital status, family relationships and other personal information. This information may also be secured from the sources described below and is subject to the conditions stated below:

  • Sources
    The personally information referenced in this paragraph may be secured or received from sources such as (i) Your transactions with us, our affiliates and third parties; (ii) Your broker-dealer, investment advisor or financial representative; (ii) Your inquiries by mail, telephone, email or face-to-face conversations; (iii) interviews with any of the foregoing parties; and (iv) agreements, applications, forms and other documents received from you or any of the foregoing parties; and (v) information you submit voluntarily to us.
  • Disclosure
    Except as stated in this Notice, we will not sell, license, transmit, or disclose your personal information outside of HT.
  • Internal Use
    We restrict access to such Personally Identifiable Information. We maintain physical, electronic and procedural safeguards to protect such Personally Identifiable Information.
  • Security
    Our Websites use various security devices and methods where appropriate to protect your Personally Identifiable Information and your data or your content depending on the nature of the Website, and we take reasonable measures to ensure that your information remains reliable, accurate, complete and current. Unfortunately, no data transmission over the Internet is 100 percent secure. We will take reasonable measures, which we believe are appropriate to protect your Personally Identifiable Information from loss, misuse, alteration or destruction; however, we cannot ensure or warrant the security of that information.
  • Fulfillment, Changes, and Communications
    We use Personally Identifiable Information for the purpose for which you provided it, such as to fulfill your request for services or information, to process and administer your requests, statements, and to activate any online account you may have with us. We may also use Personally Identifiable Information to notify you of changes to this Website, to provide you with news, email offers and other information, to let you know about other information and services that may be of interest to you, and to tailor our online offerings to your preferences.
  • Third Party Policies
    If we use agents, contractors or other companies to perform services on our behalf, we will require that they protect your Personally Identifiable Information in accordance with this Notice. On the other hand, you must be comfortable with the privacy policies of any other sites You authorize to gather information from us, as the privacy policies of such other sites will govern the use of your Personally Identifiable Information once it has been transmitted by us.
  • Website Analysis
    We may also combine anonymous usage information collected from your visit to the Website with that of other users to determine which features and areas of the website are most popular. This aggregated information does not contain Personally Identifiable Information.
  • Permitted Disclosures
    We may disclose Personally Identifiable Information to the following parties under the following circumstances: (i) to you, if you direct us to do so; (ii) to unaffiliated financial services providers, transfer agents, custodians and trustees, banks, financial representatives, proxy services, vendors, affiliates, licensees, licensors, affiliates, solicitors, printers or third parties who assist us or who perform services on Our behalf in order to provide you with products and services or to affect transactions that you request or authorize; (iii) to third parties if we are compelled to do so by law; and (iv) to third parties in order to protect any account you may have with us from fraud, misfeasance, malfeasance or other wrongful act.
  • Disclosure Required by Law
    From time to time, we may be required to disclose your Personally Identifiable Information in response to a court order, subpoena, government investigation or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful. We also may disclose certain Personally Identifiable Information when we believe that such disclosure is reasonably necessary to protect the rights, property and safety of others or ourselves.

What are Cookies?

Cookies are small text files placed on your computer by the websites that you visit. A cookie file is stored in your web browser and allows the Website or a third party to recognize you and make your next visit easier and the Website more useful for you. The use of cookies is now standard for most websites. Essentially, cookies are a user’s identification card for the HT servers. Web beacons are small graphic files linked to our servers that allow us to track your use of our Website and related functionalities.

Managing Cookies on Your Device

HT uses or may use cookies and/or web beacons to help personalize content and to provide you with an improved user experience. By using this website or application you consent to the deployment of cookies. You can control and manage cookies using your browser (see below). Please note that removing or blocking cookies can impact your user experience and some functionality may no longer be available.

We use both session and persistent cookies on the Website and we use different types of cookies to run the site:

  • Essential/strictly necessary cookies
    Some cookies we use are essential to the functioning of the Website.
  • Analytical/performance cookies
    Allow us to recognize and count the number of visitors and see how visitors move around the Website when using it. This helps us improve the way the site functions.
  • Functionality cookies
    Used to recognize you when you return to the Website. This enables us to personalize our content for you, greet you by name, and remember your preferences.
  • Targeting cookies
    Record your visit to the Website, the pages you have visited, and the links you have followed. We will use this information to make the Website more relevant to your interests.

Third Party Cookies

In addition to our own cookies, we may also use various third party cookies to report usage statistics of the Website and refine marketing efforts.

  • Tracking cookies
    Follow on-site behavior and tie it to other metrics, allowing better understanding of usage habits.
  • Optimization cookies
    Allow real-time tracking of user conversion from different marketing channels to evaluate their effectiveness.
  • Partner cookies
    Provide marketing conversion metrics to our partners so they can optimize their marketing efforts.

Using your Browser to Control Cookies

Most browsers allow you to view, manage, delete and block cookies for a website. Be aware that if you delete all cookies, then any preferences you have set will be lost, including the ability to opt-out from cookies as this function it requires placement of an opt out cookie on your device.

Google Analytics

Our sites use of Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of the services and report on activities and trends. If you are a registered user of our Websites and/or offerings, we may use this information, in combination with other information that you provide, to improve the services and other offerings of the program or website. This service may also collect information regarding the use of other websites, apps and online resources.

You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/ and may exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

IP Address

Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Website(s), along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Website(s). We may also derive your approximate location from your IP address.

Notice of Privacy Rights to California Residents

California law requires that we provide you with a summary of your privacy rights under the California Online Privacy Protection Act (the “Act”) and the California Business and Professions Code. As required by the Act, we will provide you with the categories of personally identifiable information that we collect through this Website and the categories of third party persons or entities with whom such personally identifiable information may be shared for direct marketing purposes at your request. California law requires us to inform you, at your request: (1) the categories of personally identifiable information we collect and what third parties, we share that information with; (2) the names and addresses of those third parties; and (3) examples of the products marketed by those companies. The Act further requires us to allow you to control who we can and cannot share that information with. To obtain this information, please send a request by email. When contacting us, please indicate your name, address, and what personally identifiable information you do not want us to share with third parties. The request should be emailed to us at policy@hogantaylor.com and labeled “California Customer Choice Notice.” Please allow thirty (30) days for a response. Also, please note that there is no charge for controlling the sharing of your personally identifiable information or requesting this notice.

Third Party Links

Please be aware that HT, sometimes contains links to other sites that are not covered by this Notice. Visitors to the Website may be directed to third party sites for more information about thought leadership, events, content sponsorships, vendor services, government entities, nonprofits, and social networks.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of any third party social media platform provider or other organization, including with respect to any Personal Identifiable Information you disclose to other organizations through or in connection with the Website, such as by using third party messaging services linked or integrated through the Website.

Security

HT works to protect the confidentiality and security of information it obtains in the course of its business. Access to such information is limited and policies and procedures are in place, designed to safeguard the information from loss, misuse and improper disclosure.

Retention Period

We will retain your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained.

The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the Website or offerings to you (for example, for as long as you have an account with us or keep using the Website or offerings); (ii) whether there is a legal or business obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations regulatory investigations, or other legal matters).

No Information from Children Under 13

This Website is not intended for use by children. HT believes in protecting the privacy of our children. With this belief, we do not knowingly collect or maintain Personal Identifiable Information on our Website from persons under 13 years of age, and no part of our Website is directed to persons under 13 years of age. We will take appropriate steps to delete any Personal Identifiable Information of persons less than 13 years of age that have been collected on our Website without verified parental consent upon learning of the existence of such Personal Information.

Unsubscribe

HT gives you choices regarding the collection and usage of your personal information. If you have registered for any HT related updates through www.hogantaylor.com, and do not wish to receive future e-mails, please visit our unsubscribe page within the application.

Changes to this Notice

HT reviews our Notice from time to time, and that these practices are subject to change. Any change, update or modification will be effective immediately upon posting on the site. Check this page periodically if you would like to monitor changes.

Access

Inquiries about the accuracy of identifying information previously submitted to HT through its Website, or requests to have outdated information removed, should be directed to: policy@hogantaylor.com. HT is committed to providing reasonable and practical access to visitors to allow them the opportunity to identify and correct any inaccuracies. When requested and practical, HT will delete identifying information from current operational systems.

When Personally Identifiable Information is retained, HT assumes responsibility for keeping an accurate record of the information once a visitor has submitted and verified the data. HT does not assume responsibility for verifying the ongoing accuracy of the content of personal information. When practically possible, if HT is informed that any personal data collected through a website is no longer accurate, HT will make appropriate corrections based on the updated information provided by the authenticated visitor.

Users Outside the United States of America

If you are a resident of a country within the European Union or are otherwise accessing our site from outside the United States of America, by using this site and providing us your personally identifiable information, you hereby explicitly acknowledge and agree to (i) the transfer of such information to the United States and (ii) the collection, use and disclosure of your personally identifiable information in accordance with this Notice.

Contact Us

If you have questions or you do not feel that your concerns have been addressed in this privacy statement, please contact us.