This Privacy Policy describes how Hadley Investment Co. (collectively, “Hadley,” “we,” “our” or “us”) collects, uses, processes and shares personal information collected from visitors and users (individually, “you”) of Hadley’s website GoHadley.com (collectively, our “Services”). Your use of our Services is also subject to the Hadley Terms of Use.
We provide a separate privacy policy for our mobile app and users seeking financial products and services. Information on how we collect, use, process and share personal information on our Hadley mobile application and for those users seeking financial products and services is governed by a separate privacy policy that can be found here.
For more information about the information we share with third parties and the recipients of such information, please refer to the How We Share Your Information section of this Policy. Please note that this Policy does not otherwise cover the use of personal information by those third parties or their services, and we do not take responsibility for their privacy practices.
You may have certain rights or choices that relate to your personal information, including choices about how we share your personal information with others. For more information, please refer to the Your Choices and Rights section of this Policy.
Overview
Information We Collect and Use
When you use or visit our Services, we collect information directly from you (e.g., your email address when you subscribe to our mailing list). We may also generate information about you (e.g., information about your device while you visit our website).
How We Use Your Information
We use your information to provide the information and Services on our website, tailor your experience, send you marketing communications, and for other purposes described below.
How We Share Your Information
We share your information with affiliates; with our service providers; with other business partners (including advertising partners); and others as described below. We share information to provide and improve our Services, for our own marketing purposes, and for other purposes as described below.
How We Store and Protect Your Information
We maintain technical, administrative, and physical security measures designed to protect your information. We may retain your information for as long as necessary for purposes described below.
Cookies
We use cookies and similar technologies to help provide our Services, offer you a more personalized user experience and market our products and services to you.
Your Choices and Rights
You have choices about your information, and in some circumstances, you may be able to opt-out of receiving marketing communications, change your communication preferences, access and update your information, update location sharing options and exercise choices regarding cookies. These choices and other options you may have are described in more detail below.
International Transfers of Information
We operate in the United States and our services are intended for US residents. If you are located outside of the United States, information about you may be transferred to, or accessed by, entities located in countries outside of your home country. To protect your information, any such international transfers will be made in accordance with applicable law.
Links to Other Websites
Our Services may contain links to other websites or services that are not owned or controlled by Hadley, including links to our business partners.
Children
Our Services are not directed at or intended for use by children, nor do we knowingly collect information from children under 16 years of age.
Changes to This Policy
We update this Policy from time to time, and changes will be effective when posted (as identified in the Policy).
How to Contact Us
If you have any questions about this Policy or the way your personal information has been used, please contact us at [email protected] or using the contact details set out below.
I. INFORMATION WE COLLECT AND USE
Personal Information We Collect Directly From You.
As you visit or use our Services, we collect the following categories of personal information directly from you:
Personal details, including your name
Contact information, including your email address
Your preferences, including survey and marketing responses
Communications you send us, including messages or communications to us and other requests you make through our Services
Other information you may provide, including other information you provide about yourself or others, such as information you enter when referring someone to us
You may choose not to provide some of the personal information described above. Please note, however, that many of our Services require some personal information to operate, so if you choose not to provide the personal information necessary to operate and provide you with a particular Service or feature of that Service, you may not be able to use that Service or feature.
Personal Information Generated By Us.
As you use our Services, we generate certain personal information about you, including through automatic data collection and by inferences based on the information we collect about you and your activity on our Services. We may automatically collect information about your interactions with the Services or communications you receive (such as email) using certain technologies, such as cookies, web beacons and other technologies (see our Cookie Policy for more details). We generate the following categories of personal information about you:
Device information.
When you visit or use our Services, we automatically collect certain information about your device (e.g., your mobile device, computer, or tablet), including information about your hardware and software, device configuration, and nearby networks. Such data may include data about your device operating systems, browsers, and other software installed on your device; device identifiers, such as IP address, IMEI number, MAC address, or other device identifier; country of origin, region and language settings; and information about domain servers and wireless or network access points near your device.
Usage and performance information.
We also automatically collect personal information about your usage of the Services, including information about your searches or interactions with features of our Services; access times; and performance of our Services.
Location information.
If you use our Services, we automatically collect generic location information about you (such as city or neighborhood), depending on the choices you make when you are asked to consent to our collection of location information. We may use and store this information to provide and improve features of our Services. Please see the Your Rights and Choices section below for more information about how to adjust your preferences, including those related to location information.
Inferences about you.
We combine the information we collect, generate, or otherwise obtain to draw inferences about your preferences and interests in order to provide and personalize our Services and tailor the offers we and our partners provide to you.
Personal Information We Obtain from Third Parties.
We may also receive certain categories of personal information from third parties, such as third-party websites, applications, social media networks, and services (which may include publicly-available sources; each of these is a “third-party platform”), our affiliates and other third parties. If you are an existing Hadley customer, we will combine this information with information we collect through our Services and use and share it for the purposes described below. The categories of personal information we may obtain from third parties include:
Your name
Email address or other contact information
II. HOW WE USE YOUR INFORMATION
We use your personal information for the following purposes (“Purposes”), to:
Provide the Services,
which includes providing you with the information available on our Services and fulfilling your requests, including but not limited to providing links to our mobile app.
Communicate with you
about the Services, products, and/or functionality; respond to, or follow up on, your comments and questions; and otherwise provide customer service (see below for more detail on Electronic Communications)
Send you marketing communications,
including communicating with you about services or products offered by Hadley, as permitted by law
Operate and improve our Services and develop new products and services,
including using analytics to better understand how you use our Services for purposes of product, website, application and service development and to enhance the user experience
Provide information regarding potential benefits of using our mobile app and related services
Protect against, investigate, and deter fraudulent, unauthorized, or illegal activity
Comply with our policies, procedures and legal obligations,
including complying with law enforcement or government authority requests, addressing litigation-related issues, and exercising rights or obligations conferred by law
As otherwise consented to by you and as required or permitted by applicable law.
If you give your consent to any further use of personal information, you can withdraw that consent at any time by contacting us using the details set out below.
You have choices about your personal information, and in some circumstances, you may have the right to opt-out or object to our uses of your personal information for these Purposes. For more information, or to exercise these or other rights (where available), see the Your Choices and Rights section below.
Electronic Communications.
Consistent with the above Purposes and as permitted by applicable law, we may communicate with you via electronic messages to:
Send you information relating to our products and services.
This may include reminders and updates, receipts, technical notices, updates, security alerts, and support and administrative messages.
Send you marketing communications.
In other situations, subject to the Your Choices and Rights section below and applicable law, we may communicate with you about offers, upcoming events, and other news about products and Services offered by Hadley, our affiliates and other business partners.
III. HOW WE SHARE YOUR INFORMATION
We disclose the personal information we collect (or otherwise generate or obtain) as follows:
With our affiliates.
We share your information with our affiliates, including but not limited to the Purposes described above, to provide you with integrated products and services, and for our and their marketing purposes (see below for more detail on Sharing with Our Affiliates).
With other business partners.
We share information with other third-party business partners, including but not limited to the Purposes described above, to provide you with integrated products and services, and for our and their marketing purposes where permitted under law (see below for more detail on Sharing with Our Business Partners).
With other service providers.
We share information with third-party vendors, consultants, and other service providers who perform services or functions on our behalf (see below for more detail on Sharing with Other Service Providers).
In the event of a corporate transaction.
We may disclose or transfer your information to a third party if we sell, transfer, divest, or disclose all or a portion of our business or assets to another company in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding.
To protect rights and property.
We may disclose your information to third parties when we believe in good faith that disclosure is necessary to protect our rights, our property, the integrity of the Services, personal safety, or the interests of you or any other person, and to detect, prevent and/or otherwise address fraud, risk management, security or technical issues.
To comply with and as required by law.
We may disclose your personal information to government authorities or other relevant third parties in order to comply with applicable legal requirements, judicial proceedings, court orders, legal process, or lawful requests from governmental authorities.
Aggregate information.
We may share aggregated statistical data for the improvement of our Services. We may also share aggregate or de-identified information with third parties at our discretion.
At your request.
We also share your information as directed or requested by you, or subject to your consent.
Sharing with Our Affiliates.
We do not currently have affiliates, but, if we do have affiliates in the future, we may share your information with our affiliates and subsidiaries in the U.S. and worldwide. We may share your information with our affiliates for the following reasons:
Provide customer support services.
Detect, prevent, and investigate fraud and misuse of our services, other illegal activities, and data breaches.
Analyze how users use our independent and affiliated platforms, including so that we may improve existing products and services and develop new features, products, and services that may be of interest to our users.
Ensure compliance with applicable law.
To learn more about your choices related to how we share your information with our Affiliates, please see the Your Choices and Rights section below.
Sharing with Our Business Partners.
We share your information with other third-party business partners for the following reasons:
Provide customer support services.
Detect, prevent, and investigate fraud and misuse of our services, other illegal activities, and data breaches.
Analyze how users use our independent and affiliated platforms, including so that we may improve existing products and services and develop new features, products, and services that may be of interest to our users.
Ensure compliance with applicable law.
To learn more about your choices related to how we share your information with our business partners, please see the Your Choices and Rights section below.
Sharing with Other Service Providers.
We share information with third-party vendors, consultants, and other service providers who perform services or functions on our behalf. We do not authorize these third parties to use or disclose your information for purposes other than for which it has been provided. We require these third parties to maintain and implement security measures to protect your information from unauthorized access or processing.
IV. HOW WE STORE AND PROTECT YOUR INFORMATION
Hadley maintains commercially-reasonable technical, administrative, and physical security measures designed to protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
Retention.
We may retain your personal information for as long as necessary to continue to provide you the services requested. We may also retain your personal information as necessary to:
Maintain logs and business records for analysis, security, and/or audit purposes
Comply with record retention requirements under the law
Deal with any complaints regarding the Services; and
Comply with our legal obligations, protect or defend our rights, resolve disputes and enforce our contracts
V. COOKIES
When you use or visit the Services, we collect information about your usage and activity using cookies, web beacons, and other technologies. Third parties may also view, edit, or set their own cookies. We and our third-party service providers, our Affiliates, and other business partners may also place web beacons for these third parties. The use of these technologies by third parties is subject to their own privacy policies and is not covered by this Policy, except as required by law. See our Cookies and Interest-Based Advertising Policy for more details.
VI. YOUR CHOICES AND RIGHTS
Email.
If you no longer want to receive marketing and promotional emails from Hadley, you may click on the “unsubscribe” link in such emails to opt-out of future marketing email communications. If you have a Hadley account, you may also opt-out of marketing emails in your account settings. Please note that even if you opt-out of receiving marketing communications from one or all of our Services, we will still send you service-related communications, such as confirmations of any future reservations you make.
Cookies and Interest-Based Advertising.
To exercise choices regarding cookies set through our websites or Services, as well as other types of online tracking and online advertising, see our Cookies and Interest-Based Advertising Policy for more details. We currently do not employ technology that recognizes “do-not-track” signals from your browser.
Sharing with third parties.
As described above in the How We Share Your Information section, we share your information with third parties for their own purposes.
You can opt-out of us sharing your information with:
Our Affiliates,
for their own marketing purposes.
Other business partners,
who use information for their own marketing purposes.
You can opt-out of such sharing by changing your Hadley account preferences. You may also send such opt-out requests to us as described in the How to Contact Us section below.
Any requests to erase personal data and information will be reviewed and should be submitted to [email protected]. As a registered investment adviser, Hadley cannot guarantee full erasure of data required to be maintained under the Investment Advisers Act of 1940. In such situations, Hadley will restrict access to certain personnel and will only share or access such data or information as required by regulatory or legal proceedings until such time as it may be deleted.
VII. INTERNATIONAL TRANSFERS OF INFORMATION
We are located in the United States and information about you will be transferred to, or accessed by, entities located around the world as described in this Policy. Some of these entities, like us, may be located in countries (such as the United States) that do not provide an equivalent level of protection for personal information as your home country.
VIII. LINKS TO OTHER WEBSITES
Our Services contain links to other websites or services that are not owned or controlled by Hadley, including links to websites our affiliates and our advertisers and other business partners. This Policy only applies to information collected by our Services. We have no control over these third-party websites, and your use of third-party websites and features are subject to privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third-party websites linked to our Services. Your use of third parties' websites linked to our Services is at your own risk, so we encourage you to read the privacy policies of any linked third-party websites when you leave one of our Services.
IX. CHILDREN
Our Services are not directed at or intended for use by children. We do not knowingly collect information from, children under 16 years of age. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us at using the contact details listed in the How to Contact Us section below.
X. CHANGES TO THIS POLICY
Except to the extent limited by applicable law, we will update this Privacy Policy from time to time to reflect changes in our privacy practices, legal requirements, and other factors by prominently posting notice of the update on our Services. Changes to our Privacy Policy will be effective when posted on our Services and the new effective date will be identified.
If we make any changes to the Privacy Policy that materially impact previously collected personal information about you, we will make reasonable efforts to provide notice and obtain consent to any such changes as may be required by law.
To request a copy of this Policy, or to request a copy of the Privacy Policy in place at the time you signed up for an account, please contact us at the details below.
XI. HOW TO CONTACT US
If you have any questions about this Policy or the way in which your personal information has been used, please contact us by email at [email protected] or by postal mail at:
Hadley Investment Co.
54 Danbury Road
Suite 224
Ridgefield, CT 06877
Attention: Legal Department
COOKIES AND INTEREST-BASED ADVERTISING POLICY
What are Cookies?
Cookies and similar tracking technologies, such as beacons, scripts, web beacons and tags (which together we refer to as “cookies”), are small bits of text, usually stored on a user's computer hard drive or within a browser. They enable a website to remember information about the user's visit to the website.
We and certain third-party partners (as described below) use cookies on our websites and within emails or other communications we send to you (we refer to these together as our “Sites”).
To the extent the cookies we use for these purposes lead to the processing of your personal information, details about how we use that personal information and your rights over that personal information are discussed in our Privacy Policy.
What Types of Cookies are used on our Sites and what do we use them for?
Hadley uses “first party cookies,” i.e., those that are used solely by us or by third parties who act only on our instructions or on our behalf. These types of cookies are used for our own analysis of our own Sites, or to provide functionality such as remembering your language preference.
Other cookies on our Sites are used both by us for the purposes described in this policy and by third parties for purposes where those third parties may wish to combine information from our Sites with information from other sites to improve their services. For example, these types of cookies may be used for interest-based advertising purposes.
The cookies used on our Sites, by either us or by third parties, can be “session” cookies, or “persistent” cookies. “Session” cookies are deleted automatically when you close your browser, and are used for things like ensuring you are kept logged in as you navigate around our Sites. “Persistent” cookies remain stored on your device or browser even after you close it. These cookies are used, for example, to recognize you when you come back to our Sites.
We divide the cookies we use into three categories:
Type of cookie
Description of how we use this type of cookie
What choices do you have?
Required
To provide a secure log-in to our Sites.
To keep you logged in so that you do not have to log in repeatedly to access different pages of the Sites.
Required cookies are necessary for our Sites to operate. On some platforms, you can delete all cookies, but this may affect the basic functionality of the Sites.
Functional
To recognize if you have visited previously, and remember your preferences from past visits, such as your language preference.
To track when you make purchases
To improve our Sites and our offerings by helping us to understand how users use the Sites and to analyze trends which appear in that data. For example, we make changes to the user interface if we can see that certain pages are difficult for a large number of users to navigate. We also collect broad information about how our users use the Sites, for example, to understand which aspects of our Sites and our services are particularly popular, so that we can make improvements going forward."
Where required by law, functional cookies will be used only on the Sites where you have given your consent to their use.
To recognize you if you have used our services on another device. We combine information received from multiple devices to determine if you are using a new device, so that we can continue to provide you with a personalized experience on our Sites.
To collect information for use in advertising on our own Sites and on third party sites which you may visit. Such information is based on your preferences and your usage of our Sites. We have included more information about our use of advertising cookies below.
Where required by law, advertising cookies will be used only on the Sites where you have given your consent to their use.
We work with third-parties that place cookies on our Sites to provide their services, including:
Ad Targeting.
We work with third-party advertising companies to serve ads while you are visiting our Sites and to permit these companies to place and access their own cookies on your computer in the course of serving advertisements on our Sites.
These companies may use information obtained through their cookie (which does not include your name, address, e-mail address or telephone number) about your visits to our Sites and other websites, in combination with information about your purchases and interests from other online sites in order to provide advertisements about goods and services of interest to you.
We also allow certain third parties (as described in our Privacy Policy to collect web log data from you (which may include IP address, where permitted, and information about your browser or operating system), when you visit our Sites, or to place or recognize a unique cookie on your browser to enable you to receive customized ads or content. The cookies may reflect de-identified usage data or other data linked to data you voluntarily have submitted to us, for example, your email address, that we may share with third parties solely in hashed, non-human-readable form.
Advertising Analytics/Measurement.
We make use of analytics cookies as part of our online advertising campaigns to learn how users interact with our Sites after they have been shown an online advertisement, which may include advertisements on third-party websites. In particular, our Sites use Google Analytics 360 Suite, including Google Analytics Advertising, which are web analytics and analytics advertising services provided by Google, Inc., which use third party cookies. Where required, our Sites have activated the IP address anonymization functionality so that the IP address of the user is shortened by Google. Our Sites also use the following Google Analytics Advertising features: Google Remarketing, Google Segments, Double Click by Google and AdRoll. These features use third party cookies to collect information about our website traffic by tracking users across websites and across time and generating reports for us to better understand our website users and to create audiences for our advertisements based on such understanding.
Remarketing Pixel Tags.
In addition, we may share website usage information about visitors to our Sites with third-party advertising companies for the purpose of managing and targeting advertisements and for market research analysis on our Sites and other sites. For these purposes, we and our third-party advertising companies may place pixel tags (also called clear gifs) on some of the pages you visit on our Sites. We will then use the information that is collected using these pixel tags to serve you relevant advertisements when you are visiting other sites on the Internet. These advertisements may be based on your interests.
Session Replay Technologies.
We use third party services such as those provided by, e.g., FullStory that employ software code to record users’ interactions with the Services in a manner that allows us to watch DVR-like replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, scrolls and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement. You can learn more about FullStory https://www.fullstory.com/legal/privacy-policy and you can opt-out of session recording by FullStory at https://www.fullstory.com/optout/.
Other Cookies:
Our partners, who provide certain features on our Sites or display advertising based on your browsing activity, also use Local Storage such as HTML5, to collect and store content information and preferences. Please note that different web browsers offer their own management tools for removing HTML5 local storage.
Your Cookie Choices
We provide you with choices over the use of cookies as described in this policy.
Browsers.
You may be able to change the settings to have your browser refuse certain cookies or notify you before accepting cookies. To do so, please follow the instructions provided by your browser which are usually located within the "Help", "Tools" or "Edit" facility. Some third parties also provide the ability to refuse their cookies directly by clicking on an opt-out link, and we have tried to indicate where this is possible in the table above.
You can also find more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, at www.allaboutcookies.org and www.youronlinechoices.eu.
Mobile Devices.
If you no longer wish to receive interest-based advertising on your mobile applications, please refer to your device’s operating system settings and follow instructions below.
iOS users: To use the "Limit Ad-Tracking" option, follow the instructions provided by Apple here: Apple Support Center
Android Users: To use the "opt-out of interest-based advertising" option, follow the instructions provided by Google here: Google Play Help
Users of other mobile operating systems: Options may be available in your mobile device’s settings menus.
You may also consider downloading the DAA AppChoices Mobile App to manage online behavioral advertising technology.
If you no longer wish to receive interest-based advertising on your mobile device browser, you can follow the steps in relation to Browsers outlined above.
Do-Not-Track Signals.
We currently do not employ technology that recognizes “do-not-track” signals from your browser.
Please keep in mind that, without cookies, you may not have access to certain features on our Sites, including access to your profile/account and certain personalized content. Removing all cookies from your computer could also affect your subsequent visits to certain websites, including our Sites, by requiring that, for example, you enter your login name when you return to that website. Please note that even if you exercise any of the choices described above, you will still see ads, but they will not be based upon the information collected through these tracking technologies and therefore not necessarily relevant to your interests.
Privacy Policy.
Please review our privacy policy for additional details about how we collect, use, and disclose information in connection with our Sites, including personal information obtained from cookies, and for information about how to contact us if you have any questions.
