Privacy Policy

Privacy Policy

Effective Date:  September 5, 2018

Warburton Advisers LLC and its affiliates (hereinafter, “Warburton ”, “we” or “us”) have adopted this policy with recognition that protecting the privacy and security of the personal information we obtain from and about our users is an important responsibility. This policy outlines the types of information we collect when you use our website, and the online services, training platform or other websites operated or offered by Warburton  (collectively, the “Website”). In addition to this Privacy Policy, you should read the Terms and Conditions of the Website. By using the Website, you consent to the data practices described in this policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this policy periodically for updates.

PERSONAL INFORMATION

When you use the Website, our servers automatically record certain information about your use. Similar to other web services, we record information such as account activity, data displayed or clicked on (such as UI elements, ads, and links), and other information (such as browser type, IP address, date and time of access, cookie ID, and referrer URL). Along with cookies, we may also use third-party tracking technology to record similar information regarding you and your activity on the Website. To use services offered on the Website, you must create an account. In creating this account, Warburton may ask for some personal information, including an email address and a password, which is used to protect your account from unauthorized access. Your personal and login information is considered non-public information. Except as required by law or requested by regulatory authorities, Warburton agrees to maintain your non-public information in confidence. We may access information about you from third-party sources and platforms (such as social networking sites, databases, online marketing firms, and ad targeting firms).

Warburton restricts access to non-public personal information about users to certain Warburton personnel who require that information in order to maintain and operate the Website. Warburton may store, process, and maintain data related to your account. Warburton’s uses for this data are described below.

Warburton is not directed to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without his or her consent, he or she should contact us at support@warburtonadvisers.com. If we become aware that a child under the age of 13 has provided us with personally identifiable information, we will delete such information from our files.

USE OF INFORMATION

Warburton maintains and processes your Warburton account and its contents to provide content, material and information on the Website. Warburton’s servers process the information you provide to Warburton for various purposes, including formatting and displaying your information, delivering related content, sharing community information such as message board posts and investment-related information, and other purposes relating to the Website.

  • To provide you with useful content;
  • To ensure the proper functioning of Website;
  • To offer and improve our Website;
  • To provide you with requested information or technical support;
  • To facilitate your movement through our websites or your use of our Website;
  • To do a better job of advertising and marketing our services (our use of your information to do this is performed with your consent where required by applicable law);
  • To advertise and market third party products and services (such advertisement is only performed with your permission where your consent is required by applicable law)
  • To diagnose problems with our servers or our Website;
  • In connection with our security and compliance programs;
  • To administer our Website;
  • To communicate with you;
  • To target prospective customers with our products or services (such targeting is only performed with your permission where your consent is required by applicable law);
  • To assist us in offering you a personalized experience or otherwise tailor our Website, to you; and
  • As otherwise described in this Privacy Policy

Warburton may send you information related to your Warburton account or other Warburton services. If you decide at any time that you no longer wish to receive marketing communications from us, please follow the “unsubscribe” instructions provided in the communications.

 INFORMATION SHARING AND ONWARD TRANSFER

We do not sell, rent, or otherwise share your personal information with any third parties except to persons assessing our compliance with industry standards; our attorneys, accountants, and auditors; and as permitted or required by law (such as when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities or violations of our Terms and Conditions).

We are permitted by law to disclose the non-public personal information about you to governmental or regulatory agencies, a court of law when compelled and other third parties in certain circumstances (such as third parties that perform administrative, technical or marketing services on our behalf or for joint marketing programs) These third parties are prohibited from using or sharing the information for any other purpose.

CORPORATE REORGANIZATIONS

If we are involved in a merger, acquisition, a sale of all or a substantial portion of our assets, or other similar sale transaction, your information will be transferred as part of that transaction. We will notify you by email and/or a prominent notice on our Website of any such transfer and any choices you may have regarding your information.

AUTHORIZED USERS

All users authorized by you to have access to your account can view personal information stored in the account. A primary account holder can view personal information saved in subaccounts to which they have authorized access. We share information about authorized users only for legitimate purposes consistent with this Privacy Policy, including servicing your account and marketing products and services to you.

SECURITY

The transmission of information via the internet, email or text message is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted through the Services or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organizational measures to safeguard your personal information against loss, theft and unauthorized use, access or modification.

CHOICES AND PREFERENCES

You may delete your Warburton account by emailing support@warburtonavisers.com and providing us with enough information to identify your account and prove that you are the owner of the identified account. We will endeavor to act on these deletion requests as soon as reasonably practicable. Deletions take effect when we act on them. Residual information related to your account may remain for some time on our servers.

You may decline to provide personal information to Warburton, except where such information is necessary to enable a feature of the Website. In cases where such personal information is necessary, you may not use that feature if you decline to provide the necessary personal information.

EU and EEA Users and Customers

 

YOUR RIGHTS

Where the European Union’s General Data Protection Regulation 2016/679, or GDPR, applies, in certain circumstances and subject to data processing agreements, you have rights in relation to the personal information we hold about you. We set out below an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by providing details only known to the account holder. To exercise any of your rights, please contact us at support@warburtonadvisers.com. Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.

ACCESS

You have the right to know whether we process personal information about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.

PORTABILITY

You have the right to receive a subset of the personal information you provide us if we process it on the legal bases of our contract with you or with your consent in a structured, commonly used and machine-readable format and a right to request that we transfer such personal information to another party. If you wish for us to transfer the personal information to another party, please ensure you provide detail about that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the personal information or its processing once received by the third party.

CORRECTION

You have the right to require us to correct any personal information held about you that is inaccurate and have incomplete data completed. Where you request correction, please explain in detail why you believe the personal information we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that while we assess whether the personal information we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.

ERASURE

You may request that we erase the personal information we hold about you in the following circumstances:

  • where you believe it is no longer necessary for us to hold the personal information;
  • we are processing it on the basis of your consent and you wish to withdraw your consent;
  • we are processing your data on the basis of our legitimate interest and you object to such processing;
  • you no longer wish us to use your data to send you marketing; or
  • you believe we are unlawfully processing your data.

Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure.

RESTRICTION OF PROCESSING TO STORAGE ONLY

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in the following circumstances:

  • You have objected to us processing personal information we hold about you on the basis that it is inaccurate and you wish us to temporarily cease processing your data while we investigate the objection;
  • You have objected to us processing personal information we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal information while we determine whether there is an overriding interest in us retaining such personal information;
  • We wish to erase the personal information as the processing we are doing is unlawful under applicable data protection laws such as GDPR, but you want us to simply restrict the use of that data; and
  • We no longer need the personal information for the purposes of the processing, but you require us to retain the data for the establishment, exercise or defense of legal claims.

OBJECTION

You have the right to object to our processing of data about you and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims.

You also have the right, at any time, to object to our processing of data about you in order to send you marketing, including where we build profiles for such purposes and we will stop processing the data for that purpose.

WITHDRAWAL OF CONSENT

Where you have provided your consent to us processing your personal data, you can withdraw your consent at any time by contacting us at support@warburtonadvisers.com.

COMPLAINTS

In the event that you wish to make a complaint about how we process your personal information, please contact our Data Protection and Privacy Officer at support@warburtonadvisers.com and we will try to address with your request.

CHANGES TO THIS PRIVACY POLICY

 

Warburton’s Privacy Policy about obtaining and disclosing information may change from time-to-time. In all such instances, we will provide you with notice of any material change to this policy before implementing the change.

MORE INFORMATION

This document constitutes Warburton’s complete Privacy Policy. If you have questions or comments about this Policy, please email us at support@warburtonavisers.com