Privacy policy

Privacy policy

LAST UPDATED:  29 July 2013

PRIVACY POLICY

This Privacy Policy describes the practices of Forum Partners Investment Management LLC (“Forum Partners,” “we,” and “us”) in connection with information that we collect through websites that link to this Privacy Policy (the “Sites”).  By providing Personal Information (as defined below) to us, you agree to the terms and conditions of this Privacy Policy.

PERSONAL INFORMATION

Personal Information We May Collect

“Personal Information” is information that identifies you as an individual, such as:

• Name
• User name
• Postal address
• Telephone number(s)
• Email address

If you submit any Personal Information relating to other people to us or to our service providers in connection with the Sites, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

How We May Collect Personal Information
We and our service providers may collect Personal Information in a variety of ways, including: 
• Through the Sites:  We may collect Personal Information through the Sites, e.g., when you sign up for an account. 
• Offline:  We may collect Personal Information from you offline, such as when you contact a representative. 

The Personal Information you provide through the Sites may be combined with Personal Information and Other Information that you provide to us (via online or offline means), that is publicly available, or that we may otherwise obtain online or offline.

How We May Use Personal Information

We may use Personal Information:

• to respond to your inquiries and fulfill your requests, such as to send you information or to respond to your questions and comments.
• to send administrative information to you, for example, information regarding the Sites and changes to our terms, conditions, and policies.  Because this information may be important to your use of the Sites, you may not opt-out of receiving these communications.
• to provide you with updates and announcements and programs and to send you invitations to participate in special programs.
• to re-contact you if we have not heard from you in a while.
• to send you material from any of our affiliates and from our strategic partners.
• to personalize your experience on the Sites by presenting information tailored to you. 
• for our business purposes, such as analyzing and managing our businesses, market research, audits, developing new products, enhancing our Sites, improving our services and products, identifying usage trends, and gauging customer satisfaction and providing customer service (including troubleshooting in connection with customer issues). 
• as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

How Personal Information May Be Disclosed

Your Personal Information may be disclosed: 

• to our affiliates for the purposes described in this Privacy Policy. 
• to our third party service providers who provide services such as website hosting, data analysis, infrastructure provision, IT services, customer service, email delivery services, auditing services and other similar services to enable them to provide services.
• to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
• as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

OTHER INFORMATION

Other Information We May Collect

“Other Information” is any information that does not reveal your specific identity, such as:
• Browser and device information
• Server log file information
• Information collected through cookies, pixel tags and other technologies
• App usage data
• Demographic information and other information provided by you
• Location information
• Aggregated information

How We May Collect Other Information

We and our third party service providers may collect Other Information in a variety of ways, including: 

• Through your browser or device:  Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, service provider, and the name and version of the Sites (such as the App) you are using.  We use this information for statistical purposes as well as to ensure that the Sites function properly. 
• Through server log files:  Your “IP Address” is a number that is automatically assigned to the computer or device that you are using by your Internet Service Provider (ISP).  An IP Address is identified and logged automatically in our server log files whenever a user visits the Sites, along with the time of the visit and the page(s) that were visited.  Collecting IP Addresses is standard practice on the Internet and is done automatically by many websites.  We use IP Addresses for purposes such as calculating Sites usage levels, helping diagnose server problems, and administering the Sites.  Please note that we treat IP Addresses, server log files and related information as Other Information, except where we are required to do otherwise under applicable law.
• Using cookies:  Cookies allow a web server to transfer data to a computer or device for recordkeeping and other purposes.  We use cookies and other technologies to, among other things, better serve you with more tailored information and facilitate your ongoing access to and use of the Sites.  If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies.  To learn more about cookies, please visit http://www.allaboutcookies.org/. 
• Using Adobe Flash technology (including Flash Local Stored Objects (“Flash LSOs”)) and other similar technologies:  We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Sites.  If you do not want Flash LSOs stored on your computer or device, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained using the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to "information" on the Macromedia site), how to prevent Flash LSOs from being placed on your computer or device without you being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time).  Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Sites or our online content. 
• Using pixel tags, web beacons, clear GIFs or other similar technologies:  These may be used in connection with some Sites pages and HTML-formatted email messages to, among other things, track the actions of Sites users and email recipients and compile statistics about Sites usage and response rates. 
• From you:  Information such as date of birth, gender and zip code, as well as other information, such as your preferred means of communication, may be collected when you voluntarily provide this information.  Unless combined with Personal Information, this information does not personally identify you or any other user of the Sites.
• Physical Location:  We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you choose to deny such uses and/or sharing, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
• By aggregating information:  Aggregated Personal Information does not personally identify you or any other user of the Sites, (for example, we may use Personal Information to calculate the percentage of our users who have a particular telephone area code).
How We May Use and Disclose Other Information

Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  If we are required to treat Other Information as Personal Information under applicable law, then, in addition to the uses listed in the “How We May Collect Other Information” section above, we may use and disclose Other Information for all the purposes for which we use and disclose Personal Information.

In some instances, we may combine Other Information with Personal Information (such as combining your name with your zip code).  If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.

THIRD PARTY SITES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which these Sites contain a link.  The inclusion of a link on the Sites does not imply endorsement of the linked site by us or by our affiliates. 

SECURITY

We use reasonable organizational, technical and administrative measures to protect Personal Information under our control.  Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below (note that physical mail notification will delay the time it takes for us to respond to the problem).

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

If at any time you wish to stop receiving email marketing communications from us, please just let us know by emailing, calling or writing to us using the contact information listed below in the “Contacting Us” section or by using the unsubscribe feature in the marketing email you received. In your request, please indicate that you wish to stop receiving email marketing communications from us. 

Please note that changes may not be effective immediately.  We will endeavor to comply with your request(s) as soon as reasonably practicable.  Please also note that if you do opt-out of receiving marketing-related messages from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.

How you can access, change or suppress your Personal Information

To review, correct, update, suppress, delete or otherwise limit our use of your Personal Information that has been previously provided to us, please email, call or write to us using the contact information listed below in the “Contacting Us” section and clearly describe your request. 

In your request, please make clear what information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information.  We will try to comply with your request as soon as reasonably practicable.  Note that despite our efforts, there may be residual information that will remain within our databases and other records, which will not be removed or changed.  Further, please note that we may need to retain certain information for recordkeeping purposes. 

RETENTION PERIOD
We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. 
USE OF SITES BY MINORS

The Sites are directed to individuals who are permitted to share their Personal Information without parental consent and we request that other individuals (including individuals under the age of 13) not provide Personal Information through the Sites.

CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or service providers, and by using our Sites you consent to the transfer of information to countries outside of your country of residence, including the United States, which may provide for different data protection rules than in your country.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health or medical condition, criminal background or trade union membership) on or through the Sites or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy.  Please take a look at the “LAST UPDATED” legend at the top of this page to see when this Privacy Policy was last revised.  Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on a Site.  Your use of the Sites following these changes means that you accept the revised Privacy Policy.

CONTACTING US

If you have any questions about this Privacy Policy, please contact us as follows:

1. You may email us at: mark.pearson@forumpartners.com
2. You may call us at +44 207 290 3024
3. You may send mail to the following postal mail address:

Forum Partners
1st Floor
16 Berkeley Street, London
W1J 8DZ

Please note that email communications are not always secure; so please do not include sensitive information in your emails to us.