We may update this Statement from time to time, so please check back periodically for changes.
The most recent version of the Statement is reflected by the version date located above. This Statement is not intended to and does not create any contractual or other legal right in or on behalf of any party.
New England Asset Management, Inc. (“NEAM”, “us” or “we”) understands that web enabled clients and visitors to our website (www.neamgroup.com) (“Website”) are concerned about the privacy of personal information. We have established policies and procedures concerning the collection, use and security of personal information that will help protect the privacy of registered users and visitors to our Website. Our data privacy standards are designed to help us serve our users while maintaining our own strict security standards, and are intended to comply with the data protection laws of the various jurisdictions where we do business. We want you to understand how and why we collect, use and disclose personal information about you on our Website. This Data Privacy Statement (“Statement”) provides you with information concerning our practices and procedures as they relate specifically to information we collect on this Website.
We will collect only the personal information from visitors (including email addresses and phone numbers) which visitors voluntarily submit and based on their usage of this website. We will not intentionally disclose the details about web visitors or any of their business information to anybody outside of NEAM, Inc. and its parent and affiliates without the visitor's express permission, unless disclosure is required by law, or is in compliance with legal process, or if necessary to protect our rights or our business reputation or to act in an emergency situation to protect personal safety or to prevent harm to persons or property.
Data Automatically Collected
When you use our Website, we automatically collect your IP address, traffic source, search keywords, page views, visits, language (aggregate), location (aggregate), browser and operating systems (aggregate), network (aggregate), device (aggregate), as well as other connection data like time and transferred data (collectively referred to as “automated data”) as well as the use of the analytical and portfolio analysis tools.
We store and use this automated data in server log files for the reason of system integrity and security and in order to be able to investigate and prosecute infringements or abuse of our Website and to cooperate with authorities involved (security and prosecution purposes). We also use this information in order to enable NEAM to better identify and serve its clients and/ or visitors and to respond better to their needs.
In order to pursue these purposes, we make accessible and share automated data with our IT security team, supervisory authorities and/or prosecution departments (for security and prosecution purposes) and qualified personnel (marketing) having access to the tools that are used for collecting and analyzing the automated data (Google Analytics and others, see below in section “Google Analytics”, “Leadlander”, and “Marketing automation, customer relationship management (CRM), publications and invitations.”)
We store the information required for security and prosecution purposes on a legitimate interest basis and the data required for marketing and analytics purposes (legitimate interest or where required, by obtaining your prior consent), for the period necessary to pursue the purposes outlined in this section, or as permitted by statutory laws.
We do not rely on our legitimate business interests (but obtain your prior consent), if they are overridden by your personal interests or fundamental rights and freedoms which require protection of personal data.
Information you submit through web forms and subscription pages
On our Website, you have the opportunity to pose questions or get in touch with us through web forms, subscribing to and/or accessing our publications or responding to conference invitations.
We also collect, store and use your name, company name, email address, IP address, documents or files, content of your request or query and other personal information you provide with your submission for the purpose of getting in contact with you, responding to your email request, responding to your submissions, to complete your personal profile, answering your questions or providing information as requested.
We will also collect data about the content visitors access through this Website, such as newsletters or articles visitors read or the information topics contained therein, or by sending information to a NEAM email address provided on the Website. We will use this data to manage visitor subscriptions, measure the overall interest of our visitors to the various sections of this website and our Extranets, and inform visitors about NEAM services and information that may be of interest, unless visitors inform us that they no longer wish to receive any publications/promotion material from NEAM.
We collect and use this information on a legitimate interest purpose (or, where required, by obtaining your prior consent). We store this data for the period necessary to pursue the purposes outlined in this section, or as permitted by statutory laws.
Client login/registration data
Some of our services and content of the Website are reserved for “clients only” and require access to a closed access area. We will use your registration data (name, company name, email address, phone number, and password) for authentication purposes and store your registration data until you opt-out from the services or are no longer a NEAM client.
This Website utilizes cookies which expire after one year. We audit/log some activities performed while visiting our Website - with a cookie prior to login and in our database after login.
There are two types of cookies employed by NEAM. The first type is used to track information that users have provided us so that we do not need to solicit that information upon a subsequent visit. The second type is used once users are logged into our client portal and provides information via the user session identifier about the various tools and resources each user has access to on the site. We do not employ any third party cookies for advertising.
You may refuse the storing of cookies on your computer by using the appropriate setting of your internet browser but certain services on a site may not then function properly. In addition, you may prevent the collection of the information generated by Google Analytics cookie by downloading and installing the following linked browser plug-in. http://tools.google.com/dlpage/gaoptout?hl=en. For additional information concerning Google Analytics, please visit http://www.google.com/analytics/learn/privacy.html to learn more.
Marketing automation, customer relationship management (CRM), publications and invitations
We use marketing automation software, databases and other tools (collectively the “Tools”) to disseminate our marketing content, such as publications, blogs, event alerts/conference invitations and other information. Our provider is Hubspot Inc., Cambridge, Massachusetts (“HubSpot”).
If you register for one of our offers via a web form, contact data such as name, email address, company name, address, telephone number is collected and stored in one or more of the above mentioned Tools.
HubSpot uses a cookie that is stored on the user’s computer to collect data. The following data is collected: Information about the computer you use and your visit to our Website, in particular your IP address, your location (aggregate), domain, initial timestamp, last timestamp, current timestamp and session number, the browser you use, referral source and the length of your visit to the Website (Online Access Data). This information is stored on a server of Hubspot after obtaining prior consent where necessary.
We use the Online Access Data for statistical evaluations in order to ensure the smooth operation of the offer and to continuously optimize it. Furthermore, we use the data to optimize our services, products and marketing measures.
Your contact data is stored in the Hubspot database based on legitimate interest.
Your personal data will not be passed on to any other third parties.
Confidentiality and Security
We restrict access to personal information collected about you at our Website to our employees, our affiliate’s employees, or others who need to know that information to provide services to you or in the course of conducting our normal business operations. We maintain appropriate physical, electronic, and procedural safeguards to protect personal information. We protect our databases with various physical, technical and procedural measures, and we restrict access to your information by unauthorized persons. We also advise all NEAM employees about their responsibility to protect customer data, and we provide them with appropriate guidelines for adhering to our company's business ethics standards and confidentiality policies. We apply secure sockets layer (SSL) for data in transit.
Links to Other Sites
For your convenience, we may provide links to other websites and web pages that we do not control. We cannot be responsible for the privacy practices of any websites or pages not under our control, and we do not endorse any of these websites or pages, the services or products described or offered on such sites or pages, or any of the content contained on those sites or pages. Please check the applicable privacy policies of the respective operator of those third party websites.
Connecticut Privacy Protection Notice
NEAM will take reasonable measures to protect the confidentiality of Social Security numbers and limit access to those with a need for such information. NEAM prohibits the unlawful disclosure of Social Security numbers.
California Do Not Track Disclosure
Our website does not respond to “Do Not Track” signals. DNT is a preference that users can set on their browser (if supported) to opt out from online behavioral tracking.
Visiting Our Website from Outside of the United States
If you are visiting our website or purchasing our products or services from outside of the United States or otherwise contacting us from outside of the United States, please be aware that your personal information may be transferred to, stored or processed in the United States, where our servers are located and our central database is operated or where web content is hosted by our service providers. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to protect your privacy. For example, our service providers will be contractually bound to process personal information only on behalf of and under the instructions of NEAM and to adhere to similar data privacy standards as provided by the European Union. By using our services or purchasing our products, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Statement.