Data Privacy Statement

 

 

 

Changes to Our Data Privacy Statement

We may update this Statement from time to time, so please check back periodically for changes.

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 our client portal using two-factor authentication. 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.

Use of cookies

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.

A cookie is a small data file that is created to help visitors navigate a website, and is useful to track the traffic to and at a website and to personalize the website. Cookies will allow the web server to recognize your computer on a connection to our Website, which will allow the server to make downloading of pages faster than on a first viewing. Cookies also help identify you as an authorized user of content and pages in our restricted access area. We also use the cookie to track your agreement to this Statement. It is possible to set the browser on your computer to notify you when a cookie is being placed on your computer’s hard drive. However, the procedure for refusal of cookies may differ depending on the computer and/or the software product. You may check with your software help desk or software supplier if you wish to refuse cookies. You may refuse the cookies, but certain functionalities of our Website may not function properly.

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.

Google Analytics

Google Analytics is used on our Website to analyze user behavior and visitor traffic. Google Analytics uses cookies (small data files) stored on your computer to anonymously collect and store Internet log information. This anonymous information collected by the cookies is transmitted to Google and in general stored on a server located in the United States. This data on Google Analytics is then used to evaluate website visitors’ behavior and to generate statistical reports for the Website activity. NEAM does not use any analytics tool that will collect or track any personal identifiable information of the visitors to this site.  Google will process and use the information on the use of our Website on behalf and under the instruction of NEAM for the purposes described above. The transmitted IP address will not be combined with other information on the website usage.

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.

Leadlander

LeadLander (third-party service) is used on our Website to help us better understand each individual visitor's actions on our Website.  Through the use of LeadLander services, we may also use cookies to personally identify users in order to better understand each individual visitor’s actions on our website.  LeadLander may identify a user personally based on the links the user has accessed in emails or information the user has submitted in online web forms and associate this information with LeadLander cookies.  For more information, read LeadLander’s privacy policy at https://uplandsoftware.com/privacy/.

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.

 

DATA PRIVACY STATEMENT – ADDITIONAL INFORMATION – EU BASED PERSONS

The following definitions are used throughout this Data Privacy Statement:
personal information” means any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. This definition includes name, identification number, location data or online identifier; and


sensitive personal information” means personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

 

Who is the Controller of Your Personal Information?

This Website is operated by “Controller” New England Asset Management, Inc., located at Pond View Corporate Center, 74 Batterson Park Road, Farmington, CT 06032 USA

You can pose any question regarding data privacy, this Website or a claim you want to make according to this Statement or applicable data privacy laws by sending an email to:

Bob Emery:  bob.emery@neamgroup.com

 

Information We Collect and Use

In the event we receive personal information via this Website, we will only use it for the purposes described where it is collected or otherwise described in this Statement, and we will not sell, license, transmit or disclose this information outside of NEAM and its subsidiaries and affiliates unless: (1) you expressly authorize us to do so; (2) it is necessary to allow our service providers or agents to provide services for us; (3) it is necessary in order to provide our services to you (and contacting you when necessary); (4) it is necessary in connection with other business purposes including, without limitation, customer care, service quality, business management and operation, risk assessment, security, fraud and crime prevention/detection, monitoring, research and analysis, marketing, customer purchasing preferences and trends, dispute resolution, credit checking and debt collection; or (5) otherwise as we are required or permitted by law.

Your Rights as a Data Subject

We have taken all necessary and adequate steps to protect your personal data and ensure your rights as a Data Subject.

According to the General Data Protection Regulation (GDPR), you have certain rights described below. Please note that limitations may apply to your ability to exercise these rights, for example, when your right to obtain the information is found to be overwritten by essential considerations of overriding interests.

  • Right of access

You have the right to request access to the personal data we process about you.

We will provide you with a copy of the personal data undergoing processing as a starting point, free of charge or by electronic means, if the request has been submitted in a commonly used electronic form.

  • Right to rectification

You have the right to rectification of inaccurate personal data concerning you, including completion of incomplete personal data.

  • Right to erasure (right to be forgotten)

Under certain circumstances, you have the right to the erasure of the personal data concerning you.

  • Right to restriction

Under certain circumstances, you have the right to restrict our processing of personal data concerning you.

  • Right to data portability

Where processing is based on consent or a contract and the processing is carried out by automated means, you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format. You have the right to transmit this personal data to a third party without hindrance from us, if technically possible.

  • The right to object

Under certain circumstances, you have the right to object at any time to our processing of personal data concerning you. For example, if you have requested to receive information from us, e.g., newsletters, but do not wish to receive further information, you can easily opt out of receiving further information from us.

  • Automated individual decision-making, including profiling

As a general rule you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or affects you significantly. This does not apply if among other things automated decision-making and profiling is necessary for entering into, or performance of, a contract between you and us.

  • Right to withdraw from consent

If processing of your personal data is based on your consent, you may withdraw your consent at any time by unsubscribing from an email or sending us an email. Please note that this does not affect the processing of your personal data prior to the withdrawal of your consent.

  • Exercising your rights

If you want to exercise any of your rights as described above or have any question to that, please contact us by sending an email to Bob Emery:  bob.emery@neamgroup.com.

 

  • Filing of complaint

If you wish to file a complaint regarding our processing of your personal data, you can choose to file a complaint to a supervisory Data Protection Authority.

Recipients of Your Data

We share your personal information with affiliated companies. We use software and applications from various service providers as specified in this Statement. Please check the applicable privacy policies of HubSpot, Inc., http://legal.hubspot.com/privacy-policy and LeadLander at https://uplandsoftware.com/privacy/.

We entered into data processing agreements as required with third-party recipients in order to protect your personal information and interests. In these data processing agreements, the service providers undertake measures to protect the data of our users, to process them on our behalf in accordance with the applicable data protection regulations and, in particular, not to pass the data on to third parties. NEAM thus ensures that your data are processed at a level of data protection at all times that corresponds to the level of data protection in the EU/European Economic Area.

Your data will not be passed on to other third parties for other purposes, in particular for advertising purposes.

Children

We are committed to preserving online privacy for all of the visitors to our Website, including children. Our Website is a general audience Website, and we do not knowingly collect information about children or provide services to children. Consistent with applicable laws, we will not knowingly collect any information from children under the age of 13. The Website is not designed to attract anyone under the age of 18.

 

 

DATA PRIVACY STATEMENT - CALIFORNIA RESIDENTS

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). New England Asset Management, Inc. (“NEAM”, “we”, “us” or “our”) adopts this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

YES
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). YES
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. NO
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

 

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA's scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
  • Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
  • Directly and indirectly from activity on our website (www.neamgroup.com). For example, from submissions through our website portal or website usage details collected automatically.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to engage in transactions and transaction related matters, we will use that information to direct the transactions and submit it to the applicable broker dealer and/or entities processing the requests.
  • To provide you with information, products or services that you request from us.
  • To provide you with email alerts, event registrations and other notices concerning our services, or events or news, that may be of interest to you.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  • To improve our website and present its contents to you.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
  • To respond to law enforcement or regulatory or auditor requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A:  Identifiers.
Category B: California Customer Records personal information categories.
Category D:  Commercial information.

Category F: Internet or other similar network activity.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates.
  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

NEAM has not and will not sell your personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 860.676.8722
Website: neamgroup.com
Email: neam-privacy@neamgroup.com
Postal Address: New England Asset Management, Inc.
74 Batterson Park Road
Farmington, CT 06032

 



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