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.

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.

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 http://www.leadlander.com/privacy.asp.

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 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 http://www.leadlander.com/privacy.asp.

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.



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