Effective Date: February 2019
INFORMATION WE COLLECT THROUGH THE WEBSITE AND HOW WE USE IT
We collect and process personal information through the Website for the purpose of providing our financial and advisory services. You authorize us to process your personal information, subject to your right to withdraw your consent as described below in “Your Choices About Your Information.” The specific information we collect and how and why we process it depends on how and why the Website is used and includes:
- When visiting the Website, your browser makes an HTTP request to our web server. This HTTP request contains certain information logged by our web server including IP address, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular webpages, and similar information concerning your use of the Website;
- At times, you may choose to communicate with us by populating an email using links available on the Website, such as on our Contact page. When sending the email to us, we collect your email address and, if you provide it, name, contact information, and other information you choose to provide in the email to us;
- We may collect information in order to administer and provide support for accounts available on the Website’s Investor Portal; and
- If you are an employee applicants who utilizes our Careers page, you provide certain personal information when applying for a position, such as name, contact information, and other information you provide to us via your application.
Our legal bases for processing your personal information depends on the personal information concerned and the specific context in which we collect it. We process personal information when we have your consent, if we need to information for the purposes of administering the relationship between you and us (including communications and reporting), or when the processing is in our legitimate interests and not overridden by your fundamental rights and freedoms, such as to provide our services to you, to respond to your inquiries, to monitor and improve our services, to offer new services to you, and to comply with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, securities laws, sanctions compliance, or responding to requests for information from regulatory authorities). We also collect and use information about how the Website is used to improve the Website and develop new features, to prevent, detect and fight fraud or other illegal or unauthorized activities, and to enforce or exercise our legal rights.
A cookie is a small data file that contains a unique identification number that the Website stores on your computer when you visit a website. The cookie stores information about your computer, the type of browser you use and how many times your computer visits a certain website. To learn more about cookies generally, visit http://www.allaboutcookies.org.
A pixel tag is computer code that contains a unique identifier that enables us to monitor user activity and traffic on the Website. We may use pixel tags to gather aggregate information on visits to the Website and assist with other features.
We also use Google Analytics, which is a Google service that collects aggregate information about use of the Website and reports website trends. Google Analytics does not directly identify individual clients or other users. You can learn about Google’s practices here.
Our Policy On Do Not Track Signals: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a client or other user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain personal information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, Hall Capital, like many other website operators, does not respond to DNT signals.
HOW WE SHARE INFORMATION
We may share personal information collected through the Website with third parties for the purposes described below. By using this Website, you authorize us to share such information, subject to applicable law and your right to withdraw your consent as described in “Your Choices About Your Information” below.
For legitimate business purposes. We may make certain disclosures permitted by law for our business purposes, such as disclosures to our accountants, auditors and lawyers.
With third-party service providers. We may disclose information as needed to third-party service providers that help us operate and improve the Website, such as for hosting and maintenance, analytics and security operations.
For corporate transactions. We disclose information if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
To protect and enforce legal rights. We also may disclose information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary or advisable to protect the legal rights, property or safety of Hall Capital, our clients, fund investors or other third parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
At your request or with your consent. In certain circumstances, we may ask for your consent to share your information with third parties. When we do, we will make clear why we want to share the information.
We do not disclose personal information about our current, prospective, or former customers to unaffiliated third parties for their telemarketing, direct mail or other marketing purposes.
HOW WE PROTECT AND RETAIN INFORMATION
We maintain physical, electronic and procedural safeguards to protect personal information from unauthorized access, use, disclosure, alteration, or destruction. We restrict access to each client’s personal information to those employees who have a business reason to know that information and all of our employees are subject to strict obligations of confidentiality. We have implemented appropriate safeguards intended to ensure that our third-party service providers protect personal information that they process on our behalf.
Although we take precautions intended to help protect information that we process, no system or electronic data transmission is completely secure. Any electronic transmission of your information is at your own risk and we expect that you will use appropriate security measures to protect your personal information. In particular, email sent to us may not be secure and you should therefore take special care in deciding what information you send to us via email. We may suspend your use of the Website without notice if we suspect or detect any breach of security.
We retain personal information as necessary for our legitimate business purposes (e.g., to respond to your inquiries, provide you with the services you have requested, or to comply with applicable legal, tax or accounting requirements). The criteria used to determine our retention periods include: the length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account and contract with us); whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); and whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations). From time to time, we may review the purpose for which personal information has been collected and decide to delete or anonymize it.
YOUR CHOICES ABOUT YOUR INFORMATION
If you would like to review, correct, delete or restrict our use of personal information about you that you previously provided to us or if you would like to receive an electronic copy of your personal information for purposes of transmitting it to another company (in each case, when these rights are provided to you by law), please contact us using the contact information below. In your request, please make clear the personal information to which your request relates and the actions you would like us to take. For your protection, we will verify your identity before responding to your request, and will process your request in compliance with applicable law. Please note that we may not allow you to review or delete certain data for legal, security or other reasons.
YOUR EUROPEAN UNION PRIVACY RIGHTS
If you are located in the European Union, you have the right to lodge a complaint with a data protection authority about how we process your personal information. Hall Capital is the “data controller” of your personal information. As a data controller, Hall Capital is subject to requirements under applicable data protection law and regulation, including the General Data Protection Regulation ((EU) 2016/679) and the Data Protection Act 2018, and any other European Union member state legislation in force from time to time that regulates the processing of personal information.
We may transfer your personal information to the US where are offices and servers are located, subject to suitable data protection safeguards (when required). If you are located in the European Union, please contact us using the contact information below to learn more about our safeguards for transfers of your personal information
If you are located outside of the United States, please be aware that any information you provide to us maybe transferred to, processed, maintained, and used outside your jurisdiction of residence where the privacy and data protection laws may not be as protective as those in your jurisdiction.
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. As noted above, Hall Capital does not disclose personal information about you with third parties for their direct marketing purposes.
LINKS TO OTHER WEBSITES AND SERVICES
If you have any questions about our privacy practices, please feel free to contact us at Compliance@hallcapital.com.