Privacy Policy

1. General 

LITCHFIELD ASSET MANAGEMENT, INC is committed to protecting the privacy of any person or entity that uses or makes use of its services, products, or system (“User” or “Users”). This privacy policy (hereinafter “Policy”) explains when and how personal information is collected, used, disclosed, and protected with respect to LITCHFIELD ASSET MANAGEMENT, INC. website located at www.litchfieldmgmt.com(the “Site”). By using the Site, the User fully understands and consents to the privacy practices described in this Policy, as reasonably modified from time to time by LITCHFIELD ASSET MANAGEMENT, INC. The user has carefully reviewed this Policy in order to fully understand LITCHFIELD ASSET MANAGEMENT, INC. data privacy practices. LITCHFIELD ASSET MANAGEMENT, INC. is also covered by this privacy policy.

2. Personal Information

Personal Information shall be defined, but not limited to, as information that is specifically identifiable to a unique individual, information such as a name, address, individual’s telephone number, e-mail address, account number, information about an individual’s activities if directly linked to that person (hereinafter “Personal Information”). Personal Information also includes, but shall not be limited to, demographic information, such as date of birth, one’s gender, geographic area, and personal preferences if such information can be identifiable and unique.

3. Personal Information We Collect

LITCHFIELD ASSET MANAGEMENT, INC. collects Personal Information from Users in a number of ways, examples such are: when Users visit LITCHFIELD ASSET MANAGEMENT Site, LITCHFIELD ASSET MANAGEMENT collects Personal Information when Users: (1) register and set up an account; or (2) contact LITCHFIELD ASSET MANAGEMENT by e-mail for any reason; or (3) Users enter the contact information of clients or potential clients for the purpose of engaging with them through the use of LITCHFIELD ASSET MANAGEMENT platform. (4) Onboarding and tech support. When Users visit LITCHFIELD ASSET MANAGEMENT website, some information is also automatically collected, such as the Users computer’s Internet Protocol (“IP”) address, Users computer’s operating system, the browser type, the address of a referring website, and the time and date of Users visit and purchases. LITCHFIELD ASSET MANAGEMENT treats this information as Personal Information if it is combined with or linked to any of the identifying information mentioned above. While these may be some examples of how LITCHFIELD ASSET MANAGEMENT can gather and obtain User Personal Information, the User shall not consider this to be an exhaustive list.

4. How We Use Personal Information

LITCHFIELD ASSET MANAGEMENT uses Personal Information to process User requests and provide Users with services, to inform Users about other products, to provide Users with products and/or services LITCHFIELD ASSET MANAGEMENT believes may be of interest to the User. When LITCHFIELD ASSET MANAGEMENT uses User Personal Information in its own marketing efforts, LITCHFIELD ASSET MANAGEMENT provides Users with options and does not disclose the User’s Personal Information to third parties, except as described in this Policy. Personal Information provided online may be linked together or merged with other Personal Information so that LITCHFIELD ASSET MANAGEMENT may better understand User needs and inform Users about LITCHFIELD ASSET MANAGEMENT products or services. LITCHFIELD ASSET MANAGEMENT also uses User Personal Information to send Users informational emails, including without limitation to newsletters, notifications by account owners, project managers, forum moderators, group members, and reminders of event schedules and attendance.

5. Emails

If Users send emails through LITCHFIELD ASSET MANAGEMENT Site, the User must understand that the email will include an email address and any personal message included. Due to the nature of the email being sent from LITCHFIELD ASSET MANAGEMENT Site, these emails are not private communications and therefore are not confidential. LITCHFIELD ASSET MANAGEMENT has no responsibility to keep such information confidential if the User sends emails through LITCHFIELD ASSET MANAGEMENT Site. Users shall not use the Site or any software provided through the Site to send spam or content that violates this agreement or any other User agreement. To stop receiving emails from us or our clients, please click the link found at the bottom of each email or update your account preferences.

6. Security

LITCHFIELD ASSET MANAGEMENT has put security measures into place in an effort to protect User’s Personal Information while such information is under LITCHFIELD ASSET MANAGEMENT control. All Personal Information relating to Users are stored in a reasonably secure environment, separate from the Site. User’s account information is accessible online only through the use of a confidential password. To protect the confidentiality of Personal Information, the User must keep his password confidential and not disclose it to any other person. Users are solely responsible for all uses of the Site by any person using a User password. Users shall advise LITCHFIELD ASSET MANAGEMENT immediately if User believes its password has been misused or improperly obtained.

7. Control of Personal Information

Companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. The types of personal information we collect and share depend on the product or service you have with us. This information can include (but is not limited to):

Login information

Email addresses

Phone numbers

Credit Card information

LITCHFIELD ASSET MANAGEMENT does not share any of this information and recommends clients change their assigned password after tech setup and onboarding is complete. To protect your personal information, we use security measures including computer safeguards and educating our employees about the importance of confidentiality and customer privacy. We collect your personal information, for example, when you:

provide us your information to set up your Technology Tools

provide account information for payment

provide us your login information for electronic marketing services

LITCHFIELD ASSET MANAGEMENT gives the User the opportunity to opt-out of receiving communications from LITCHFIELD ASSET MANAGEMENT, and to limit the use and disclosure of the User’s own Personal Information for purposes other than which it was originally collected or subsequently authorized. Every non-transactional email sent by LITCHFIELD ASSET MANAGEMENT servers includes a link to manage preferences. Use that link to opt-out of any communications from that sender. LITCHFIELD ASSET MANAGEMENT does not sell, rent, or share Personal Information with third parties without the User’s prior consent, except in the limited circumstances, such circumstances described in this Policy. LITCHFIELD ASSET MANAGEMENT acknowledges that EU individuals have the right to access the personal information that we maintain about them. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his query to the contact information listed below. If requested to remove data, we will respond within a reasonable timeframe.

LITCHFIELD ASSET MANAGEMENT may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. Information about LITCHFIELD ASSET MANAGEMENT Users, including Personal Information, may be disclosed or transferred as part of, or during negotiations of, any merger, sale of company assets, or acquisition.

Notwithstanding any other provision, LITCHFIELD ASSET MANAGEMENT may also engage a data provider who may collect web log data from contacts in LITCHFIELD ASSET MANAGEMENT accounts (including IP address and information about the browser or operating system), or place or recognize a unique cookie on such contacts’ browsers to enable the delivery of customized content. These cookies contain no personally identifiable information. The cookies may reflect de-identified demographic or other data linked to data that LITCHFIELD ASSET MANAGEMENT users voluntarily have submitted to us, e.g., email address, that we may use to interface with a data provider solely in hashed, non-human readable form. To opt-out of these data provider cookies, please go to http://www.aboutads.info/choices

8. Cookies, IP Addresses, and URLs

Automatically Collected Information: LITCHFIELD ASSET MANAGEMENT automatically receives certain types of Personal Information whenever a User interacts with LITCHFIELD ASSET MANAGEMENT. For example, when a User visits the Site, LITCHFIELD ASSET MANAGEMENT automatically collects the User IP address and the type of browser the User uses. Information may be automatically collected through the use of a term called “cookies.” LITCHFIELD ASSET MANAGEMENT also collects various types of information called ‘clickstream information’, which is information about Users browsing behavior, such as IP address information, entry, and exit points for the Site, search terms, website addresses, User visits, page views, and impressions. Cookies are also collected. Cookies are small text files placed on Users hard drive by a web site when Users visit a particular website. These files identify a User’s computer and record a User’s preferences and other data about a User’s visit so that when the user returns to the site, the site knows who the User is, and can personalize the User’s visit. Most browsers automatically accept cookies as the default setting. Users can modify the setting to reject cookies or to prompt Users before accepting a cookie from the site’s User visit by editing browser options. LITCHFIELD ASSET MANAGEMENT may place or recognize a unique cookie on Users browser to enable Users to receive customized content or services. Any cookies made available to shopping carts or other tracking information sent to third parties will reflect only de-identified demographic or other data linked to data Users have voluntarily submitted to LITCHFIELD ASSET MANAGEMENT, will be encrypted, and will not be used to identify Users individually. If Users decide not to accept LITCHFIELD ASSET MANAGEMENT cookies, Users will still be able to access those parts of LITCHFIELD ASSET MANAGEMENT site available to the general public, but Users may not be able to login or use the site’s features or services, and Users may have a less satisfactory experience.

9. Links to Other Websites

LITCHFIELD ASSET MANAGEMENT Site may contain links to other websites. Any Personal Information User provided on the linked pages, is provided directly to that third party and is subject to that third party’s privacy policy. Except as described above, LITCHFIELD ASSET MANAGEMENT is not responsible for the content or privacy and security practices and policies of web sites to which LITCHFIELD ASSET MANAGEMENT links. Links from LITCHFIELD ASSET MANAGEMENT’s Site to third parties or to other sites are provided for User convenience. LITCHFIELD ASSET MANAGEMENT encourages Users to learn about their privacy and security practices and policies before providing them with Personal Information.

10. Policy Changes

LITCHFIELD ASSET MANAGEMENT reserves the right to change or alter this Policy at any time. LITCHFIELD ASSET MANAGEMENT may use User Personal Information for new, unanticipated uses not previously disclosed in this Policy. If LITCHFIELD ASSET MANAGEMENT’s privacy practices change, LITCHFIELD ASSET MANAGEMENT will post the policy changes to our website and notify Users by indicating the date the privacy policy was last updated. LITCHFIELD ASSET MANAGEMENT encourages Users to check back at LITCHFIELD ASSET MANAGEMENT Site periodically if the User is concerned about how the Users Personal Information is used.

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Our site uses technologies of third-party partners to help us recognize your device and understand how you use our site(s) so that we can improve our services to reflect your interests and serve you advertisements about the [products and/or services] that are likely to be of more interest to you. Specifically, these partners collect information about your activity on our site(s) to enable us to measure and analyze traffic and browsing activity on our site(s);

We may share data, such as hashed email derived from emails or other online identifiers collected on our site(s) with our advertising partners. This allows our partners to recognize and deliver you ads across devices and browsers.   

Opting-Out 

Our partners may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. For this reason, you can use the following third-party tools to decline the collection and use of information for the purpose of serving you interest-based advertising: