(a) “We”, “Us”, “Our”, or “CSH” mean Clark Schaefer Hackett.
(b) “Site” or “Sites” means the CSH web site used for CSH matters and includes, without limitation, www.cshco.com; and any other related web sites used by CSH now or in the future.
(c) “You” or “Your” means You, Your registered business, and any of Your employees, officers, or agents who may use the Site.
(d) “Data” means information of any kind that You upload, input, or submit to or through the Site.
2. General Types of Information.
3. Personal Information.
In order to use our Sites, you do not need to send us any personal information. You may voluntarily provide us with personal information, such as your name and contact information, by subscribing to publications, registering for events (e.g., webcasts, seminars, or conferences) or by submitting requests through our “Contact Us” mailboxes. We may use the personal information you submit through the Site to respond to your requests (e.g. send you information about CSH’s services or events), send you administrative information or notices, send you information about our services, and for our internal business purposes. If you no longer wish to receive promotional communications from us, you may at any time request that we discontinue sending you such materials by contacting us using the contact information listed below.
We do not seek sensitive personal information on our Sites except where we are required to do so as part of the recruitment process. If you choose to apply for a job through our Sites, we may collect information such as name, address and other contact information, work and educational experience, licenses and certifications, and other personal information. Your decision to submit such information is entirely voluntary. We may use this information to process and evaluate your application for employment and to communicate with you about employment opportunities. We may also retain and use this information to identify, and communicate with you about, future potential employment opportunities with us. If we elect to make an offer of employment, this information may become part of the employee file and may be used for other employment and work-related purposes.
4. Client Personally Identifiable Information.
If you are Our client, we may collect certain personally identifiable information from You, including, without limitation, Your name, address, Social Security number, tax identification number, age, corporate name and structure, internal accounting methods, financial status, assets, income, tax information, retirement and estate plan information, transaction history, account balance, payment history, investment objectives, marital status, family relationships and other personal information. This information may also be secured from the sources described below and is subject to the conditions stated below:
(a) Sources. The personally identifiable information referenced in this paragraph may be secured or received from sources such as (i) Your transactions with Us, our affiliates and third parties; (ii) Your broker-dealer, investment advisor or financial representative; (ii) Your inquiries by mail, telephone, email or face-to-face conversations; (iii) interviews with any of the foregoing parties; and (iv) agreements, applications, forms and other documents received from You or any of the foregoing parties; and (v) information You submit voluntarily to Us.
(c) Internal Use. We restrict access to such personally identifiable information to Our personnel, Our affiliates and subsidiaries. We maintain physical, electronic and procedural safeguards to protect such personally identifiable information. We reserve the right to store your information for the amount of time we reasonably determine to be necessary in order to perform the purposes for which that information was collected or otherwise processed.
(d) Security. The security of your personal information is important to us. We seek to use reasonable physical (e.g. key card office entry, locking doors), technical (e.g. password protection, network firewalls, laptop encryption, authentication mechanisms), and administrative safeguards (e.g. confidentiality agreements, training, procedures that limit access to and use of data) to protect the information we process. However, no method of transferring data over the Internet or storing electronic data is completely secure. Therefore, while we strive to use reasonable and appropriate means to protect your personal information, we cannot guarantee absolute security.
(e) Fulfillment, Changes, and Communications. We use personally identifiable information for the purpose for which You provided it, such as to fulfill Your request for services or information, to process and administer Your requests, and to activate any online account You may have with Us. We may also use personally identifiable information to notify You of changes to this Site, to provide You with news, email offers and other information, to let You know about other information and services that may be of interest to You, and to tailor Our online offerings to Your preferences.
(g) Permitted Disclosures. We may disclose personally identifiable information to the following parties under the following circumstances: (i) to You, if you direct Us to do so; (ii) to unaffiliated financial services providers, transfer agents, custodians and trustees, banks, financial representatives, proxy services, vendors, affiliates, licensees, licensors, affiliates, solicitors, printers or third parties who assist Us or who perform services on Our behalf in order to provide You with products and services or to affect transactions that You request or authorize; (iii) to third parties if we are compelled to do so by law; and (iv) to third parties in order to protect any account You may have with Us from fraud, misfeasance, malfeasance or other wrongful act.
(h) Disclosure Required by Law. From time to time, We may be required to disclose Your personally identifiable information in response to a court order, subpoena, government investigation or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that We, in good faith, believe to be unlawful. We also may disclose certain personally identifiable information when We believe that such disclosure is reasonably necessary to protect the rights, property and safety of others or Ourselves.
5. Cookies and Similar Technologies.
CSH automatically logs certain information about user access to the Site, which may include a user’s internet protocol address, browser type, internet service provider, referring/ exit pages, operating system, as well as date and time stamps. We also use “cookies” which are small data files stored on a user’s computer to enhance your on-line experience when visiting our Site. The use of “cookies” is common practice for most Web sites; however, most Web browsers include settings that allow users to decline cookies.
Most Web browsers will allow you to see what cookies you have and delete them on an individual basis or block cookies from particular or all websites. Be aware that any preference you have set will be lost if you delete all cookies, including preference to opt-out from cookies as this itself requires an opt-out cookie to have been set. If you wish to restrict or block the cookies which are used on the Site, you can do this through your browser settings.
From time to time, CSH websites may provide links to other websites not owned or controlled by CSH that we think might be useful or of interest to you. We cannot, however, be responsible for the privacy practices used by other website owners or the content or accuracy of those other websites. Links to various non-CSH websites do not constitute or imply endorsement by CSH of these websites, any products, or services described on these sites, or of any other material contained in them.
7. Transfer of Information to the United States.
8. Access and Correction.
You may obtain a copy of Your personally identifiable information by contacting Your representative at CSH or by contacting Us online by utilizing Our Contact Us form. For Your protection, You may be required to provide proof of Your identity to obtain a copy of Your personally identifiable information. You may correct any errors in Your personally identifiable information by providing Us with the correct information, and We will delete Your personally identifiable information (except for Your transaction history) from Our records upon Your written request. However, You may not be able to access some areas of the Site if You choose to delete Your personally identifiable information. If You are or have been Our client or customer, or received any services from Us, We reserve the right to maintain archive copies of all communications and other documents in Our possession concerning or related to You, including personally identifiable information.
10. EU Data
Individuals in the European Union (EU) may have certain additional rights with respect to their personally identifiable information which is protected by law (“Personal Data”), including the rights to:
- request access to and rectification or erasure of your Personal Data as described in Section 8;
- request information about our processing, including categories of your Personal Data collected, information about the source of that collection, the purposes of processing, the recipients or categories of recipient to whom your Personal Data has been or will be disclosed;
- restrict or object to how we process your Personal Data;
- withdraw your consent for us to process your Personal Data in some circumstances;
- lodge a complaint with a supervisory authority; and
- receive your Personal Data provided to us or have that Personal Data transmitted to another controller without hindrance (also known as “data portability”)
To exercise any of these rights please contact Your representative at CSH or by contacting Us online by utilizing Our Contact Us form.
We reserve the right to ask for information verifying your identity prior to disclosing any information to you. Should we ask for verification, the information you provide to verify your identity will be used only for that purpose, and all copies of this information in our possession will be destroyed when the process is complete.
11. Contacting Us.
If You have any additional questions, please feel free to contact Us any time utilizing Our Contact Us form.
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