Fundstrat Privacy Policy

Last Updated 6/18/2021

We are pleased that you have elected to visit the website, fundstrat.com (the “Website” or the “Site”), which is operated by Fundstrat Global Advisors (“Fundstrat” “us” and “we”). Fundstrat is a market-leading independent research firm that, through the Website, offers individual investors the opportunity to subscribe to weekly newsletters and research packages which provide data and information to help investors understand and formulate investment strategies (“Subscription Packages”). The Website also offers members general information about markets, investments and related financial news *(collectively, with Subscription Packages, “Services”).

Fundstrat respects privacy rights, and is committed to safeguarding the Personal Information entrusted to us by our clients and visitors to our Site. Fundstrat has implemented this Privacy Policy to govern the use of Personal Information that we collect through the Website, including Personal Information you send to us. This Privacy Policy does not govern Personal Information collected from any other source or in any other manner. This Privacy Policy is intended to provide you with information as to: (i) the type of information that is collected, (ii) how the collected information is used and with whom it is shared; (iii) how we intend to protect the information; and (iv) how you can access such information and have it modified and/or removed.

This Privacy Policy may be changed from time to time, and we reserve the right to make changes without prior individual notice. Such changes are effective upon publication of the revised Privacy Policy. Please review this Privacy Policy often so that you will remain abreast of Fundstrat’s current policies, including its policies concerning the gathering and use of information that may be collected on our Site. You are responsible for making sure you are aware of the provisions of Fundstrat’s most current Privacy Policy. You can tell when the Privacy Policy was last modified by checking the “updated” date.

California Privacy Rights

Under California law, California residents who have provided personally identifiable information to a company may have the right to request the categories of Personal Information and the specific pieces of personal information that the company has collected from you. California residents also may have the right to request a list of all third parties to whom that company has disclosed and/or sold such information for the third parties’ business purposes during the preceding calendar year, along with a list of the categories of Personal Information that has been so disclosed and/or sold. Fundstrat only shares users’ Personal Information, including but not limited to e-mail addresses, with third parties with your consent, and gives you the right to opt out of having your Personal Information disclosed to third parties for the third parties’ direct marketing purposes. If you are a California resident who would like information on how to exercise your rights concerning third party disclosures under California law, you may send an email to inquiry@fundstrat.com For avoidance of doubt, this provision is made applicable to all users of the Website who want to request information about the Company’s use of their personal information, whether or not such user resides in California.

Collection and Use of Information Personal Information

Personal Information is information that uniquely identifies you, such as your name, address, email address, and telephone number. When you register with Fundstrat and subscribe to one of our services, Fundstrat will collect your Personal Information. For example, we collect your Personal Information if you subscribe to one of our investment packages or contact us with inquiries. When you subscribe to one or more of our services, your subscription and account information is password-protected. Only you have access to password-protected areas of the Website. Do not share your password with anyone Additionally, when you enter any password-protected area of the Site, then the Site will recognize who you are and will collect information that you submit. Any information collected about you from that Site may be associated with other information that Fundstrat has collected about you. We may ask for additional information subject to laws and regulations governing the financial industry, which may require additional information for Know-Your-Customer and Anti-Money Laundering Purposes.

IP Address

An IP (Internet Protocol) address is a number that is automatically assigned to your computer by your internet service provider when you log on. Your IP address is not linked to your Personal Information but Fundstrat does reserve the right to use IP addresses to identify individuals who threaten the Site or other users or visitors. IP addresses may also be used to help diagnose problems with the Site and to gather broad demographic information. The information we collect in this manner is usually anonymized, and we will not identify you from this data, subject to a need to do so to protect the Site and/or other users.

Other Information

When you access the Website, Fundstrat will automatically receive some information about your use of the service. The type of information that is automatically collected by Fundstrat includes such things as the date and time of access of the Website, the Internet protocol (IP) address of the computer that you are using, the domain and host from which you access the Internet, your browser software and operating system, the referring website address, and the specific activities you are engaged in while visiting the Site. This aggregate tracking information is used to help Fundstrat improve and enhance the website experience for all of its visitors. The information we collect in this manner is usually anonymized, and we will not identify you from this data, subject to a need to do so to protect the Site and/or other users.

Your Consent

We only collect, use and/or disclose your Personal Information with your consent. We will request your consent to use your Personal Information for a particular purpose when we collect such information. Additionally, when you submit your Personal Information to us to become a subscriber and/or registered user of our services, you are consenting to the collection of your Personal Information for the purposes identified or apparent at the time of collection and/or as otherwise described in this Privacy Policy.

You must be 18 years of age and a resident of the United States to use this Site. Fundstrat does not knowingly collect or maintain any Personal Information from children under the age of 13, and no part of any of the Site is designed with the purpose of attracting such children.

Use of Your Personal Information

We use your Personal Information with your consent for the purposes for which it is submitted, such as to provide the Subscription Packages and other services and products offered by Fundstrat through the Website; to reply to your requests for information; and to respond to other requests you have. Your Personal Information may also be used in the following ways:

• to deliver materials, information and services to you, • to give you notice of and/or resolve any problems that may arise in connection with our services,
• to better understand the needs and interests of our customers, • to analyze the success of our products and services and Site,
• to manage the Site’s interactive functionality,
• to help Fundstrat improve and enhance the Site experience for all of its visitors, and customize the content on our Site,
• to provide information about potential client/consultant projects,
• for compliance with Fundstrat’s legal and regulatory obligations,
• as otherwise reasonably required to provide customer services and maintain the Site,
• to investigate potentially unlawful activity
• for any other purpose outlined in this Privacy Policy,
• with your consent, to communicate with you about Fundstrat products or services we think may be of interest to you, and as permitted by law.
• We may also use your Personal Information to contact you via direct postal mail and/or electronically, with your consent, regarding your relationship with Fundstrat.

Opting in and opting out of electronic communications.

You may opt out of receiving future electronic communications, such as emails, from Fundstrat at any time by:

• Sending an e-mail directly to inquiry@fundstrat.com;
• Writing to Fundstrat’s corporate offices at 150 E 52nd St 3rd Floor, New York, NY 10022 or
• Clicking on the “opt-out” or “unsubscribe” link in any electronic communication you receive.

Do Not Track Signals.

Certain web browsers provide users with an option by which you may have your browser send a “Do Not Track” signal to the website that you are visiting, advising the recipient website that you do not want to have your online activity tracked. However, the way browsers communicate such “Do Not Track” signals is not yet uniform and accordingly, our Site do not take any action in response to such signals. In the event a final standard is developed and accepted, we may reassess how we should respond to such signals.

Use of Your Personal Information Within Fundstrat.

Fundstrat does not share your Personal Information with our affiliates, which are companies controlled or owned by us, or companies that control us, or are under common control with us (“Affiliates”) without your express consent. The Site is intended for users in the United States and its territories and possessions, but if you use the Site from any country outside the United States, the various communications will necessarily result in the transfer of information across international boundaries, and by visiting the Site, you consent to these transfers as required or permitted by applicable law. We will not share your Personal Information with unaffiliated third parties, except as stated in this Privacy Policy, without your consent. Your Personal Information will be stored on servers located in the United States.

Use of Your Personal Information by Our Service Providers.

From time to time, we may hire third parties to assist us with certain functions and services, such as data processing, computer software and website maintenance and development, transaction processing, promotional and marketing services, customer service, professional, legal or accounting services and/or business and sales analysis. Fundstrat may share your Personal Information, without restriction (and regardless of whether you have chosen to limit our sharing of your Personal Information as collected on the Website), with such companies that we hire to perform services for us. In such situations, Fundstrat requires that these companies agree to maintain the confidentiality of your Personal Information and to comply with the safeguards described in this Privacy Policy. These companies have access to the Personal Information needed to perform their functions but are not permitted to share or use such information for any other purposes. Furthermore, in compliance with privacy laws, we also provide our opt-out lists to non-affiliated third party companies so that communications sent by those companies on Fundstrat’s behalf do not get sent to addresses appearing on our opt-out lists.

Lawful Access, Legal Action and Investigations.

Your Personal Information may be disclosed to nonaffiliated third parties as either required by, or to comply with, applicable laws and regulations. We may disclose Personal Information if we believe it is necessary to investigate, prevent, or take action regarding suspected illegal activities or fraud, situations involving the physical safety of any person, violations of our Privacy Policy, or otherwise in accordance with applicable law. For example, Fundstrat may disclose your Personal Information to comply with investigations by regulatory authorities or enforcement agencies in the United States of America or elsewhere, or to protect against or prevent actual or potential fraud. Furthermore, Fundstrat may disclose your Personal Information if it has a reasonable good faith basis to believe that it is required to do so by law, compelled by court order or legal process, or is reasonably necessary and/or appropriate to:

(i) protect the rights, property and/or safety of Fundstrat or any other person or entity; or
(ii) prevent or take action concerning any alleged: (a) illegal activity or (b) breach of the Privacy Policy of the Website.

Use of Cookies, Google Analytics

The Site may make use of “cookies” – small data files which we may send to your computer on the basis of the information that we have collected about your visit. They contain information allowing us to recognize when you are visiting the Site and to keep track of your preferences. Through the use of a cookie, we also may automatically collect information about your online activity on our Site, such as the web pages you visit, the links you click, and the searches you conduct on our site. Cookies are stored in your computer’s browser or on your hard disk and can then be retrieved by the website.

If you want to delete any cookies that were already sent to your computer or personal device, please refer to your web browser’s “Help” facility. In addition, most web browsers can be set to prevent you from receiving new cookies, notify you before accepting cookies or disable cookies altogether. Details about this can normally be found in the “Help” facility provided with your browser. Please note that if you disable cookies you may not be able to take advantage of some of the Website’ interactive functionality.

The Website may also use Google Analytics, a web analytics tool that helps website owners understand how visitors engage with their website. We can view a variety of reports about how visitors interact with our Site so we can improve it. Google Analytics collects information anonymously, and uses cookies, and IP addresses, and reports website trends without identifying individual visitors. For more information related to Google Analytics, click here https://www.google.com/analytics/learn/privacy.html. You can opt-out of Google Analytics by installing the Google Analytics Opt-out Browser Add-On. For more information about and to install Google Analytics Opt-out Browser Add-on, click here: https://tools.google.com/dlpage/gaoptout?hl=en

Other, Third Party Services

The Site is enhanced by other third-party services to understand our users help us provide a better browsing experience.

Google Fonts:
Google Fonts provides different font faces for our Website. You can read more about the Google Fonts’ service here.

BunnyCDN:
BunnyCDN helps the Site deliver a faster and snappier user experience by relaying static files of the Site thus reducing latency. BunnyCDN automatically serves images and other resources from the closest network node. You can read BunnyCDN’s privacy and data policy here.

Typeform:
Our Website displays Typeform polls and questionnaires on select pages. You can read Typeform’s privacy policy here.

Disclosure of Personal Information to Non-Affiliated Third Parties

We will not sell, rent or market Personal Information collected on this Site to non-affiliated third parties for their marketing purposes, unless we have your consent. However, we may disclose aggregated statistics about visitors to the Site, along with anonymous information concerning individual users of the Site. We may combine anonymous information and/or aggregate information we collect with additional anonymous and/or aggregate information collected from other sources. We may share anonymous information (including aggregate information) we collect regarding our users with third parties (such as advisors, and/or consultants) for various business purposes including conducting general business analysis, and developing website content and services.

Retention of Personal Information

Personal Information is retained to deliver our services, to otherwise fulfill identified or apparent purposes, and for record-keeping. At some point Fundstrat may elect to destroy, erase or anonymize your Personal Information. Once anonymized, Fundstrat undertakes not to re-identify the information. You have the right to have your Personal Information removed from the Website. You are also able to edit your own account on the Website. If you want your Personal Information deleted from the Website and/or Fundstrat’s records, please e-mail Fundstrat at inquiry@fundstrat.com.

Your Privacy Choices – Limiting Information Sharing/Accessing Your Information

You have the right to access the Personal Information that we hold about you, which includes the right to amend or correct that information, as appropriate, and to receive an account of how it has been used and a list of the organizations to whom it has been disclosed. In some circumstances, you may have the right to object to Fundstrat’s use of that Personal Information. If you wish to update, amend, or change your Personal Information, please contact us at inquiry@fundstrat.com or make edits directly to your Account. You also have the right to request a copy of the Personal Information you have provided to Fundstrat by writing to 150 E 52nd St 3rd Floor, New York, NY 10022 or contacting Fundstrat at inquiry@fundstrat.com.
To protect the confidentiality of your information and respect your wishes for how it is used, Fundstrat offers “opt out” alternatives. If you have consented to the sharing of your Personal Information at any point, you may instruct us not to share Personal Information about you in the future. As noted above, you may also opt-out of receiving future electronic communications from us at any time. You may make your privacy choice at any time and it will remain in effect until you change it.

If you would like to check, change, or confirm your privacy choices please contact us at: inquiry@fundstrat.com.

Protection and Security of Information

Fundstrat maintains reasonable standards of confidentiality and security for the Website and the Personal Information collected from the Website. Physical, technical, electronic and managerial procedures have been employed to safeguard the security and integrity of Personal Information collected through the Website. The Personal Information you provide is secured using industry standard security technology. Fundstrat also restricts its own employees’ access to Personal Information. However, it is possible that someone may intercept or access communications, transmissions and/or Personal Information. You must also seek to protect against unauthorized access to any passwords and/or accounts that you use in connection with the Website, and you should remember to log off of the Website once you have completed your activities on the Website or if you have decided to step away from your computer.

In the event that Fundstrat determines that there has been a security breach that results in the unauthorized disclosure of Personal Information to a third party, Fundstrat will promptly notify consumers whose Personal Information it reasonably believes has been compromised by posting information on the Website and, if email contact is possible, then also by sending an email notification with respect to the situation.

You acknowledge that the security of online transactions you conduct using the Website cannot be guaranteed. To the fullest extent permitted at law, Fundstrat shall not accept responsibility for misuse or loss of, or unauthorized access to, your Personal Information.

Links to Other Website and Services

From time to time, the Fundstrat Site may contain links to other websites or social media features (collectively, “other websites”) that are not controlled and/or maintained by Fundstrat. Please be aware that these other websites may have different privacy policies which may subject you to different privacy practices. Please review the privacy policies of such other websites for information concerning what information is collected on such websites and how it is used. Fundstrat is not responsible for the contents or privacy practices of any linked site or any link on a linked site.

Governing Law

This Privacy Policy shall be governed by the laws of the State of New York of the United States of America, without regard to its conflict of law provisions. Please click here to review the terms relating to Disputes and Governing Law for the Site.

Contact Us

If you have any questions or complaints concerning this Privacy Policy or our handling of your Personal Information you may contact us at 150 E 52nd St 3rd Floor, New York, NY 10022 or by e-mail at inquiry@fundstrat.com.