Effective January 6, 2017
Last Modified August 2023
OUR COMMITMENT TO PRIVACY
- Personal Information
- Why and How We Use Your Personal Information
- Why and How We Share Your Personal Information
- Your Choices for How We Collect, Use and Share Your Personal Information
- Accessing, Correcting and Deleting Personal Information
- Children’s Privacy
- Supplemental Disclosures and Rights Based on State Law
- International Users
- Data Security
- Contact Information
“Personal Information” or “Personal Data”: Information identifying, relating to or about an identified or identifiable individual, as described more fully in this Policy.
“Platform”: Our Website(s) and related functionality and online services, as applicable.
“Website”: Our website(s) located at https://www.danforthadvisors.com/.
“Danforth Advisors,” “we,” “us”: Danforth Advisors LLC.
Please refer to our Glossary for additional explanations of terms and phrases used in this Policy.
2. Personal Information
What is Personal Information?
Personal Information is information that you provide to us which personally identifies you, such as your name, email address, or billing information, or other data that can be reasonably linked to such information by Danforth Advisors.
What types of Personal Information do we collect?
We collect and use Personal Information in order to operate and provide our Platform to you. You may provide Personal Information to us, and we may collect Personal Information from you automatically as you use and navigate through our Platform.
How do we collect your Personal Information?
Information you provide to us. You may provide Personal Information to us through our Platform. For example, you may complete a form requesting additional information from us, which allows or requires you to provide certain information to us (e.g., contact information such as your name, email address, telephone number, etc.). You provide Personal Information and other information to us when you contact us through our Platform.
Information we collect automatically as you use our Platform. We collect Personal Information and information automatically about the computers, devices, browsers and your Internet activity as you use and interact with our Platform. The information we collect typically includes Unique Identifiers, browser type and settings, device types and settings, operating system, mobile network information including carrier name and phone number, and application version number. We also collect information about the interaction of your browsers and devices with our Platform, such as IP address, device type, system activity, wireless carrier name (when you use a wireless or mobile device), and the date, time, and referrer URL of your request.
Online Activity. We collect information about your activity on our Platform, Internet, network, and other online activity information, such as browsing history, search history, and information regarding your interaction with our Platform and other websites. We use various technologies to collect and store location information, including cookies, pixels or pixel tags, local storage, such as browser web storage or application data caches, databases, session replay, and server logs.
Location. We collect information about your location when you use our Platform, which helps us provide our Platform Services, features and functionality. Your location can be determined with varying degrees of accuracy by:
- IP address
- Sensor data from your device
- Information about things near your device, such as Wi-Fi access points, cell towers, and Bluetooth-enabled devices
The types of location data we collect depend in part on your device and account settings. For example, you can turn your mobile device’s location on or off using the device’s settings app. You may also be able to turn on location history if you want to create a private map of where you go with your devices.
Third-Party Sources. In some circumstances, Danforth Advisors also collects information about you from publicly-accessible sources. We may collect information about you from trusted partners, such as marketing partners who provide us with information about our potential customers, and security partners who provide us with information to protect against fraud and abuse of our Platform.
As described more fully below, we use information that we collect about you or that you provide to us, including any Personal Information for the following purposes:
- Provide our Platform and related services to you.
- Provide you with information that you request from us.
- Support, develop, troubleshoot, and debug our Platform.
- Provide you with support for the Platform and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- Personalize your Platform experience and to deliver content and product and service offerings relevant to your interests.
- Provide personalized and interest-based advertising. (More information below.)
- Authenticate use, detect fraudulent use, and otherwise maintain the security of our Platform.
- Help maintain the safety, security, and integrity of our Platform.
- To respond to law enforcement requests, court orders, and subpoenas and to carry out our legal and contractual obligations.
- In any other way we may describe when you provide the information.
- Fulfill any other purpose for which you provide it.
- For any other purpose with your consent.
Provide our Platform and Related Services. We use your Personal Information to operate, maintain, supervise, administer, improve and enhance our Platform and related Services, features and functionality. We use your contact information to communicate and interact with you, such as to send you emails and text messages about our Platform. We use the IP address assigned to your device to send you the data you request to display on your device. We use unique identifiers stored in cookies on your device to help us authenticate you as the person who should have access to certain areas and features of our Platform. We also use your information to ensure our Platform is working as intended, such as tracking outages or troubleshooting issues that you report to us. And we use your information for research and development for our business, and to make improvements to our Platform.
Analyze Use of the Platform.We use data collected from you and your devices for analytics and measurement to understand how our Platform is used. We use a variety of tools to do this, such as Google Analytics and similar third-party online data analytics services.
Personal Information Provided by Third Parties. We may use Personal Information collected automatically and associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Platform and to deliver a better and more personalized service by enabling us to:
- estimate our audience size and usage patterns;
- store information about your preferences;
- customize our Platform according to your individual interests;
- speed up your searches; and
- recognize you when you return to our Platform.
Personalized and interest-based advertising. We may use your Personal Information to provide interest-based advertisements from us and that are customized to your particular preferences, including for companies that are not affiliated with us. See additional information under Why and How We Share Your Personal Information below for additional information about our sharing your Personal Information for personalized and interest-based advertising.
Please contact us using the Contact Information at the end of this Policy, or use the Contact Us page of our Platform if you would like to opt out or change your preferences with respect to receiving advertising and marketing communications from us.
We share Personal Information with third parties under certain circumstances and for certain purposes described throughout this Policy, including:
- Service providers and others to operate our Platform and Services. We share your Personal Information with our affiliates, vendors, service providers, and business partners, including providers and vendors we use for operating and maintaining our Platform, and its features, functionality and Services. These third parties include data hosting and data storage partners, analytics, ad network, advertising (including interest-based advertising), technology services and support, and data security. We contractually require these third parties to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
- Our business purposes. We may share your Personal Information with our affiliates, vendors, service providers, and business partners, including providers and vendors we use for our business activities and operations generally, such as data hosting and data storage partners, analytics, ad network, advertising, technology services and support, and data security. We may also share your Personal Information with professional advisors, such as auditors, law firms, and accounting firms.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info).
- Affiliates.We may share your Personal Information with our subsidiaries and affiliates.
- Compliance with law. We may share your Personal Information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, subpoenas, and regulatory inquiries.
- Protect Rights, Property and Safety. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Danforth Advisors, our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- Business transfers. We may share your Personal Information to a buyer, potential buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our users are among the assets transferred.
- De-identified information. We may also de-identified information, so that it cannot be reasonably used to identify any individual, with third parties for marketing, advertising, research, or similar purposes.
- Knowledge and Consent. With your consent, pursuant to your instructions, to fulfill a purpose for which you provide the information to us, and for any other purpose disclosed by us when you provide the information.
5. Your Choices for How We Collect, Use and Share Your Personal Information
We provide you with various choices on how you can opt out of our certain uses and sharing of your Personal Information. As a general rule, you cannot opt out of our collection, use and sharing of Personal Information to the extent it is necessary to provide the Platform or related basic services, features and functionality available on or through the Platform to you.
Cookies.You can change the cookie settings that will be placed when you use our Platform by changing the settings on your Internet browser. You can also block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please note that internet browsers allow you to change your cookie settings. These settings are usually found in the ‘options’ or ‘preferences’ menu of your internet browser. However, if you use your browser settings to block all cookies (including strictly necessary cookies), you may not be able to access or use all or areas and aspects of our Platform.
Personalized and interest-based advertising. You can generally opt out of receiving personalized and interest-based advertisements from third-party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt out pages on the NAI website and DAA website. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website. You can learn more about interest-based advertisements and your opt out rights and options on the NAI website and DAA website.
Messages. If you do not wish to have your email address used by Danforth Advisors to send you advertising messages and content, you can opt out at any time by clicking the unsubscribe link at the bottom of any marketing emails you receive from us. You may have other options with respect to marketing and communication preferences through our Platform.
Do Not Track Signals.We do not track you over time and across third-party websites or other online services for any purpose. Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities.
6. Accessing, Correcting and Deleting Personal Information
Access, Corrections and Deletion. Please contact us using the Contact Information at the end of this Policy, or use the Contact Us page of our Platform if you have any questions regarding reviewing, accessing, correcting or deleting your Personal Information. . Please promptly inform us of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible. You may also have certain deletion rights in accordance with applicable law. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
Copies and Retention of Personal Information. Please contact us using the Contact Information at the end of this Policy, or use the Contact Us page of our Platform if you have any questions about obtaining copies or the retention of your Personal Information. . Please promptly inform us of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible. You may also have certain deletion rights in accordance with applicable law. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
Exporting Data. If you need to export or a copy of your data, please let us know and we will assist you with your request. We retain the data we collect for different periods of time depending on what it is, how we use it and applicable legal requirements. We may retain some data for longer periods of time than other data when necessary for legitimate business or legal purposes, such as security, fraud and abuse prevention, or financial record-keeping.
7. Children’s Privacy
Our Platform is not intended for children under 18 years of age. No one under age 18 may provide us with any Personal Information on or through the Platform. We do not knowingly collect Personal Information from children under 18. If you are under 18, do not use or provide any information on our Platform or on or through any of its features, register on the Platform, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information directly from a child under 18, please contact us using the Contact Information at the end of this Policy.
In addition to the disclosures and rights set forth elsewhere in this Policy, you and other users may have certain rights based on applicable state law, e.g., for California residents, the California’s Privacy Rights Act (CPRA). Other states have passed consumer privacy laws that may be applicable to Danforth Advisors and your use of this Site. These supplemental disclosures and rights apply to you and your use of our Platform to the extent applicable state law applies to Danforth Advisors and your use of our Platform. Please contact us using the Contact Information at the end of this Policy, or use the Contact Us page of our Platform if you have any questions regarding your rights under applicable state law.
Categories of Personal Information Collected
Personal information does not include information that is: (a) publicly available information from government records; (b) de-identified or aggregated consumer information; or (c) certain information excluded from the scope of applicable state law (e.g., PHI covered under HIPAA and medical information may be covered under HIPAA and other state laws).
Categories of Sources From Which We Have Collected Personal Information
We collect Personal Information directly from you, for example when you provide it to us, when you contact us through our Platform; and indirectly from you automatically through your computer or device as you use our Platform. We may also collect Personal Information about you from our advertising partners and service providers.
Use of Personal Information
Sharing Personal Information
Danforth Advisors may disclose your Personal Information to a third party for one or more business purposes. When we disclose Personal Information for a business purpose, such as to service providers, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
Disclosures of Personal Information for Business Purposes
We may disclose your Personal Information for our business purposes, such as your contact information, other information you have provided to us and unique identifiers that identify you to us or to our service providers, such as companies that assist us with marketing and advertising. We disclose your Personal Information to certain third parties such as our vendors, business partners, service providers, including companies that assist us with marketing and advertising.
Access Request Rights
You may have the right to request that Danforth Advisors disclose certain information to you about our collection and use of your Personal Information over the past 12 months for the above business and commercial purposes. To submit an access request, see Exercising Access and Deletion Rights, below. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you.
- If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
- Sales, identifying the Personal Information categories that each category of recipient purchased; and
- Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You may have the right to request that Danforth Advisors delete your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless certain exceptions apply.
Exercising Access and Deletion Rights
To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 857-995-6500
- Emailing us at email@example.com or firstname.lastname@example.org
Only you or your legal representative authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify whether you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not discriminate against you for exercising any of your rights under applicable state law. Unless permitted by applicable law, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you with a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
9. International Users
Danforth Advisors is the data controller of the Personal Information you provide on the Platform and/or through the Services.
Consent to Processing of Personal Information.
We rely on your consent as a lawful basis to process your Personal Information for the following purposes:
- Initial collection of Personal Information through the Platform and/or the Services; and
- Providing you with marketing or promotional communications. You may opt out of such communications at any time by clicking the “unsubscribe” link found within the Danforth Advisors email updates and changing your contact preferences.
We also process Personal Information based on our contractual obligations to provide you the Platform and/or the Services as described in How do we share your Personal Information, including:
- To enable the Platform to function as expected.
- To communicate with you in response to customer services inquiries, to deliver non-promotional, service-related emails, or to administer surveys and questionnaires.
- To tailor your experience based on your general region.
Danforth Advisors may also process Personal Information pursuant to a legal obligation or to protect your vital interests or those of another person.
We will process your Personal Information as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personal Information if your rights and freedoms outweigh our legitimate interests. Our legitimate interests are to: facilitate communication between Danforth Advisors and you; detect and correct bugs and to improve our Platform and/or the Services; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; develop our Products and Services.
We have appointed a Data Protection Officer in the United Kingdom (“UK”) in compliance with the General Data Protection Regulations. Danforth Advisors and its Data Protection Officer may be contacted in any manner set forth below in Contact Us.
What rights do I have?
Individuals located in the UK and other countries and jurisdictions may have certain rights with respect to their Personal Information. These rights include:
- Access and Update. You can review and change your Personal Information by notifying us through the Contact Information below of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
- Restrictions. You have the right to restrict our processing of your Personal Information under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Information is determined to be unlawful, or if we no longer need your Personal Information for processing but we have retained it as permitted by law.
- Portability. To the extent the Personal Information you provide Danforth Advisors is processed based on your consent or that we process it through automated means, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Information in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Information to another controller, when technically feasible.
- Withdrawal of Consent. To the extent that our processing of your Personal Information is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Information.
- Deletion / Right to be Forgotten. You have the right to request that we delete all of your Personal Information. We cannot delete your Personal Information except by also deleting your user account, and we will only delete your account when we no longer have a lawful basis for processing your Personal Information or after a final determination that your Personal Information was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Information as set forth in this policy. In addition, we cannot completely delete your Personal Information as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.
- Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
- How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods listed under Contact Us below. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Information, you may be charged a fee subject to a maximum set by applicable law.
Automated Decision Making
Our processing of Personal Information may include automated decision making, including profiling, which may produce a legal effect concerning you or similarly significantly affect you. The algorithms used for our automated decision-making process classifies and categorizes your interests and preferences based on data collected by the Platform and Personal Information collected by the Platform.
10. Data Security
Security Measures. We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Platform like message boards. The information you share in public areas may be viewed by any user of the Platform.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Platform. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures deployed on the Platform.
Consent to Processing of Personal Information in the United States. In order to provide our Platform, products, and services to you, we may send and store your Personal Information outside of the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Information. Your Personal Information may be processed and stored in the United States and federal, state, and local governments, courts, or law enforcement or regulatory agencies in the United States may be able to obtain disclosure of your information through the laws of the United States. By using our Platform, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Information outside the country where you reside or are located, including in the United States.
YOUR CONTINUED USE OF OUR PLATFORM FOLLOWING THE POSTING OF CHANGES CONSTITUTES YOUR ACCEPTANCE TO SUCH CHANGES.
12. Contact Information
Danforth Advisors LLC
300 5th Avenue
Waltham, MA 02451
Browser Web Storage enables websites to store data in a browser on a device. When used in “local storage” mode, it enables data to be stored across sessions. This makes data retrievable even after a browser has been closed and reopened. One technology that facilitates web storage is HTML 5.
A Cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. You can configure your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies.
A Pixel or Pixel Tag is a type of technology placed on a website or within the body of an email for the purpose of tracking certain activity, such as views of a website or when an email is opened. Pixel tags are often used in combination with cookies.
An Application Data Cache is a data repository on a device. It can, for example, enable a web application to run without an internet connection and improve the performance of the application by enabling faster loading of content.
Interest-based Advertising is sometimes referred to as personalized or targeted ads. Interest-based ads are used to display features, products, and services that might be of interest to the user.
Server Logs. Like most websites, our servers automatically record the page requests made when you visit our sites. These “server logs” typically include your web request, Internet Protocol address, browser type, browser language, the date and time of your request, and one or more cookies that may uniquely identify your browser.
Session Replay provides the ability to replay a visitor’s journey on a web site or within a mobile application or web application. Replay can include the user’s view (browser or screen output), user input (keyboard and mouse inputs), and logs of network events or console logs. Session replay is used to help improve customer experience, analyze usability and help identify obstacles in conversion processes on websites. It can also be used to study a website’s usability, customer behavior, interests, and the handling of customer service questions as the customer journey, with all interactions, can be replayed. It can also be used to analyze fraudulent behavior on websites.
A Unique Identifier is a string of letters, numbers and characters that can be used to uniquely identify a computer, device, personal device, browser or app.
Different identifiers vary in how permanent they are, whether they can be reset by users, and how they can be accessed. Unique Identifiers can be used for various purposes, including security and fraud detection, syncing data from your device(s) to our Platform, remembering your preferences, and providing personalized advertising. You can configure your browser to refuse all cookies or to indicate when a cookie is being sent. See your browser documentation for additional information.
On other platforms besides browsers (e.g., personal devices), Unique Identifiers are used to recognize a specific device or app on that device. For example, a Unique Identifier can be used to provide relevant advertising on mobile devices and can be managed in your device’s settings. Unique identifiers may also be incorporated into a device by its manufacturer (sometimes called a universally unique ID or UUID), such as the IMEI-number of a mobile phone. For example, a device’s unique identifier can be used to customize our Platform and Services to your device or analyze device issues related to our Platform and Services.