For more information about the information we share with third parties and the recipients of such information, please refer to the How We Share Your Information section of this Policy. Please note that this Policy does not otherwise cover the use of personal information by those third parties or their services, and we do not take responsibility for their privacy practices.
You may have certain rights or choices that relate to your personal information, including choices about how we share your personal information with others. For more information, please refer to the Your Choices and Rights section of this Policy.
When you use or visit our Services, we collect information directly from you (e.g., your email address when you subscribe to our mailing list). We may also generate information about you (e.g., information about your device while you visit our website).
We use your information to provide the information and Services on our website, tailor your experience, send you marketing communications, and for other purposes described below.
We share your information with affiliates; with our service providers; with other business partners (including advertising partners); and others as described below. We share information to provide and improve our Services, for our own marketing purposes, and for other purposes as described below.
We maintain technical, administrative, and physical security measures designed to protect your information. We may retain your information for as long as necessary for purposes described below.
You have choices about your information, and in some circumstances, you may be able to opt-out of receiving marketing communications, change your communication preferences, access and update your information, update location sharing options and exercise choices regarding cookies. These choices and other options you may have are described in more detail below.
We operate in the United States and our services are intended for US residents. If you are located outside of the United States, information about you may be transferred to, or accessed by, entities located in countries outside of your home country. To protect your information, any such international transfers will be made in accordance with applicable law.
Our Services may contain links to other websites or services that are not owned or controlled by Hadley, including links to our business partners.
Our Services are not directed at or intended for use by children, nor do we knowingly collect information from children under 16 years of age.
We update this Policy from time to time, and changes will be effective when posted (as identified in the Policy).
If you have any questions about this Policy or the way your personal information has been used, please contact us at [email protected] or using the contact details set out below.
As you visit or use our Services, we collect the following categories of personal information directly from you:
You may choose not to provide some of the personal information described above. Please note, however, that many of our Services require some personal information to operate, so if you choose not to provide the personal information necessary to operate and provide you with a particular Service or feature of that Service, you may not be able to use that Service or feature.
We may also receive certain categories of personal information from third parties, such as third-party websites, applications, social media networks, and services (which may include publicly-available sources; each of these is a “third-party platform”), our affiliates and other third parties. If you are an existing Hadley customer, we will combine this information with information we collect through our Services and use and share it for the purposes described below. The categories of personal information we may obtain from third parties include:
We use your personal information for the following purposes (“Purposes”), to:
You have choices about your personal information, and in some circumstances, you may have the right to opt-out or object to our uses of your personal information for these Purposes. For more information, or to exercise these or other rights (where available), see the Your Choices and Rights section below.
Consistent with the above Purposes and as permitted by applicable law, we may communicate with you via electronic messages to:
We disclose the personal information we collect (or otherwise generate or obtain) as follows:
We do not currently have affiliates, but, if we do have affiliates in the future, we may share your information with our affiliates and subsidiaries in the U.S. and worldwide. We may share your information with our affiliates for the following reasons:
To learn more about your choices related to how we share your information with our Affiliates, please see the Your Choices and Rights section below.
We share your information with other third-party business partners for the following reasons:
To learn more about your choices related to how we share your information with our business partners, please see the Your Choices and Rights section below.
We share information with third-party vendors, consultants, and other service providers who perform services or functions on our behalf. We do not authorize these third parties to use or disclose your information for purposes other than for which it has been provided. We require these third parties to maintain and implement security measures to protect your information from unauthorized access or processing.
Hadley maintains commercially-reasonable technical, administrative, and physical security measures designed to protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
We may retain your personal information for as long as necessary to continue to provide you the services requested. We may also retain your personal information as necessary to:
When you use or visit the Services, we collect information about your usage and activity using cookies, web beacons, and other technologies. Third parties may also view, edit, or set their own cookies. We and our third-party service providers, our Affiliates, and other business partners may also place web beacons for these third parties. The use of these technologies by third parties is subject to their own privacy policies and is not covered by this Policy, except as required by law. See our Cookies and Interest-Based Advertising Policy for more details.
If you no longer want to receive marketing and promotional emails from Hadley, you may click on the “unsubscribe” link in such emails to opt-out of future marketing email communications. If you have a Hadley account, you may also opt-out of marketing emails in your account settings. Please note that even if you opt-out of receiving marketing communications from one or all of our Services, we will still send you service-related communications, such as confirmations of any future reservations you make.
To exercise choices regarding cookies set through our websites or Services, as well as other types of online tracking and online advertising, see our Cookies and Interest-Based Advertising Policy for more details. We currently do not employ technology that recognizes “do-not-track” signals from your browser.
As described above in the How We Share Your Information section, we share your information with third parties for their own purposes.
You can opt-out of us sharing your information with:
You can opt-out of such sharing by changing your Hadley account preferences. You may also send such opt-out requests to us as described in the How to Contact Us section below.
Any requests to erase personal data and information will be reviewed and should be submitted to [email protected]. As a registered investment adviser, Hadley cannot guarantee full erasure of data required to be maintained under the Investment Advisers Act of 1940. In such situations, Hadley will restrict access to certain personnel and will only share or access such data or information as required by regulatory or legal proceedings until such time as it may be deleted.
We are located in the United States and information about you will be transferred to, or accessed by, entities located around the world as described in this Policy. Some of these entities, like us, may be located in countries (such as the United States) that do not provide an equivalent level of protection for personal information as your home country.
Our Services contain links to other websites or services that are not owned or controlled by Hadley, including links to websites our affiliates and our advertisers and other business partners. This Policy only applies to information collected by our Services. We have no control over these third-party websites, and your use of third-party websites and features are subject to privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third-party websites linked to our Services. Your use of third parties' websites linked to our Services is at your own risk, so we encourage you to read the privacy policies of any linked third-party websites when you leave one of our Services.
Our Services are not directed at or intended for use by children. We do not knowingly collect information from, children under 16 years of age. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us at using the contact details listed in the How to Contact Us section below.
If you have any questions about this Policy or the way in which your personal information has been used, please contact us by email at [email protected] or by postal mail at:
Hadley Investment Co.
54 Danbury Road
Ridgefield, CT 06877
Attention: Legal Department
Cookies and similar tracking technologies, such as beacons, scripts, web beacons and tags (which together we refer to as “cookies”), are small bits of text, usually stored on a user's computer hard drive or within a browser. They enable a website to remember information about the user's visit to the website.
Hadley uses “first party cookies,” i.e., those that are used solely by us or by third parties who act only on our instructions or on our behalf. These types of cookies are used for our own analysis of our own Sites, or to provide functionality such as remembering your language preference.
Other cookies on our Sites are used both by us for the purposes described in this policy and by third parties for purposes where those third parties may wish to combine information from our Sites with information from other sites to improve their services. For example, these types of cookies may be used for interest-based advertising purposes.
The cookies used on our Sites, by either us or by third parties, can be “session” cookies, or “persistent” cookies. “Session” cookies are deleted automatically when you close your browser, and are used for things like ensuring you are kept logged in as you navigate around our Sites. “Persistent” cookies remain stored on your device or browser even after you close it. These cookies are used, for example, to recognize you when you come back to our Sites.
We divide the cookies we use into three categories:
|Type of cookie||Description of how we use this type of cookie||What choices do you have?|
To provide a secure log-in to our Sites.
To keep you logged in so that you do not have to log in repeatedly to access different pages of the Sites.
|Required cookies are necessary for our Sites to operate. On some platforms, you can delete all cookies, but this may affect the basic functionality of the Sites.|
To recognize if you have visited previously, and remember your preferences from past visits, such as your language preference.
To track when you make purchases
To improve our Sites and our offerings by helping us to understand how users use the Sites and to analyze trends which appear in that data. For example, we make changes to the user interface if we can see that certain pages are difficult for a large number of users to navigate. We also collect broad information about how our users use the Sites, for example, to understand which aspects of our Sites and our services are particularly popular, so that we can make improvements going forward."
Where required by law, functional cookies will be used only on the Sites where you have given your consent to their use.
You can opt out of our use of Google Analytics by downloading the browser add-on Google Analytics Opt-out Add-on (by Google) - Chrome Web Store.
|Advertising (e.g., Google AdRoll, AdWords)||
To recognize you if you have used our services on another device. We combine information received from multiple devices to determine if you are using a new device, so that we can continue to provide you with a personalized experience on our Sites.
To collect information for use in advertising on our own Sites and on third party sites which you may visit. Such information is based on your preferences and your usage of our Sites. We have included more information about our use of advertising cookies below.
Where required by law, advertising cookies will be used only on the Sites where you have given your consent to their use.
You can opt out of our use of Google Analytics by downloading the browser add-on Google Analytics Opt-out Add-on (by Google) - Chrome Web Store.Web Store."
We work with third-parties that place cookies on our Sites to provide their services, including:
These companies may use information obtained through their cookie (which does not include your name, address, e-mail address or telephone number) about your visits to our Sites and other websites, in combination with information about your purchases and interests from other online sites in order to provide advertisements about goods and services of interest to you.
You may be able to change the settings to have your browser refuse certain cookies or notify you before accepting cookies. To do so, please follow the instructions provided by your browser which are usually located within the "Help", "Tools" or "Edit" facility. Some third parties also provide the ability to refuse their cookies directly by clicking on an opt-out link, and we have tried to indicate where this is possible in the table above.
You can also find more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, at www.allaboutcookies.org and www.youronlinechoices.eu.
If you no longer wish to receive interest-based advertising on your mobile applications, please refer to your device’s operating system settings and follow instructions below.
If you no longer wish to receive interest-based advertising on your mobile device browser, you can follow the steps in relation to Browsers outlined above.
We currently do not employ technology that recognizes “do-not-track” signals from your browser.
Please keep in mind that, without cookies, you may not have access to certain features on our Sites, including access to your profile/account and certain personalized content. Removing all cookies from your computer could also affect your subsequent visits to certain websites, including our Sites, by requiring that, for example, you enter your login name when you return to that website. Please note that even if you exercise any of the choices described above, you will still see ads, but they will not be based upon the information collected through these tracking technologies and therefore not necessarily relevant to your interests.