When we refer to “you” or “your” we mean the person accessing the Sites. If the person accessing the Sites acts on behalf of, or for the purposes of, another person, including a business or other organization, “you” or “your” also means that other person, including a business or organization.
1. The Types of Information We Collect
When you enter and browse the Sites, you may provide us with information, and we will collect certain information through technology.
- Information You Provide to Us
In order to obtain access to certain information or materials provided via the Sites or to request certain information from Hunt via the Sites, you may have to provide information that we collect and store in a way that allows us to relate it to you personally.
This may include your name, postal address, email address, telephone number, facsimile number, investor status, or other information about yourself. In particular, you may be required to provide a username and password to access certain features. If you choose to not provide us with information, you might not be able to gain access to certain information and materials on the Sites, which rely on such information. We refer to such information a personally identifiable information.
Additionally, we may collect and retain a record of all communications with you.
- Information We Collect Through Technology
We also collect information about you through technology.
For example, when you visit the Sites, we collect your IP address, your browser type, your operating system, the pages you view on the Sites, the duration of your visit, the pages you view immediately before and after you access the Sites, and the search terms you enter on the Sites.
We or another party authorized by us collect this information using cookies, which are small text files that a website sends to your computer or device while you are viewing the website, or other technical methods to track visitor usage, including web beacons, which are small pieces of data that are embedded in images on the pages of a website.
Using the settings of your internet browser, you can choose to have your computer warn you each time a cookie is being set, or you can choose to turn off all cookies. Consult your browser’s Help menu to learn the correct way to modify your cookies. If you choose to turn off all cookies, you may not have access to features that make your browsing of the Sites smoother, and some of the services on the Sites may not function properly. You may at any time delete any cookies sent by using the relevant option on your internet browser or by deleting the cookies on your hard drive. If you continue without changing your settings, Hunt will assume that you accept receipt of all cookies on the Sites.
Other technical methods including web beacons may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML emails that we send visitors to the Sites to determine whether such visitors have opened those emails and/or clicked on links in those emails.
- Additional Information Collection Practices
The Sites may contain links to websites operated by third parties, and your personal information may be collected by those third parties when you use their websites.
Should you choose to visit these third-party sites, you should review their privacy policies to ensure you understand and are comfortable with their practices concerning your information. We do not accept, and do disclaim, any responsibility for the privacy policies and information collection, use, and sharing practices of any third-party website (whether or not such site is linked on or to the Sites). These links are provided to you for convenience purposes only, and you access them at your own risk.
Some of our third-party partners may ask you to provide personal information on their websites and may share such personal information with us, as governed by their respective privacy policies.
We will link the information that we collect automatically with the information you provide us, and we will combine the information we collect online with information we collect offline or that is collected by third parties.
2. How We Use the Information We Collect
We use the information we collect about you primarily to: provide services to you in accordance with any contract with you, communicate with you, and manage and improve our services for you and our other investors, as permitted by applicable laws.
We use your personally identifiable information to:
- respond to your requests for forms, literature, or information;
- manage and administer customer services, including but not limited to the administration of your customer account;
- process transactions, as necessary to meet our contractual obligations to you;
- provide you with the services you have requested and to meet our business interests in providing the best service possible;
- prepare investor disclosure materials;
- improve the Sites and learn about how visitors use the Sites;
- comply with legal obligations including in response to any court order, subpoena, document request or governmental request; and
- protect our rights, your rights, and the rights of others.
We may use information for any purpose if the information does not identify you and cannot be combined with other information accessible to us to identify you. For example, we may prepare aggregated reports about how visitors tend to interact with the Sites for research about the use of the Sites and how the Sites could be improved, from which your interactions with the Sites cannot be singled out.
In the event that Hunt, or substantially all of the assets of Hunt or one or more of its businesses, are acquired or merged with another entity, whether an affiliate or a third party, user information may be one of the transferred assets. We may transfer all user information (which may include personally identifiable information) to our acquirers or successors. Hunt reserves the right to use any personally identifiable information in any manner permitted by applicable law.
3. How We Share the Information We Collect
- In Connection with Third-party Offers
We will share information about you with third parties when you engage in certain activities on the Sites that are sponsored by third parties. For example, you may elect to receive information or communications from a third party. When you engage in such third party offerings, we may share information (e.g., your email address) with third parties in association with the offerings.
- Service Providers
Sometimes we engage companies that act on our behalf in association with the operation of the Sites. For example, such companies may deliver products or services, improve the functionality of the Sites, collect information about you, communicate with you, or store information for us. In some cases, these companies may need to access information about you.
- Analytics Providers
- Additional Sharing Practices
From time to time we share your information with our affiliates and subsidiaries, or with our attorneys, banks, auditors, securities brokers and other service providers in connection with the purposes described above. From time to time, we partner with other organizations or companies to provide co-sponsored or co-branded promotions, services, or events, and we will share your information with our co-sponsor(s) and partners to the extent necessary for the partnership to function.
We may disclose information when we believe in good faith that such disclosures:
- are required by law, including, for example, to comply with a court order or subpoena, or in response to a law enforcement agency’s request;
- will support our detection, prevention, or response to fraud or intellectual property infringement;
- will help protect your safety or security, including the safety and security of property that belongs to you; and
- will protect the safety and security of the Sites, databases, and/or third parties, including the safety and security of tangible and/or intangible property that belongs to us or to third parties.
Additionally, we reserve the right to share with third-parties information that does not identify you (and cannot be combined with other information accessible to us to identify you) for any purpose.
4. The Security Measures We Take to Safeguard Information
The security and confidentiality of the information we collect or receive is extremely important to us, and we take our responsibility to protect this information very seriously. We use technical, administrative and physical methods to maintain the integrity and security of our databases, including firewalls. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable, and third parties may unlawfully intercept or access transmissions or private communications. Hunt will not be responsible or liable for any damages, losses or causes of action arising out of or in connection with the disclosure of your personally identifiable information.
5. Updating Your Contact Information
You may update your contact information and/or modify your communication preferences by sending us an email at HIM_privacy@huntcompanies.com. Additionally, we may provide tools on the Sites that facilitate such updates or modifications.
6. Children’s Information
Although the Sites are not targeted toward children, we are concerned about the safety and privacy of children who use the internet.
We do not knowingly solicit or collect personal information on the Sites from children under the age of 13. If we learn that, despite these measures, a child under the age of 13 has submitted personally identifiable information to us through the Site, we will use commercially reasonable efforts to delete such information from our records and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law).
7. Do Not Track
Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. Hunt does not track visitors to its Sites over time and across third-party websites to provide targeted advertising and therefore does not currently respond to such signals.
Third parties, such as our analytics providers, may collect data that relates to you on the Sites, across time, and over other websites. We cannot control third parties’ responses to do-not-track signals or other such mechanisms. Third parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.
8. California Privacy Rights
If you are a California resident, you have the right to request certain information from us regarding the manner in which we share with third parties certain categories of information that identifies you for the third parties’ direct marketing purposes. If you wish to exercise those rights, please email us at HIM_privacy@huntcompanies.com.
9. Your Choices and Rights
If you no longer wish to receive marketing materials from us, you can let us know by contacting us at HIM_privacy@huntcompanies.com.
Subject to local law, you may have certain additional rights regarding your personal information.
Where the General Data Protection Regulation (GDPR) applies, you have the following rights in respect of your personal information:
- Data rights. In certain circumstances, you have the right to access and receive a copy of the information we hold about you, to rectify any personal information held about you that is inaccurate and to request the deletion of personally identifiable information held about you. Any access request after the first such request by you may be subject to a reasonable fee to meet our costs in providing you with details of the information we hold about you. You can exercise your rights by contacting us at HIM_privacy@huntcompanies.com.
- You have the right to ask us not to process your personally identifiable information for marketing purposes. You can exercise your right to prevent such processing at any time by contacting us at HIM_privacy@huntcompanies.com.
- In the event that you wish to make a complaint about how we process your personally identifiable information, please contact us in the first instance at HIM_privacy@huntcompanies.com and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to raise a complaint with the supervisory authority.
10. Where Is Information Processed?
We process information collected via the Sites in and subject to the laws of the United States, which may not provide the same level protection for your information as your home country. The information may be available to the United States government or its agencies under a lawful order made in the United States. In addition, we may transfer your information outside the United States to our affiliates, business partners, and service providers located in other countries.
In some cases, your personal information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for personal information under European Union or other applicable laws. For more information on the appropriate safeguards in place or to obtain a copy, please contact us at HIM_privacy@huntcompanies.com.
11. How Long Is Information Retained?
We retain your personal information for as long as we have a relationship with you and for a period after our relationship with you has ended.
When deciding how long to keep your personal information after our relationship with you has ended, we take into account how long we need to retain the information to fulfill the purposes described above and to comply with our legal obligations, including obligations to financial services regulators. We may also retain personal information to investigate or defend against potential legal claims in accordance with the limitation periods of jurisdictions where legal action may be brought.
13. How to Contact Us
Hunt Investment Management, LLC
230 Park Ave, 19th Floor
New York, New York 10169
Attn: Privacy Officer