Data Privacy Statement

DATA PRIVACY STATEMENT

We may update this Data Privacy Statement (“Statement”) from time to time, so please check back periodically for changes. The most recent version of this Statement is reflected by the version date located above.

This Statement is not intended to and does not create any contractual or other legal right in or on behalf of any party.

New England Asset Management, Inc. (“NEAM”, “us” or “we”) understands that web-enabled clients and visitors to our website (www.neamgroup.com) (“Website”) are concerned about the privacy of personal information. This Statement covers our treatment of information that relates to or could reasonably be associated with an individual (“Personal Information”) that we gather when you are accessing or using our Website. We have established policies and procedures concerning the collection, use and security of personal information that are designed to protect the privacy of registered users and visitors to our Website. Our data privacy standards are designed to help us serve our users while maintaining our own strict security standards and are intended to comply with the data protection laws of the various jurisdictions where we do business. We want you to understand how and why we collect, use and disclose personal information about you on our Website. This Statement provides you with information concerning our practices and procedures as they relate specifically to information we collect on this Website. Your use of the Website is also subject to our Legal Statement.

We may share your personal information with third parties for certain business purposes, as required by law, in compliance with legal process, to our affiliates and subsidiaries for the business purposes described in this Statement, when necessary in the case of a merger with, or acquisition of a portion of our business by, another company or entity, as necessary in connection with other lawful business purposes, or if necessary to protect our rights or our business reputation or to act in an emergency situation to protect personal safety or to prevent harm to persons or property; and as otherwise necessary when required or permitted by law.

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Collection And Use Of Personal Information

Data Automatically Collected

When you use our Website, we automatically collect your IP address, traffic source, search keywords, page views, visits, language (aggregate), location (aggregate), browser and operating systems (aggregate), network (aggregate), device (aggregate), as well as other connection data like time and transferred data, and data collected via the use of the analytical and portfolio analysis tools (collectively referred to as “automated data”). We store and use this automated data in server log files for system integrity and security and in order to be able to investigate and prosecute infringements or abuse of our Website and to cooperate with authorities involved (security and prosecution purposes). We also use this information in order to enable NEAM to better identify and serve its clients and/or visitors and to respond better to their needs, as further described below. 

We will also collect data about the content visitors access through this Website, such as newsletters or articles visitors read or the information topics contained therein, or by sending information to a NEAM email address provided on the Website. We will use this data to manage visitor subscriptions, measure the overall interest of our visitors to the various sections of this website and our Client Portal, and inform visitors about NEAM services and information that may be of interest, unless visitors inform us that they no longer wish to receive any publications/promotion material from NEAM. You can exercise this option by following the unsubscribe link contained at the bottom of every email.

In order to pursue these purposes, we make accessible and share automated data with our IT security team, supervisory authorities and/or prosecution departments (for security and prosecution purposes) and qualified personnel (marketing) having access to the tools that are used for collecting and analyzing the automated data (Google Analytics and others, see below in section “Google Analytics”, “LeadLander”, and “Marketing automation, customer relationship management (CRM), publications and invitations.”)

Information you submit through web forms, emails, surveys, and subscription pages

On our Website, you have the opportunity to pose questions or get in touch with us through web forms, subscribing to and/or accessing our publications or responding to conference invitations, and emailing us. You may also have the opportunity to submit responses to surveys. 

We collect, store and use your name, company name, email address, IP address, documents or files, content of your request or query and other personal information you provide with your submission (or when you otherwise communicate with us) for the purpose of getting in contact with you, responding to your email request, responding to your submissions, to complete your personal profile, answering your questions or providing information as requested. In addition, for events, we or our service provider may send information to you, and may collect limited personal information from you related to that event, such as dietary preferences. 

Client login/registration data

Some of our services and content of the Website are reserved for “clients only” and require access to our client portal using two-factor authentication. We will use your registration data (name, company name, email address, phone number, and password) for authentication purposes and store your registration data until you opt-out from the services or are no longer a NEAM client.

Personal information we collect from other sources

We may collect and receive personal information from third parties, such as business partners, clients and customers, data analytics providers, Internet service providers, operating systems and platforms, public databases, and service providers.

Use of cookies and other online tracking technologies
This Website utilizes cookies and other online tracking technologies (collectively, “cookies”). We audit/log some activities performed while visiting our Website, including with a cookie prior to login and in our database after login.

A cookie is a small data file that is created to help visitors navigate a website and is useful to track the traffic to and at a website and to personalize the website. Cookies will allow the web server to recognize your computer on a connection to our Website. Cookies also help identify you as an authorized user of content and pages in our restricted access area. We also use the cookie to track your responses to our banners, including acknowledgement of this Statement.  We and our third-party providers use cookies, pixel tags, and other technologies to collect automated data, as described above. We may allow third parties to collect this automated data on our behalf and to retain and use this automated data themselves. We use this automated data to, for example, analyze and understand how you access, use, and interact with us through the Website, to identify and resolve bugs and errors in the Website, to assess, secure, protect, optimize, and improve the performance of the Website, for marketing and advertising purposes, analytics purposes, and to personalize content in the Website. We may also aggregate such information to analyze trends, administer the Website, and gather broad demographic information.  

In addition to automated data, there are two types of cookies employed by NEAM.  The first type is used to track information that users have provided us so that we do not need to solicit that information upon a subsequent visit.  The second type is used once users are logged into our client portal and provides information via the user session identifier about the various tools and resources each user has access to on the site. 

Upon visiting our website, you will be presented with a cookie pop-up banner that gives you the option to decline non-essential cookies. Selecting this option will ensure that all cookies not necessary to the proper functioning of the website are not deployed during your website visit.

Third Party Analytics

We use third party tools, which are operated by third party companies, to analyze ad traffic and usage of the Website. These tools collect data about your interaction with the Website via the cookies and through the standard implementation. This data may be used for purposes including delivering banner advertisements and other advertising tailored to your interests when you visit certain websites.

• Google Analytics

Google Analytics is used on our public Website to analyze user behavior and visitor traffic and to generate statistical reports for the Website activity. 

You may opt out of Google Analytics as described below. In addition, you may prevent the collection of the information generated by Google Analytics cookie by downloading and installing the following linked browser plug-in http://tools.google.com/dlpage/gaoptout?hl=en. For additional information concerning Google Analytics, please visit https://policies.google.com/privacy and https://policies.google.com/technologies/partner-sites to learn more.

• LeadLander

LeadLander is used on our public Website to help us better understand each individual visitor's actions on our Website.  Through the use of LeadLander services, we may also use cookies to personally identify users in order to better understand each individual visitor’s actions on our website.  LeadLander may identify a user personally based on the links the user has accessed in emails or information the user has submitted in online web forms and associate this information with LeadLander cookies.  For more information, read LeadLander’s privacy policy at https://uplandsoftware.com/privacy/.

• HubSpot & other analytics

We use HubSpot and other analytics tools on the Website to help us analyze traffic and improve services. Additional information on HubSpot is available in the section titled “Marketing automation, customer relationship management (CRM), publications and invitations”. 

You may refuse the storing of cookies on your computer by using the appropriate setting of your internet browser or by declining non-essential cookies via the pop-up banner that appears when you first visit our website. Declining cookies may mean that certain services on a site may not then function properly. 

Global Privacy Control

You may also opt-out of cookies by setting a browser-level opt-out, the Global Privacy Control. You may learn how to set that signal by going to this website: https://globalprivacycontrol.org/.

Marketing automation, customer relationship management (CRM), publications and invitations

We use marketing automation software, databases and other tools (collectively the “Tools”) to disseminate our marketing content, such as publications, blogs, event alerts/conference invitations and other information and emails. Our provider is HubSpot Inc., Cambridge, Massachusetts (“HubSpot”).

If you register for one of our offers via a web form, contact data such as name, email address, company name, address, telephone number, other event-related information as described above is collected and stored in one or more of the above-mentioned Tools.

HubSpot uses a cookie that is stored on the user’s computer to collect data. The following data is collected: Information about the computer you use and your visit to our Website and/or your interactions with our emails, in particular your IP address, your location (aggregate), domain, initial timestamp, last timestamp, current timestamp and session number, the browser you use, referral source and the length of your visit to the Website (Online Access Data). This information is stored on a server of HubSpot after obtaining prior consent where necessary.

We use the Online Access Data for statistical evaluations in order to ensure the smooth operation of the Website and to continuously optimize it. Furthermore, we use the data to optimize our services, products and marketing measures. (See “Data Automatically Collected” for additional detail.)

Use of Personal Information

In addition to the purposes described above, we may use the personal information we collect to provide our services to you, notify you about your account, provide you with customer support, identify and prevent fraud, enable or administer our business, personalize your experience with the Website and services, communicate with you (including for marketing purposes), improve, evaluate, and develop services and products of NEAM and our affiliates and subsidiaries (including by aggregating information to understand how our products and services are being used), or for security purposes, or to comply with applicable laws and industry regulations.

Confidentiality and Security

We maintain appropriate physical, electronic, and procedural safeguards designed to protect personal information. We take steps to protect our databases with various physical, technical and procedural measures, to restrict access to your information by unauthorized persons, and to inform NEAM employees about their responsibility to protect customer data, among others. We apply secure sockets layer (SSL) for data in transit. Please be aware, however, that no method of data transmission or storage is completely secure. 

Links to Other Sites

For your convenience, we may provide links to other websites and web pages that we do not control. We cannot be responsible for the privacy practices of any websites or pages not under our control, and we do not endorse any of these websites or pages, the services or products described or offered on such sites or pages, or any of the content contained on those sites or pages. Please check the applicable privacy policies of the respective operator of those third-party websites.

Connecticut Social Security Privacy Protection Notice

NEAM will take reasonable measures to protect the confidentiality of Social Security numbers and limit access to those with a need for such information. NEAM prohibits the unlawful disclosure of Social Security numbers.

California Do Not Track Disclosure

Our website does not respond to “Do Not Track” signals. DNT is a preference that users can set on their browser (if supported) to opt out from online behavioral tracking. We respond to a similar signal, the Global Privacy control, as discussed above.

Visiting Our Website from Outside of the United States

If you are visiting our website or purchasing our products or services from outside of the United States or otherwise contacting us from outside of the United States, please be aware that your personal information may be transferred to, stored or processed in the United States, where our servers are located and our central database is operated or where web content is hosted by our service providers. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to protect your privacy. For example, as applicable, our service providers will be contractually bound to process personal information only on behalf of and under the instructions of NEAM and to adhere to similar data privacy standards as provided by the European Union. By using our services or purchasing our products, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Statement.

Children’s Privacy

We do not knowingly collect or solicit Personal Information from anyone under the age of 13 or knowingly allow such persons to register for our services. If you are under 13, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address.

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DATA PRIVACY STATEMENT - CALIFORNIA RESIDENTS

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). New England Asset Management, Inc. (“NEAM”, “we”, “us” or “our”) adopts this notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”) and other California privacy laws.  Some of our obligations may be exempt from the CCPA’s requirements pursuant to the Gramm-Leach-Bliley Act (“GLBA”) exemption. Specifically, personal information collected by us where the specific data is subject to the GLBA is exempt from some of the CCPA’s requirements. Any terms defined in the CCPA have the same meaning when used in this notice.

California Notice at Collection

1) Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
  •  health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

•  Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
•  Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
•  Directly and indirectly from activity on our website ( www.neamgroup.com) or via interaction with our emails/communications or otherwise described above. For example, from submissions through our website portal or website usage details collected automatically.

2) Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to engage in transactions and transaction related matters, we will use that information to direct the transactions and submit it to the applicable broker dealer and/or entities processing the requests.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To improve our services and website and present its contents to you.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement or regulatory or auditor requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We retain the categories of personal information for the period necessary to pursue the purposes outlined in this section, and/or as permitted by applicable laws.

Disclosing, Selling and Sharing Personal Information

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, 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.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A:  Identifiers.
Category B:  California Customer Records personal information categories.
Category D:  Commercial information.
Category F:   Internet or other similar network activity.

We disclose your personal information for a business purpose to the following categories of third parties:

• Our affiliates.
• Service providers.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
• Analytics and marketing partners.

We do not knowingly sell or share the personal information of consumers under 16 years of age. 

We engage in online tracking, i.e., allowing third party advertising platforms to collect your interaction with our website (Category F: Internet or other similar network activity). That activity may qualify as a “share” or “sale” under California law. To opt out of that sharing or selling on our public Website, we respond to privacy preferences enabled through Global Privacy Controls on our public Website. For more information on how to communicate your preferences to us, please visit https://globalprivacycontrol.org/. Given our response to GPC, our website does not respond to “Do Not Track” signals. DNT is a preference that users can set on their browser (if supported) to opt out from online behavioral tracking. You may opt-out of our use of non-essential cookies by selecting “Decline” on our cookie pop-up banner.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. 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 or selling 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 (also called a data portability request).
• 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 have the right to request that we delete any of 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 an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Additional Rights Available To You:

• Right to Opt-Out of Sale or Share: The right to opt-out of the sale or sharing of your personal information collected on our public Website by us, which you may do by setting the Global Privacy Control signal. You may opt-out of our use of non-essential cookies by selecting “Decline” on our cookie pop-up banner.
• Right to Limit Disclosure of Sensitive Personal Information: We do not use your sensitive personal information except for certain limited purposes, such as the following: (1) performing our service or providing goods, (2) detecting security incidents, (3) resisting malicious, deceptive, fraudulent, or illegal actions, (4) ensuring physical safety, (5) for short-term transient use, including certain non-personalized advertising, (6) maintaining or servicing accounts, providing customer service, verifying customer information, or providing similar services, and (7) to verify and maintain the quality or safety of a service or product, or to improve, upgrade, or enhance a service or product. The right to limit therefore does not apply.
• Right to Correct Inaccurate Personal Information: The right to correct inaccurate personal information that we maintain about you.

Exercising CCPA Rights

To exercise the CCPA rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 860.676.8722.
• Emailing us at  neam-privacy@neamgroup.com

Only you or an authorized agent may act on your behalf and 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 or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify 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 cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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 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.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. The most recent version of this privacy notice is reflected by the version date located at the top of the Statement. When we make material changes to this privacy notice, we will notify you as required, such as through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 860.676.8722
Website: neamgroup.com
Email: neam-privacy@neamgroup.com
Postal Address: New England Asset Management, Inc.
74 Batterson Park Road
Farmington, CT 06032

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