Privacy Policy

PRIVACY POLICY

Last Updated: July 28, 2020

This Privacy Policy explains how Grove Street Advisors, LLC (“GroveStreet,” “we,” or “us”) collects, uses, and discloses information about you. This Privacy Policy applies only when you use our website at www.grovestreet.com (the “Site”), and other online services that link to this Privacy Policy (collectively, our “Services”), or otherwise interact with us. This Privacy Policy does not cover or include any GroveStreet advisory services or the partner portal accessible via the Site.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our Site or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

CONTENTS

  • Collection of Information
  • Use of Information
  • Sharing of Information
  • Analytics
  • Transfer of Information to the United States and Other Countries
  • Your Choices
  • Additional Disclosures for Individuals in Europe
  • Contact Us

 

COLLECTION OF INFORMATION

Information You Provide to Us

We collect information you provide directly to us. For example, you share information directly with us when you fill out a form, communicate with us via our Site or otherwise communicate with us. The types of personal information we may collect include your name and email address, and any other information you choose to provide.

Information We Collect Automatically When You Interact with Us

When you access our Site or use our Services or otherwise transact business with us, we automatically collect certain information, including:

  • Device and Usage Information: We collect information about how you access our Site, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Site, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Site.
  • Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Site and Services, and your experience, see which areas and features of our Site and Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see the Your Choices section below.

 

Information We Collect from Other Sources

We obtain information from third-party sources. For example, we may collect information about you from content streaming platforms, data analytics providers, and mailing list providers. For example, if you input personal information through a third-party platform (such as Vimeo), we will have access to certain information from that platform, such as your name and email address, in accordance with the authorization procedures determined by such platform.

 

USE OF INFORMATION

We use the information we collect to advertise GroveStreet products and services to you. We also use the information we collect to:

  • Provide the Site to you and, maintain and improve our products and services;
  • Personalize and improve your experience on our Site;
  • Send you technical notices, security alerts, and support and administrative messages;
  • Respond to your comments and questions and provide customer service;
  • Communicate with you about services and events offered by GroveStreet and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
  • Monitor and analyze trends, usage, and activities in connection with our Site;
  • Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of GroveStreet and others;
  • Debug to identify and repair errors in our Services;
  • Comply with our legal and financial obligations; and
  • Carry out any other purpose described to you at the time the information was collected.

 

SHARING OF INFORMATION

We share personal information in the following circumstances or as otherwise described in this policy:

  • We share personal information with vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies that assist us with web hosting, fraud prevention, customer service, and marketing and advertising.
  • If you choose to use integrations we offer on our Site, such as watching an embedded Vimeo video, we may share certain information with our integration partners.
  • We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
  • We may share personal information if we believe that your actions are inconsistent with our terms of use, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of GroveStreet, our visitors, the public, or others.
  • We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
  • We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
  • We share personal information with your consent or at your direction.

We also share aggregated or de-identified information that cannot reasonably be used to identify you.

 

ANALYTICS

We allow others to provide analytics services on our behalf on the Site. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and the Site, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by GroveStreet and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and Site, and better understand your online activity.

 

TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

GroveStreet is headquartered in the United States, and we have operations and service providers in the United States and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

 

YOUR CHOICES

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Site and Services.

Communications Preferences

You may opt out of receiving promotional emails from GroveStreet by following the instructions in those communications or by emailing us at privacy@grovestreet.com. If you opt out, we may still send you non-promotional emails, such as those about our ongoing business relations.

ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you.

Legal Basis for Processing

When we process your personal data, we will do so in reliance on the following lawful bases:

  • To perform our responsibilities under our contract with you (e.g., providing the Site to you and providing the products and Services you requested).
  • When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our Site and Services, and communicate with you).
  • To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
  • When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.

Data Retention

We store your personal data in accordance with our data retention policy, or for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Data Subject Requests

Subject to certain limitations, you have the right to request access to the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please email us at privacy@grovestreet.com.

Questions or Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en

For individuals in the UK: https://ico.org.uk/global/contact-us/

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

 

CONTACT US

If you have any questions about this Privacy Policy, please contact us at privacy@grovestreet.com.