Brydon Privacy Policy
Last updated [4_18_2024]
1. INTRODUCTION
Brydon Group LLC (“Brydon”, “we”, “us”) has created this privacy policy (“Privacy Policy”) in order to set out how we collect, use, and disclose information through our website located at www.brydon.com (the “Website”) as well as our related, affiliated and/or subsidiary companies (collectively the “Services”), unless another applicable privacy policy applies to such Service.
Your privacy is very important to us. By visiting our Website and/or using the Services in any manner, you acknowledge that you have read the practices and policies outlined in this Privacy Policy and you understand that your information will be collected, used and disclosed in accordance with this Privacy Policy. If you do not agree with our policies and practices, you should not use the Website or the Services.
2. WHAT DOES THIS PRIVACY POLICY COVER?
This Privacy Policy describes our collection, use and disclosure of information, including information which can be used to identify an individual (“Personal Information”). Personal Information does not include any anonymized information which we may create or derive from information (including Personal Information) you provide to us.
Personal Information may be collected about employees, prospective customers, and visitors to the Website. You can choose not to provide us with certain Personal Information, but by doing so, you may not be able to use certain features and functionality of our Services.
This Privacy Policy does not apply to the practices of companies that we do not own or control. Such companies are responsible for maintaining their own privacy policies governing the collection, use and disclosure of Personal Information and for ensuring that they have obtained the necessary authorizations and consents for any Personal Information made available to us for use in accordance with this Privacy Policy.
3. COLLECTION AND USE OF PERSONAL INFORMATION AND OTHER DATA
Types of information we collect
The categories of Personal Information we may collect include:
- Contact Data, such as first name, last name, email address and phone number.
- Marketing Data, such as your preferences in receiving marketing materials from us, the content of your communications, and the date and time of any such communications.
- Location data, such as geolocation information.
- Account Data, such as your email address and password.
- Any other information you voluntarily provide to us.
We may also collect certain other types of information that may not specifically identify you, but may be unique to your device, such as:
- Technical Data, which includes information collected via cookies and similar technologies (and identifiers associated with those cookies and technologies), internet protocol (IP) address, cookie data, your mobile or internet service provider, mobile device identifier, browser type, and operating system.
- Usage Data, which includes information about how you use our Services, your access times, pages viewed, and the routes by which you access or exit our Services.
We collect and use your information for the following purposes:
To create your account
To use certain Services (such as to manage funds, investments and access documents), users may be required to create a valid account. When you register for the Services, Brydon may collect your name, email address, birth date, zip or postal code, and your phone number.
Brydon uses account data to authenticate access to your account and provide access to the Services. We may also use this information to better understand, improve and personalize the delivery of our Services and related products, to conduct our business, to develop analytics and aggregated data that allow us to improve our Services and related products, or to correspond with you including to send alerts, updates and administrative messages.
We may also use information to investigate and prevent fraudulent transactions, unauthorized access to the Services, and other unlawful activities.
To contact prospective partners
We collect names, email addresses and other business contact information about individuals who we consider to be prospective business partners (“Prospects”). We may use third-party service providers to collect, store and process Personal Information about Prospects and to identify Prospects and locate contact information to contact Prospects about our products and services.
To send marketing communications
With your consent, we use your email address as well as other information on an optional basis to help us tailor our communications to you. You will receive email message communications from us or our partners regarding our or our partners’ products, services and initiatives (including collaborations and partnerships).
To improve our products and services
Brydon may use demographic information that we collect about our users for our own business purposes, including forecasting demand for our products and services, improving our products and services and creating a personalized experience. Personal Information is not shared with third parties for these purposes.
To assist you when you contact us
When you contact us with a comment, question or complaint through email, telephone, or message features available on the Services, you may be asked for information that identifies you, such as your name, address and a telephone number, along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future and to improve our customer service and service offerings.
To assess your application for employment
If you apply for a job with us, we may collect certain personal information about you (such as information that would be contained in a resume, cover letter, or other employment-related materials). We use this information for the purpose of processing and responding to your application.
Aggregate or De-identified Data
We may aggregate or de-identify Personal Information, including information that we may receive from Practices, so that it does not personally identify you (“De-identified Data”). We may collect, use and disclose De-identified Data for our business purposes and any purpose permitted by law. In some instances, we may combine De-identified Data with Personal Information. If we combine any De-identified Data with Personal Information, the combined information will be treated by us as Personal Information.
4. MINORS
Brydon does not knowingly solicit or collect data from children nor knowingly market to anyone under the age of 16. If you are under the age of 16, you are explicitly not authorized to use these Services.
5. WEBSITE INFORMATION
In general, you can visit our Website without telling us who you are or creating an account. However, like many internet and mobile services, we may automatically gather certain information about our Services traffic and store it in log files. This information may include mobile device identifiers, browser type, IP address, mobile or internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, to administer the Services, to understand users’ movements around the Services. We may link this automatically collected data to Personal Information. Device identifiers may be tied to Personal Information to troubleshoot access issues. Some of the ways in which we automatically collect such information are further described below:
Log Files
We may automatically gather certain information about our Service’s traffic and store it in log files. This information includes mobile device identifiers, browser type, IP address, mobile or internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, to administer the Services, to track users’ movements around the Services, and to gather demographic information about our users, to comply with legal obligations relating to such data, and use it to improve our Services.
Cookies and other tracking technologies
Cookies are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand activity and patterns, and facilitating online advertising.
We may also use other technologies such as:
- Local storage technologies, like HTML5, provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
- Web beacons, also known as pixel tags or clear GIFs, are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
We use the following categories of cookies:
Essential. These cookies are necessary to allow the technical operation of our services (e.g., they enable you to move around on a website and to use its features).
Functionality / performance. We use these cookies to enhance the functionality and performance of the Services.
Analytics. We use these cookies to help us understand how our Services are performing and being used. For example, we use Google Analytics to collect information about how users use our Services, which we then use to compile reports that disclose trends without identifying individual visitors, and help us improve our Services. For more information on Google Analytics, click here. For more information about Google’s privacy practices, click here. You can opt out of by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
You can limit online tracking by:
- Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. Use the following links to learn more about how to control cookies and online tracking through your browser:
- Firefox; Chrome; Microsoft Edge; Safari
Do Not Track. Some Internet browsers can be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Clickstream
As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as "clickstream data," can be collected and stored by a website's server. Clickstream data can tell us the type of computer and browsing software you use and the address of the website from which you linked to the Website. We may collect and use clickstream data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our Website, how visitors navigate throughout the Website and how we may tailor our web pages to better meet the needs of visitors. This information will be used to improve our Website and our Services.
Analytics
We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) to evaluate and improve the user experience and the Website. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can also obtain additional information on Google Analytics’ data privacy and security at the following links:
Third Party Links and Social Networking Services
Our Website may contain links to other websites that we do not own or operate. Any such linked websites have separate and independent privacy policies. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the terms of use and privacy policy of every website you visit.
You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others. We are unable to control such uses of your Personal Information, and by using such services you assume the risk that the information provided by you may be viewed and used by third parties.
6. DISCLOSURE OF INFORMATION
Service Providers
We may from time to time employ third parties to perform tasks on our behalf and we may need to share Personal Information with them to provide certain services. We do not authorize such third parties to use the Personal Information we share with them beyond what is necessary for them to provide the tasks and services on our behalf. The third parties we currently engage include third party companies and individuals employed by us to facilitate our services, including the provision of maintenance services, hosting services, database management, Web analytics, payment processing, email and content marketing services, advertising services, sales productivity services, and general improvement of the Services.
Marketing
We may also share aggregated, non-identifiable data to conduct our business, improve the delivery of our Services, to develop analytics, and to enable us and our partners to improve and promote our products and services.
Business Transfers
If our business (or substantially all of our assets) are merged with or acquired by a third party, or if we go out of business, enter bankruptcy, or go through some other prospective, partial or complete change of control, Personal Information may be made available or otherwise transferred to the prospective or new controlling entity, in accordance with applicable law.
With Your Consent
If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain consent as required under applicable privacy laws.
Legal Compliance
We, and our affiliates and Service Providers, may disclose your Personal Information to third parties without your consent in response to a warrant or other legally valid inquiry or order, for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable law. Your personal information may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
7. RETENTION
We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or to meet our legal or regulatory obligations.
8. OPT-OUT CHOICES
To “opt-out” of any consents previously given to us or having your Personal Information disclosed to third parties, send an e-mail to info@brydon.com. Please note that we may continue to use and retain your Personal Information as necessary to provide Services to you.
Communications
If you do not wish to receive promotional communications from us or our partners, you can unsubscribe from such promotional e-mails at any time by clicking on the unsubscribe link in any of our e-mail communications.
Please note that you may continue to receive transactional or account-related communications from us, such as technical notices, security alerts and support and administrative messages.
Cookies
If you prefer, you can turn off cookies in your web browser by changing your browser’s security settings. Please note, however, some features of our Products and Services may not function properly if your browser’s cookies are disabled. You may be able to set your browser to notify you when you are sent a cookie. This gives you the choice to decide whether or not to accept it.
To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.
Currently, this Service does not support Do-Not-Track signals. However, you can follow the instructions above to opt-out of interest-based advertising.
9. SECURITY
Brydon has implemented commercially reasonable technical and organizational measures designed to secure your user data, including any personal information, from accidental loss and from unauthorized access, use, alteration or disclosure. However, we cannot guarantee the security of your information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section below.
10. CALIFORNIA CONSUMER NOTICE
If you are a California resident, you have the right to submit requests about your personal information, such as:
- Knowledge. Request that we provide with information about the personal information we collect about an individual;
- Deletion. Request that we delete the personal information that we maintain about the individual;
- Correction. Request that we update or correct inaccuracies in the individual’s personal information;
- Transfer. Request that we transfer a machine-readable copy of the individual’s personal information to the individual or a third party the individual designates;
- Opt out of the sale or sharing of your personal information and opt out of the processing of your personal information for targeted advertising. We don’t sell personal information or engage in interest-based advertising.
To make privacy-related requests, please email us at info@brydon.com. We reserve the right to confirm the identity of the individual making a request before we respond to the request and to assess whether these rights apply to you. Additionally, applicable law can limit these rights, for example, by prohibiting businesses from providing certain sensitive information in response to an access request and limiting the circumstances in which they must comply with a deletion request. If we decline a request, we will explain why we took that action, subject to legal restrictions. You are entitled to exercise the rights described above free from discrimination.
Please note that the law of your state may limit these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.
California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.
11. CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date at the top of this page. Such changes shall be effective on the date the revised Privacy Policy is posted, provided that such changes will only be applied prospectively. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or sending you an email prior to the change becoming effective.
12. CONTACT US
If you have questions regarding our Privacy Policy or the manner in which we or our service providers treat your personal information, or to request access to our collection of your personal information, please contact us at:
(202) 972-4620
2000 Pennsylvania Avenue, Suite 4006
Washington, D.C. 20006
