1) Website Privacy Policy
Kaufman Hall Investment Management, LLC ("KHIM" or "We") knows that you care about how your personal information is used and shared, and we take your privacy seriously. KHIM has created this privacy statement ("Privacy Statement") in order to demonstrate our commitment to your privacy.
Please read the following to learn more about our privacy policy.
This Privacy Statement forms part of our Terms and Conditions of Use, available at:[HYPERLINK]. By accessing the KHIM website at www.KHIM.com, including all related pages and subdomains of KHIM www.KHIM.com, ("Website"), including in email, text, and other electronic messages between you and this Website, any subscription based features or services offered by KHIM through the Website, through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website (collectively, the "Service"), you are accepting and agreeing to the practices outlined in this Privacy Statement. If you do not agree with our policies and practices, your choice is not to use our Website. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
For purposes of this Privacy Statement, the term “personal information” has the meaning given to such term (or to terms of similar intent, such as “personal data”) under applicable law, as and to the extent applicable to your rights and our obligations with respect to such information, including (as and to the extent applicable): (i) “personal information” as defined under the California Consumer Privacy Act of 2018 (the “CCPA”) and the California Privacy Rights Act (the “CPRA”); (ii) “non-public personal information” as defined under the Gramm-Leach-Bliley Act (Public Law 106-102); (iii) “personal data” as defined under the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) or the UK General Data Protection Regulation (i.e., the GDPR as implemented into the laws of the United Kingdom (the “UK”)) (the “UK GDPR”); and/or (iv) “personal data” as defined under the Data Protection Act (As Revised) of the Cayman Islands (the “DPA”). We do not consider personal information to include information that has been aggregated or de-identified such that it does not allow a third party to reasonably identify a specific individual or household.
2) Business Service
KHIM’s services are designed for businesses and are not intended for use by individual consumers. We only request your business information. Please do not provide us with personal contact information. If you are a business (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with personal information about individuals connected to you for any reason in relation to your investment with us, this Privacy Policy is relevant for those individuals and you should provide this Privacy Policy to such individuals or otherwise advise them of its content.
3) Information We Collect and How We Use It
You may use the Website to access general information about KHIM’s services and other related topics that may be of interest to your organization.
4) Requesting and Receiving Additional Information
If you wish to receive additional information provided on our Website, we may ask you to provide certain information such as your name, company name, company email address and business contact information. We store this information and use it to respond to your inquiries.
In addition, from time to time, KHIM and its affiliates would like to send you details of products and services which we think may be of interest to you, but we will only do this if you have indicated that you wish to receive such communications.
5) Event Registration
If you wish to attend a KHIM sponsored event, we ask you to provide certain information such as your name, company name, business address, business telephone number and e-mail address. We use this information to contact you regarding the event. We will not sell or give your information to any third-party vendors except as follows. If you wish to pay to attend an event by using the online credit card payment method, information submitted by you that is necessary to process such credit card payment will be provided to a third party online payment vendor. We will not use such information for any other purpose.
6) Publications
When you sign up online to receive one of our publications, we ask for your name, company name, business mailing address, business telephone number and e-mail address. We may use this information to contact you regarding promotions.
7) Join Our Team
You can submit your resume and other information online to apply for a job with us. We use the information you submit only to evaluate your job application and to contact you regarding possible employment.
8) Surveys and Questionnaires
We occasionally may ask visitors to our Website to complete online surveys and opinion polls about their activities, attitudes and interests. These surveys help us understand the needs of our Website visitors.
9) Cookies and Other Technologies Tracking Activity on Our Website
When browsing our Website, unless specifically requesting event registration or a service, personally identifiable information is not collected. However, through the use of “cookies” and other technologies, we track information relating to your usage of our Website that allows us to evaluate the usefulness of our Website, diagnose problems with our server, administer the Website, analyze trends, and gather broad demographic information for aggregate users. This information cannot be tracked to an individual and is used only for statistical reporting. Cookies on our website are deployed by third party provides, including Marketo, Inc., 6sense Insights, Inc., and Google and can be broadly categorized as follows:
- Essential/strictly necessary cookies, which are essential to the functioning of the Website.
- Behavioral advertising/targeting cookies in our Website.
- Functional cookies, which are used to enhance consumer’s experience (e.g. remember settings).
- Performance cookies to measure KHIM Website’s performance and improve website user’s experience.
- Social media cookies, which allow KHIM to share the content on its Website on social media.
You have the right to choose whether or not to accept non-essential cookies. If you prefer not to enable cookies, you can change your cookie settings for at any time here. Please note that certain features of our web site will not be available once cookies are disabled. As an alternative, you can block all cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. If you have disabled one or more cookies, we may still use information collected from cookies prior to your disabled preference being set; however, we will stop using the disabled cookie to collect any further information.
As is true of most web sites, we gather certain information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. The Company will not use the information collected to market directly to that person.
In some of our email messages we use a “click-through URL” linked to content on our web site. When customers click one of these URLs, they pass through our web server before arriving at the destination web page. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked simply avoid clicking text or graphic links in the email.
In addition we use pixel tags—tiny graphic images—to tell us what parts of our web site customers have visited or to measure the effectiveness of searches customers perform on our site. Pixel tags also enable us to send email messages in a format customers can read. And they tell us whether emails have been opened to ensure that we’re sending only messages that are of interest to our customers. We may use this information to reduce or eliminate messages sent to a customer. We store all of this information in a secure database located in the United States.
10) Information We Share
We do not sell, rent, trade or otherwise disclose personal information about our Website visitors, except as described here. We share your personal information only with entities that are controlled by or under common control of KHIM. The non-personally identifiable information we gather in aggregate form may be used to improve our site and we may share information provided, as permitted by law, by our Website visitors with service providers we may retain to perform services on our behalf. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements. We may also disclose information about you (i) if we are required to do so by law, (ii) in connection with a potential or actual sale, merger or other disposition of all or part of our business or assets or any other corporate transaction or (ii) in response to a request from law enforcement authorities or other government officials.
11) Links to Other Websites
On occasion, we provide links to other Web sites for your convenience and information. These sites operate independently from www.KHIM.com and are not under our control. This Privacy Statement does not apply to such sites. You should review any privacy policies on those linked websites. We are not responsible for any linked websites. We are not responsible for the content of these sites, any products or services that may be offered through these sites, or any other use of these sites. The use of links to such sites outside of www.kaufmanhall.com does not constitute or imply any affiliation with or endorsement of any of the owners of any of the Web sites to which we provide links.
12) Children Under Age 18
OUR WEBSITE IS NOT INTENDED FOR CHILDREN UNDER 18 YEARS OF AGE. NO ONE UNDER 18 YEARS OF AGE MAY PROVIDE ANY PERSONAL INFORMATION TO OR ON THE WEBSITE. WE DO NOT KNOWINGLY COLLECT OR USE ANY PERSONAL INFORMATION THROUGH OUR WEBSITE FROM USERS UNDER 18 YEARS OF AGE.
IF YOU BELIEVE THAT WE MAY HAVE COLLECTED ANY PERSONAL INFORMATION FROM AN INDIVIDUAL UNDER AGE 18, PLEASE CONTACT US AS DESCRIBED IN THE “HOW TO CONTACT US” SECTION BELOW.
13) Security
All customer information collected and stored by KHIM is maintained in a secure corporate data center in the United States. Only employees who need customer information to perform a specific job are granted access to it. All of our employees are kept up to date on our privacy and security practices. We use commercially reasonable measures to secure this Website to protect against unauthorized disclosure, use, alteration or destruction of information in our possession. While we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining your personal information.
While we do our best to protect your personal information, KHIM cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. You are responsible for maintaining the secrecy of your password and any other account information. Change your passwords often using a combination of letters and numbers, and make sure you use a secure web browser.
14) Integrity of Your Personal Information
The Company has safeguards in place to keep your personal information accurate, complete, and up to date for the purposes for which it is used. You always have the right to access and correct the personal information you have provided by contacting us at Compliance@kaufmanhall.com. In addition, you can request a copy of your personal information, your product registration history, and your interactions with our sales and support agents by contacting us at the email address below.
California Shine the Light Law (SB 27) Compliance Statement
Under California S.B. 27 (“Shine the Light” Law), California residents have the right under certain circumstances to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to [email address] and please include the phrase “California Privacy Request” in the subject line, the domain name of the web site you are inquiring about, along with your name, address and email address. We will respond to you within thirty days of receiving such a request.]
15) Updates to this Privacy Statement
We may update or change this Privacy Statement from time to time. We may provide you with notice of such changes, but we encourage you to review this Privacy Policy whenever you interact with us to stay informed about our privacy practices. Any changes will become effective when the revised Privacy Policy is posted on the Site and will apply on a go-forward basis. We will post the date of the most recent update to this Privacy Statement at the end of this webpage. Your use of the Website following these changes means that you accept the revised Privacy Statement. Use of information we collect is subject to the Privacy Statement in effect at the time such information is used.
16) General Data Protection Regulation (“GDPR”) (PERSONAL DATA FROM THE EUROPEAN UNION ONLY)
For personal data collected from a resident of a European Union member country, the UK, or otherwise collected in the European Union or UK, we rely on legitimate interests as our lawful basis for processing. These interests include, without limitation, improving our service, maintaining a relationship with you so that we can provide information to you about our services, and better understanding your relevant interests so that we can personalize our relationship. We reserve the right to process your information for all of the purposes set forth in this Privacy Policy, or for which you otherwise consent. You have the right to object to any processing. You may make such a request by contacting us as provided in the section titled “How to Contact Us” below.
Our processing of your personal information may involve transferring your personal data outside of the European Union, including to countries (such as the United States) which may not offer the same standard of protection for personal data as countries within the European Union or the UK. Whenever we transfer your personal data outside of the EEA or the UK to countries that have not been deemed to provide an adequate level of protection for personal data by the European Commission and/or the relevant public authority in the UK, as applicable, we seek to ensure a similar degree of protection is afforded to it by, where required by the GDPR or the UK GDPR, using specific contracts approved by the European Commission or the relevant public authority in the UK. You may be entitled, in accordance with the GDPR or the UK GDPR, as applicable, to request further information regarding such safeguards, which you can do by contacting us as described in the “How to Contact Us” section below.
Additionally, we will honor your rights concerning your personal data including:
- Right to rectify inaccurate or incomplete information we process.
- Right to object to or restrict our data processing.
- Right to withdrawal of consent, at any time and we will stop processing your personal data without undue delay.
- Right to data portability, including rights to receive your personal data in a structured, commonly used, and machine-readable, and to have it forwarded to a third-party controller.
- Right to erasure, commonly known as Right to be Forgotten.
- Right of access to your personal data with details of processing including, without limitation, categories of personal data processed, where the data is processed, categories of recipients who have received it, and the envisaged period for which the personal data will be stored.
- Right to lodge a complaint with a supervisory authority in your local jurisdiction.
- Right to restrict processing of your personal information in certain circumstances, e.g., if you object to us processing it.
- Rights to request not to be subject to a decision when it is based solely on automated processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling in necessary for entering into, or the performance of, a contract between you and us.
For more information about our processing or to exercise your rights, contact us as provided in the section titled “How to Contact Us” below. These rights are not absolute and each is subject to certain exceptions or qualifications. For example, if you wish to withdraw your consent or object to processing, we may need to discuss with you whether our use of your personal data needs to continue for other lawful purposes, such as fulfilment of a legal or contractual requirement.
17) California Consumer Privacy Act (“CCPA”) (CALIFORNIA RESIDENTS ONLY)
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit here. The Privacy Notice for California Residents is an addendum to this Privacy Policy, and in case of any conflict, the terms of the Privacy Notice for California Residents will prevail as to personal data of California residents that is subject to the CCPA. As used in this section, the term “personal data” includes all “personal information” as defined in the CCPA. Please note that the rights under the CCPA and the CPRA do not apply to Personal Information collected, processed, sold or disclosed subject to the Gramm-Leach-Bliley Act (Public Law 106-102), the Fair Credit Reporting Act (12 CFR 1022) and/or the California Financial Information Privacy Act
18) CANADIAN PRIVACY NOTICE (CANADIAN RESIDENTS ONLY)
We will comply with applicable Canadian data protection laws, such as the Personal Information Protection and Electronic Documents Act (PIPEDA), and any other applicable Canadian federal and provincial laws regulating the collection, use and disclosure of personal information. We will not collect, use or disclose your personal information for any other purpose than those outlined above, except with your consent. We will respond to your request to access personal information as promptly as possible.
We may collect personal information from you through:
- Your Purchase of Services.
- Completed and returned surveys or questionnaires.
- Requests for newsletters, brochures, or information.
- Your participation in any of our marketing campaigns.
- Visits to our website, if you voluntarily submit such information.
Your name, email address or any other personal information you may have shared, or choose to share with us in the future, will never be sold, traded, rented, given away or used for any other purpose than to provide you with the information or services you have requested or as required by applicable law. At all times, it is your choice whether or not you provide us with your personal information, and if you do not notify us of your objection to our use of your information as outlined within this Privacy Policy, we will consider you to have consented to such continued use.
19) How to Contact Us
If you would like us to update your contact information, remove you from contact lists, or if you have any questions or concerns about our information practices, please contact us by:
- Calling us at:
(847) 441-8780
(8:30 a.m. - 5:00 p.m. Central time) - Online:
You may send us your comments and request information using our online form. - Writing us at:
10 Cadillac Drive, Suite 120, Brentwood, TN 37027 - E-mailing us at:
Compliance@kaufmanhall.com
20) Conditions of Use
If you decide to visit the KHIM Website, your visit and any possible dispute over privacy is subject to this Privacy Statement and our Terms of Use, including limitations on damages, which are incorporated herein by reference. The security of your user name and password is your responsibility. Do not share your password with anyone. Do not use the same password on this website as you use on other websites.
21) Retention
Our policy is to retain personal data only for as long as it is needed for the purposes described in the section “Purposes for which we process personal data.” Note that retention periods vary in different jurisdictions and are set in accordance with local regulatory and professional retention requirements.
In order to meet our professional and legal requirements, to establish, exercise or defend our legal rights, and for archiving and historical purposes we need to retain information for significant periods of time. You may be entitled to request further information regarding such retention periods, which you can do by contacting us as described in the “How to Contact Us” section below.
22) Questions or Concerns
If you have any questions or concerns regarding privacy at the KHIM site, please email Compliance@kaufmanhall.com. Your privacy is important to us and we will make every effort to resolve your concerns.
Last Updated: July 2024