THERESA HORIZONWAVE LLC
Privacy Policy
This Privacy Policy (the “Policy”) describes THERESA HORIZONWAVE LLC How it and its affiliates, subsidiaries and related entities (collectively, “We” or “our”) collect, use, disclose and retain information about each website, mobile application and other online platform linked to this Policy (collectively, the “Website”) and the services offered through our Website (collectively, the “Services”). This policy also describes the rights you may have with respect to our processing of your personal information under applicable local law.
By accessing this website or using any of our services, you acknowledge and agree that your personal information will be processed in accordance with this Policy. Your use of the Site and Services and any dispute over privacy is governed by this Policy and our Terms of Use, including their applicable limitations of liability and the resolution of disputes. THERESA HORIZONWAVE LLC Terms of Use are incorporated by reference into this Policy.
This policy describes how we collect, use, disclose, sell, share and retain your personal information, as well as your rights and choices regarding how we process your personal information.
The types of personal information we collect about you
Depending on your interaction with us, we may collect the following categories of personal information about you directly from you, automatically through your use of our website or services, and from third parties:
- Identifiers, such as your name, email address, telephone number, mailing address, date of birth, social security number, driver’s license or state issued identification card number, passport or other government-issued identification card number, account login credentials, IP address, device identifier, unique online identifier, or similar identifiers.
- Protected classifications, such as your age, gender, marital status, nationality, and country of origin.
- Financial information, such as your estimated level of investible assets, financial account number, credit card number, debit card number, or other payment card information.
- Commercial information, such as records of services and resources obtained or considered, feedback you may provide, and the contents of your communications with us.
- Professional or employment-related information, such as your occupation, employment history, professional contact information, education history, or other information provided by you in connection with the Services or in the job application process.
- Education information, such as where you attended school.
- Audio, video, electronic or similar information, such as CCTV footage and photos captured in and around our offices.
- Internet or other electronic network activity, such as your browser type and operating system; browsing history, clickstream data, search history on the Site, and information regarding your interaction with an internet website, mobile application, email, newsletter, or advertisement, including access logs and other activity information related to your use of our Site; the length of time you visit our Site; and the referring URL, or the website or application that led you to our Site.
- Geolocation data, such as the approximate physical location of your device or network connection.
- Inferences, such as inferences drawn to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
- Sensitive personal information, as defined under applicable local law, such as social security number, driver’s license or state-issued identification card number, passport number, financial account information, credit card number, debit card number, or other payment card information, certain characteristics of protected classifications, and account login credentials and passwords.
Information we collect directly from you. When you use our website or services, we collect personal information directly from you. If you register for an account, we may collect your name, login credentials, phone number, postal address, and email address. If you contact us, we may collect information such as your name, email address, zip code, your estimated level of investable assets, your preferences (such as services you may be interested in), the content of messages or attachments you may send to us, and other information you choose to provide. We may also collect information directly from you when you register for webinars or other events. If you apply for a job with us, we may collect information from you during the online resume submission process.
Information we collect automatically. When you use our website, we and our third party business partners automatically collect personal information using cookies, pixel tags, transparent GIFs and similar technologies. This may include information such as your IP address and the types of personal information referred to above as “Internet or other electronic network activity”. For more information, please see the “Our Use of Cookies and related Technologies” section below.
How do we use your personal information
We use each of the above types of personal information for the following commercial purposes:
- To provide our Services and fulfill your requests. We use your information to provide and maintain our Site and Services, to process and fulfill your requests, to communicate with you about your use of our Services, to respond to your inquiries, and for other customer service and business administration purposes.
- To improve our Site and Services. We use your information to understand and analyze how you use our Site and Services, to improve and enhance the Site and Services, and to develop new services, electronic offerings, features, and functionality.
- Identity and authentication purposes. We use your information for identification and authentication purposes. For example, when you enter your account login credentials to enter one of our registration or login portals, we use your login ID and password to authenticate your identity.
- Personalization. We use your information to tailor the content and information that we may send or display to you, to offer location customization, to provide personalized offers, personalized help and instructions, and to otherwise personalize your experiences while using the Site and Services.
- Marketing and promotional purposes. We may use your information to send you news and newsletters, webinar and event updates, and to communicate with you about products, services, and special promotions offered by us or our third party business partners that may be of interest to you. We may also use your information to assist us in advertising our services on third-party websites and in other forums. To the extent you have consented to receive promotional text messages from us, we will not share that consent with third parties for purposes of allowing those third parties to send you text messages that are not on our behalf. Message and data rates may apply.
- To comply with legal obligations. We may use your information where we believe necessary to comply with our legal and regulatory obligations or to exercise or defend our rights or the rights of a third party, including complying with law enforcement or government authority requests and participating in compliance audits.
- To protect us and others. We may use your information where we believe necessary to investigate, prevent, or take action regarding suspected or actual illegal activities, fraud, situations involving potential threats to the safety of any person or to otherwise enforce this Policy, our Terms of Use, or the integrity of our Site and Services.
- Deidentified data. We may deidentify or anonymize your data in such a way that you may not reasonably be reidentified by us or another party, and we may use such deidentified data for any purpose permitted under applicable law. To the extent we deidentify data originally based on personal information, we will maintain and use such data in deidentified form and will not attempt to reidentify the data.
How do we disclose the information we collect
We may disclose each of the above categories of personal information for our business purposes, as follows:
- Related entities. We may disclose the personal information we collect about you to our subsidiaries, affiliates, and related entities.
- Service providers. We may disclose the personal information we collect about you to service providers, contractors, and agents who perform functions and business operations on our behalf, for the purposes set forth above. For example, we engage service providers to help us host and manage our events and webinars, verify your information, and with our advertising and marketing efforts.
- Third parties. At your request, we may disclose your personal information to your financial advisor, your legal, accounting, and tax representatives, and to your financial institutions (including custodians and broker-dealers). We may also disclose the personal information we collect about you to our third party business partners, such as our advertising and analytics partners.
We may also disclose your personal information in the following circumstances:
- Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected about you to the other company. As part of the business transfer process, we may disclose certain of your information to lenders, auditors, and third party advisors, including attorneys and consultants.
- In response to legal process. We may disclose your personal information where we believe necessary to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- To protect us and others. We disclose your personal information where we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which we are involved.
- Aggregate and deidentified information. We may disclose aggregate, anonymized, or deidentified information about you for any purpose permitted under applicable law.
- Consent. We may disclose your personal information with your consent.
Our Use of Cookies and Related Technologies
We and our third-party advertising and analytics partners use cookies and similar technologies to track information about your use of our sites and services. We use this information to better understand, customize and improve users’ experience with the Site and services, as well as for advertising purposes. We may combine this information with other personal information we collect about you (our third party business partners may do so on our behalf).
- Cookies. A Cookie is a small text file that contains a string of alphanumeric characters. We may use both session cookies and persistent cookies. Session cookies disappear when you close the browser. Permanent cookies persist after you close your browser and may be used on subsequent visits to our website by your browser. Check your browser’s “Help” file for the correct way to change Cookie Settings. Please note that if you delete or choose not to accept cookies from this website, you may not be able to take full advantage of the features of this website.
- Clear GIFs, pixel tags, and other technologies. Transparent GIFs are tiny graphics with unique identifiers that function similarly to cookies. In contrast to cookies stored on a computer’s hard drive, transparent GIFs are embedded on web pages and application pages in an invisible way. We may use transparent GIFs (also known as web beacons, web bugs, or pixel tags) to track the activity of website visitors, help us manage content, and compile statistics about website usage. Transparent GIFs can collect information, such as: the IP address of the computer from which the page with the label appears; The URL of the page that displays the pixel label; Time to view the page containing the Pixel TAB; Browser type and language; Type of equipment; Geographical location; And the identification number of any cookies previously placed on the computer by the server. We and our third-party business partners may also use transparent GIFs in HTML emails sent to customers to help us track email response rates, determine when our emails are being viewed, and track whether our emails are being forwarded.
- Interest-based advertising. In some cases, we may set up tracking tools (e.g., cookies, transparent GIFs) provided by third party advertising partners to collect information about your activity on our website (e.g., your IP address, pages visited, time of day) for advertising purposes. We may also share this information with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) in order to provide you with targeted advertising when you visit unaffiliated websites within their network. This practice is often referred to as “interest-based advertising” or “online behavioral advertising.”
- Do not Track (DNT). Currently, our system does not recognize the browser’s “Do not Track” request. However, you can disable some of the tracking discussed in this section (for example, by disabling cookies). You can also opt out of certain targeted ads by following the instructions provided in the Interest-based Advertising section above.
Other status disclosure
Under applicable local law, you may have certain rights regarding our processing of your personal information. If our processing of your personal information is governed by such laws, this section will provide you with additional information about your rights and our processing of your personal information in accordance with applicable local laws.
We may “sell” your Personal Information or “share” your Personal Information for use in behavioral advertising (these terms are defined in applicable local law). We do not use and disclose your sensitive personal information for purposes other than those permitted by applicable local law. The following table describes the categories of third parties to whom we may disclose, “sell” or “share” for behavioral advertising across the below for the commercial purposes described above, and each category of your personal information.
| Category of personal information | Categories of third parties to whom we may disclose personal information for a business purpose | Categories of third parties to whom we may “sell” or “share” personal information |
| Identifiers | ·Affiliates and subsidiaries ·Service providers ·Advertising networks ·Data analytics providers ·Professional advisors (such as lawyers, accountants, and consultants) ·Government authorities | ·Advertising networks ·Data analytics providers |
| Financial information | ·Affiliates and subsidiaries ·Service providers ·Professional advisors (such as lawyers, accountants, and consultants) ·Government authorities | Not applicable |
| Internet or other electronic network activity | ·Affiliates and subsidiaries ·Service providers ·Advertising networks ·Data analytics providers ·Professional advisors (such as lawyers, accountants, and consultants) ·Government authorities | ·Advertising networks ·Data analytics providers |
| Geolocation data | ·Affiliates and subsidiaries ·Service providers ·Professional advisors (such as lawyers, accountants, and consultants) ·Government authorities | Not applicable |
| Inferences | ·Affiliates and subsidiaries ·Service providers ·Advertising networks ·Data analytics providers ·Professional advisors (such as lawyers, accountants, and consultants) ·Government authorities | ·Advertising networks ·Data analytics providers |
| Sensitive personal information | ·Affiliates and subsidiaries ·Service providers ·Professional advisors (such as lawyers, accountants, and consultants) ·Government authorities | Not applicable |
Data retention
Your personal information will only be retained for as long as necessary for the purpose for which it was originally collected and in compliance with applicable local laws. We will retain your personal information for the period necessary to achieve the purposes described in this Policy. In assessing the retention period, we first examine whether it is necessary to retain the personal information we collect, and if so, we will endeavour to retain the personal information for the shortest period permitted by applicable law.
Your privacy choices and rights
Depending on the jurisdiction in which you live, you may have the following rights under applicable local law:
- Right to request access and a copy of your personal information and information relating to how it is processed;
- Right to request deletion of your personal information;
- Right to request the correction or update of the personal information we hold about you;
- Right to opt-out of “sales” of your personal information and “sharing” of your personal information for cross-context behavioral advertising purposes (as these terms are defined under applicable law)
- Right to opt-out of targeted advertising;
- Right to limit our use of your sensitive personal information;
- Right to opt-out of certain profiling activities;
- Right to not be unlawfully discriminated against for exercising your rights.