EFFECTIVE: AUGUST 25, 2014.
How Freehold Collects Information You Provide
We may receive information from you through the Site in several ways, including information you voluntarily submit through the Site. We may collect information that you voluntarily provide in a number of ways, including when you:
- register for and use an online account with us (your name and e-mail address may be collected in connection with such registration);
- subscribe to a newsletter;
- participate in a contest;
- respond to a survey;
- fill out a form;
- request information from us (your request and information we need to respond to your inquiry may be collected in connection with requests);
- express an opinion in an online forum; or
- communicate with us in person, via e-mail, or using available online tools.
Additional Information Collection/Cookies and Online Tools
Advertising, Analytics, and Online Tracking
We may use third-party advertising and analytics service providers to serve ads to you when you visit our Site or other websites (including on social media), and to analyze the use of our Site and the effectiveness of our marketing efforts. These service providers may collect non-identifiable information about your visits to our website, and your interactions with our products, services, and your reaction to our marketing communications (such as what you do when you receive a marketing communication from us). Such non-identifiable information does not include your name, address, e-mail address or other personal information.
We and our service providers may collect personally identifiable information about your online activities over time and across third-party websites or online services, and third parties may similarly collect such information, including when you visit the Site. The Site currently do not respond to web-browser “do-not-track” or other similar mechanisms.
If you set up an account for use on the Site, we will collect information from you as necessary to support your use of the account and to process transactions you make using the account. In addition, when you create an account, you will be required to provide your e-mail address and create a password. It is your responsibility to maintain the confidentiality and security of your e-mail address and password.
How We Use Your Information
We use information collected through the Site to fulfill your requests, improve service, understand use of the Site, improve the Site, to run contests, for marketing and promotions, to communicate with you about topics in which you have expressed an interest, or satisfy any other purpose for which you provided information to us. We also use that information to: perform our everyday business purposes; identify fraud; perform legal compliance operations; provide you with notices; analyze the quality of our offerings; analyze the usage and effectiveness of our marketing efforts; and provide you with advertising, content, and marketing that we believe may be of interest to you (including advertisements that may be served to you elsewhere on the Internet).
We may also combine your information with other information to create aggregate or summary reports, and we may provide data in aggregate form to other parties for marketing, advertising, and other purposes. If we provide information to non-affiliates in aggregate form, we will not disclose any personal information about you. We may also use and disclose information gathered through our Site for research and analytics purposes, as well as to help detect fraud, or, in the case of surveys you fill out through the Site, to help detect other inappropriate survey responses.
How We Share Information
We do not sell, trade, or rent your personal information to third parties. We may share generic, aggregated demographic information with our business partners, trusted affiliates, and advertisers. In addition, in order to operate the Site and carry out our business operations, and provide you with the offerings and information you have requested, as well as ads and information that we believe may be of interest to you, we occasionally need to share information with our business partners and affiliates, as well as certain third parties. By way of example, we may share information with a third party to carry out surveys or send communications on our behalf.
We do not allow these business partners, affiliates, or third parties to use or disclose your personal information for any purpose other than those described in this Policy.
How We Communicate With You
We may use information you provide to send you periodic e-mails about updates, information about our offerings, and other information we believe may be of interest to you; these communications may be tailored based on preferences you express. We may also send you communications to respond to inquiries, questions, or requests. If at any point you would like to stop receiving e-mails from us as described here, an opt-out mechanism is available at the bottom of these e-mails. If you do opt out we will unsubscribe you from our e-mail list within a reasonable time.
If you provide us with your mailing address, we may periodically send mailers to you that include updates and other information that we believe may be of interest to you, as well as to respond to inquiries, questions, or other requests. If you elect to receive certain additional mailings from us, we may periodically send you information about Freehold, including updates, news, and newsletters. You may opt out of these mailings at any time by sending a letter with the subject line “MAIL UNSUBSCRIBE” to our corporate office at the following address:
If you opt out of receiving mailing we will unsubscribe you from our mailing list within a reasonable time.
Please note that we will separately obtain express or implied consent from you before contacting you whenever we are required to do so by law (such as the Canadian “anti-spam” law or the Telephone Consumer Protection Act).
How We Secure and Protect Your Information
We take information security very seriously, and protecting your personal information is an important priority. We use several physical, electronic, and procedural safeguards to protect information entrusted to us.
You acknowledge, however, that no transmission of data over the Internet can be guaranteed to be 100% secure, despite our efforts. Thus, while we take appropriate measures to ensure the security of information you transmit to us, we cannot guarantee that such information will not be intercepted by third parties.
To ensure that we carry out your instructions accurately, improve our services and for security, we may monitor and/or record: (1) telephone calls; (2) activities using CCTV in and around our premises; and (3) transactions and activities on the Site. All recordings are and shall remain our sole property.
Consistent with the Children’s Online Privacy Protection Act of 1998, we do not knowingly collect personally identifiable information of children under the age of thirteen (13). You may not use our Site or provide information to us if you are under the age of 13. If we become aware that information has been collected about a person under the age of 13, we will remove and permanently delete that information as soon as reasonably possible. If you are a parent or guardian who believes that your minor child under the age of 13 has submitted personal information or other information to us, please contact us. Once we verify that you are the parent or legal guardian, we will cooperate with you to discuss what, if any, personal information we have collected about your child and how that information may have been shared or used.
Your California Privacy Rights
California Civil Code Section 1798.83 permits Site visitors who are California residents to request that we not share your personally identifiable information with third parties if we know or have reason to know that the third parties use the personally identifiable information for the third parties’ direct marketing purposes. For your protection we do not share personally identifiable information with third parties for purposes other than set forth in this Policy, and thus do not share with third parties for their own direct marketing purposes.
We maintain social media pages and accounts (including through Facebook, LinkedIn, Twitter, and Google+). Actions you take in connection with social media pages may be reflected in a manner visible to others; for example, if you “Like” us on Facebook or post a comment, others may be able to see that you have done so.
We may receive personal information from a social media page when you connect through a social media feed, post content, or otherwise interact with us using social media tools. For example, we may receive basic Facebook account information through our Facebook Page(s). Also, when you “like,” “subscribe to,” or send a “tweet” to us through social media, we may receive your username, handle, and any other available personal information from the social media site. All information received from social media sites may be used by us in the same manner and for the same purposes as described in this Policy with respect to similar information we obtain through our Site, including to allow us to send and tailor messages that we believe may be of interest to you.
Legally Required Disclosures
If we receive a subpoena, court order, or other legal process requesting your personal information we may, in our sole discretion, disclose your personal information pursuant to such legal process without providing any notice to you.
The Site may contain links to other websites, and conversely, other websites may contain links to the Site. Those websites have their own policies regarding privacy and security, and it is your responsibility to review such policies while visiting each site. We are not responsible for the privacy practices, security, or content of linked websites. We provide links to third-party websites solely for your convenience.
Visiting Our Website From Outside the United States
If you are visiting the Site or otherwise contacting us from outside 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. 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. By using or purchasing our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Policy.
We reserve the right to change, supplement or update its this Policy. We will alert you to these changes by noting the date that this Policy was last updated at the beginning of the Policy. We encourage you to review this Policy from time to time to make sure that you understand how we may gather, secure, use, and share your personal information.
Freehold Capital Management, LLC
500 Boylston St., Suite 1870
Boston, MA 02116
We will keep a copy of your message until we have had an opportunity to address your concerns. We may archive your message for a certain period of time or discard it once it is no longer needed.