Policies & Disclosures
Code of Ethics (updated Nov. 2023)
Part 2A of Form ADV Investment Adviser Brochure
Callan LLC Website Privacy Policy
Effective Date: October 8, 2024
Introduction
Callan LLC (“Callan,” “we,” “us,” or “our”) recognizes the importance of privacy. In this privacy policy (“Privacy Policy”), we describe how we collect, use, and disclose information that we obtain about visitors to our website, www.callan.com, and other Callan websites where we post this policy (the “Site”), our mobile applications, and the services available through our Site and our mobile application (collectively, the “Services”). Services also include the services that we provide to our clients, including fund sponsors and clients of our Independent Adviser Group (IAG), Institutional Consulting Group (ICG), and Trust Advisory Group (TAG), as well as our development and dissemination of research.
Your use of our Site or Services, and any dispute over privacy, is subject to this Privacy Policy, any of our Terms of Service, and any client agreement you may have with Callan. Any customer agreement between you and Callan supersedes the terms of this Privacy Policy to the extent there are any discrepancies. As used in this Privacy Policy, “Personal Information” is any information that we can reasonably use to identify you.
California Residents: Additional information for California residents is available at the bottom of this policy.
How and why we collect information
We collect Personal Information solely for business purposes. We collect Personal Information about you directly from you, from third-party sources, and automatically through your use of our Site or Services. We may combine the Personal Information that we collect from various sources.
- Information we collect directly from you through our Site. We and our service providers collect certain information (e.g., personnel, structure, etc.) through password-protected portals. The information we collect directly from you includes, for example, your name, email address, and phone number. We may also collect information about your company, such as your company’s name and location, industry, personnel structure, and products. We will also collect any other information that you choose to provide to us through our Site.
- Information we collect directly from you through our mobile application. Although Callan does not currently offer its own mobile application, we may in the future. If you use our mobile application, you may choose to provide us with profile information such as your name, email address, job title, bio, profile photo, phone numbers, address, and social media handles. If you connect a social media account to our mobile application, we may also receive information from these social media services such as your name, photo, location, and email address. We may collect information that you post in our mobile application, such as comments and photos. We may enable app users to message each other through our mobile application. To provide this service, Callan may receive the message content. In the event you use a third party’s mobile application for Callan events, please refer to the third party’s privacy policy for additional information.
- Information we collect about you from other sources. We and our service providers may collect certain information about you from other sources, such as other employees of your company if they identify you as an executive or key professional or if someone else registers you for an event.
- Information we collect automatically. We and our service providers automatically collect information through your use of our Services using cookies and other technologies. This information may include, without limitation, information about your operating system; settings and system configurations; device IDs; push notification tokens; IP address; device model; the webpages you access within our Services; the website that led you to our Services; the website to which you go after leaving our Services; the number of times you access our Service, including the dates and times you do so; and other Services usage data.
Callan does not collect your personally identifiable information (PII). For purposes of this Privacy Policy, PII means a person’s first name and last name or first initial and last name combined with any one or more of the following data elements that relate to a person: (a) Social Security number, (b) driver’s license number or state issued ID card number, and (c) a financial account number, or credit or debit card number.
How we use your information
We may use your Personal Information for the following purposes:
- Providing Our Services. To provide our Site and Services to you; to communicate with you, including via email, about your use of our Site and Services; to respond to your inquires; and for other customer service and support purposes.
- Customized Experience. To tailor the content and information that we may send or display to you, to offer personalized help and instructions, and to otherwise personalize your experiences while using the Services.
- Marketing and Communications. To communicate with you about your account and use of our Site and Services; to provide you with news and newsletters, research, and other items of interest regarding invest-related topics; to send you push notifications.
- Surveys. To administer surveys and questionnaires, such as for market research or client satisfaction purposes.
- Research and Analytics. To analyze how users interact with our Site and Services; to understand financial trends; and for other research, analytical, and statistical purposes.
- Protecting Rights and Interests. To protect our rights and interests as well as the rights and interests of our users and any other person, as well as to enforce this Privacy Policy and our Terms of Service.
- Legal Compliance. To comply with applicable legal or regulatory obligations, including informal requests from law enforcement or other governmental authorities.
How we disclose your information to third parties
We may disclose your Personal Information to the following third parties:
- Affiliates. We may disclose information to any current or future affiliates, parent companies, or subsidiaries of Callan.
- Service Providers. We may disclose your information to our vendors, service providers, agents, or others who perform functions on our behalf.
- Conferences and Events. If you register to attend a Callan-hosted conference or event, we may share your name, contact information, and other information you wish to share about yourself with persons registered on Callan’s Site.
We may also disclose your information in the following ways:
- Client and Financial Reports. We may disclose information in our client reports. For example, we may aggregate information about your company with information about similar companies to report on financial trends or provide investment manager information to our fund sponsor clients as part of a manager search.
- Mobile App User Content. You may also optionally make your profile public and visible to other app users. The mobile app enables you to post comments and photos that will be viewable by other users.
- Business Transfers. We may disclose information to another entity if we are or may be acquired by or merged with another company, if we sell or transfer a business unit or assets to another company, as part of a bankruptcy proceeding, or as part of any other similar business transfer. If the surviving entity involved in such a transfer is not Callan, in accordance with applicable law, the surviving company may use the information we collect about you pursuant to its own privacy policies, which may be different from this Privacy Policy.
- Protecting Rights and Interests. We may disclose information where we believe it is necessary 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 Service or this Privacy Policy, or as evidence in litigation in which we are involved.
- Legal Compliance. We may disclose your information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; in response to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.
- Aggregate and De-Identified Information. We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, security or other purposes.
Cookies and other tracking mechanisms
Callan and our service providers use cookies and other tracking mechanisms to track information about your use of our Site or Services. Callan and our service providers may combine this information with other Personal Information we collect about you. Additional information about these tracking tools is provided next:
- Cookies. We and our service providers may use cookies to track visitor activity on our Site. A cookie is a text file that a website transfers to your computer’s hard drive for recordkeeping purposes. We and our service providers may use cookies to track users’ activities on our Site, such as the pages visited, amount of time spent on each page, and general information about the device used to access our Site. Most browsers offer their own settings to manage cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether. Visitors to our Site who disable cookies may not be able to browse certain areas of the Site.
- Clear GIFs, Web Beacons, Pixel Tags, and Other Technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, which are embedded invisibly on webpages. We and our service providers may use clear GIFs (also known as web beacons, web bugs or pixel tags) in connection with our Site to track the activities of visitors to our Site, help us manage content, and compile statistics about usage of our Site. We and our service providers may also use clear GIFs in HTML emails to our users, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Third-party analytics
We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site and Services. We also may use other analytic means to evaluate our Site and Services. We use these tools to help us improve our Site’s and Services’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
Third-party links
Our Site and Services may contain links to third-party websites and applications. Any access to and use of such linked websites and applications is not governed by this Privacy Policy but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third-party websites or applications.
Security
Consistent with our obligations under applicable laws and regulations, we have taken steps to help protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your device and account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Your choices
You may modify the information that you have submitted by logging into your account or emailing us at [email protected].
Callan may send periodic emails to you containing links to research or other investment-related content that may be of interest. You may opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt out of receiving emails containing this content, Callan may still send you electronic notification about your account or any services you have requested or received from us.
Children
Our Site and Services are not designed for children under thirteen (13) years of age. If we discover that a child under 13 has provided us with Personal Information, we will promptly delete such Personal Information from our systems.
Contact us
If you have questions about this Privacy Policy or any privacy aspects of our Site or Services, please contact us at:
Callan LLC
One Bush Street, Suite 700
San Francisco, CA 94104
[email protected]
Additional Information For California Residents
This notice is provided to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice. As used in this section, “personal information” means information that meets the definition of “personal information” as set forth in the CCPA and is not otherwise excluded from the scope of the CCPA (e.g., publicly available information).
A California Resident’s Rights Under the CCPA
California residents have the below rights under the CCPA.
Right to Know
You have a right to submit a verifiable request for copies of your personal information that Callan has held over the past 12 months, free of charge, including:
The categories of personal information that we have collected.
The categories of sources from which we collected personal information.
The business or commercial purpose for collecting, selling, or sharing personal information.
The categories of third parties to whom we disclose personal information.
The specific pieces of personal information we have collected.
Right to deletion
At your request, we will delete your personal information unless we need to keep such information for legal or business purposes and/or to provide services or further the relationship with us that you have requested (including, but not limited to your role as an employee or other employment or business relationship).
Right to opt out of sale or sharing
Subject to certain business and legal exceptions, including those noted above, you may request that we stop selling or sharing your personal information for cross-context behavioral advertising. Notwithstanding the foregoing, we do not sell or share your personal information for cross-context behavioral advertising.
Right to correct
We will use commercially reasonable efforts to comply with your request to correct any inaccurate personal information.
Right to limit the use and disclosure of Sensitive Personal Information
Subject to certain business and legal exceptions, including those noted above, you may request that we limit the use and disclosure of sensitive personal information, as that term is defined under the CCPA (e.g., social security number, driver’s license number, passport number, account log-in information, and a precise geolocation).
Right to data portability
At your request, and subject to certain exceptions, we will provide you free of charge with any of your personal information that we hold, and will provide it in a structured, commonly used and machine-readable format.
Right to nondiscrimination
You are entitled to exercise the rights described above free from discriminatory treatment prohibited by the CCPA.
Categories of personal information we may collect
The categories of personal information that we may collect about you are:
Name
Phone number(s)
Email address (es)
Mailing address(es)
User ID(s), online identifiers, and log-in credentials
Internet Protocol addresses
Signature
Callan’s products or services purchased, obtained, or considered; and other purchasing or consuming histories or tendencies
Date of birth
Gender, sexual orientation, race, ethnicity, and national origin
Family-related data, e.g., marital status, family member information
Professional or employment-related information, such as job title and business contact information
Education information
Military status
Nationality
Residency
Internet activity information, such as browsing and search history, and interactions with websites and applications, our systems, and networks
Geolocation data
Biometric information, including imagery of the fingerprint, face, or voice recordings
Inferences, including inferences drawn from any of the information identified above, to create a profile about you, such as a profile that reflects your pronoun preferences, characteristics, abilities, and aptitudes
Sources from which personal information may be collected
In addition to the sources described above (see “How and why we collect information”), we may also obtain personal information about you from the following sources:
Public sources
Third parties that perform services for us or on our behalf
You or your representative(s), including your employer, if your employer is a client of ours
Government agencies
Automated technologies
Purposes for collecting personal information
In addition to the purposes described above (see “How we use your information”), we may collect your personal information for the following additional business and/or commercial purposes:
Marketing and communications
Training and quality-control
Customer education
To provide a customized and personalized list of our products and services that may interest you
To conduct business analysis, planning and reporting
To verify your identity
To protect you (e.g., to protect you against fraudulent or illegal activity)
To maintain the accuracy of our records
We retain each category of personal information that we collect for as long as necessary to fulfill the purposes described in this privacy policy.
Disclosures to third parties
As noted above in the section “How we disclose your information to third parties,” we may disclose your personal information with the following third parties:
Affiliates. We may disclose information to any current or future affiliates, parent companies, or subsidiaries of Callan.
Service Providers. We may disclose your information to our vendors, service providers, agents, or others who perform functions on our behalf.
Conferences and Events. If you register to attend a Callan-hosted conference or event, we may share your name, contact information, and other information you wish to share about yourself with persons registered on Callan’s Site.
Exercising your California privacy rights – Callan will respond to permitted CCPA requests in accordance with applicable laws if it can verify the identity of the individual submitting the request.
You may submit a CCPA request by emailing [email protected] or filling out this form.
Changes and Updates to this Privacy Policy
This Privacy Policy is reviewed periodically and updated to reflect any changes. Your provision of Personal Information to use after any change in this policy will constitute your acceptance of such changes.