Policies & Disclosures
Effective Date: December 15, 2023
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 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.
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.
- 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
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.
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.
- 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
- 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.
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.
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.
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.
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:
Email address (es)
User ID(s), online identifiers, and log-in credentials
Internet Protocol addresses
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
Internet activity information, such as browsing and search history, and interactions with websites and applications, our systems, and networks
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:
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
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
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
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:
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.