Privacy Policy

Last Updated: February 27 2024

Broughton Partners has developed this Privacy Policy that describes our practices concerning the collection, use, disclosure, transfer, and storage of your personal information. Our website may contain links to third-party websites. This Privacy Policy will not apply to any information you may provide while on such third-party websites and we recommend you review and become familiar with their privacy policies as well.

California Notice at Collection

We collect personal information detailed in the “Information We Collect” section for business purposes and commercial purposes outlined in the “Purpose of Collection (including business purposes)” column in the table below. To learn more, including how you can opt-out of the sale or sharing of your personal information, please see the “Exercising Your Privacy Rights” section below.

This Privacy Policy includes the following sections:

• Information We Collect
• Disclosure of Personal Information
• Security of Personal Information
• Retaining Personal Information
• Sale/Sharing of Personal Information
• California Rights
• Changes to Our Privacy Notice
• Questions and Contact Information

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. In particular, we have collected the following categories of personal information:

Disclosure of Personal Information

We have disclosed the following categories of personal information to our service providers for the business purpose of performing services on our behalf such as maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services on our behalf.

• Identifiers
• Customer Records
• Commercial Information
• Internet or Network Activity

We may also disclose personal information for the following purposes:

• Fraud Prevention: We may disclose your personal information when we believe disclosure is necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of us, our users, or others.
• Law enforcement or legal requests: We may disclose your personal information with government authorities, such as law enforcement authorities, courts, or regulators to comply with the law.
• Corporate Restructuring: We may transfer your information to a third party if we or any of our affiliates are involved in a corporate restructuring, including a sale, merger, or other transfer of some or all of our assets.

Security of Personal Information

We take the security of your personal information seriously. To protect the privacy and security of your personal information, we maintain physical, technical, and administrative safeguards. We update and test our security technology on an ongoing basis. Additionally, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.

Retaining Personal Information

We keep your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, as may be required by law (e.g., for tax and accounting purposes), or as otherwise communicated to you. This is based on the nature of the data, why the data was collected and processed, and additional applicable legal retention requirements.

Sale/Sharing of Personal Information

Broughton Partners has not sold personal information in the last 12 months.

California Rights

Residents of California are provided with the following privacy rights:

The Right to Access: You have the right to request that we disclose to you the categories of personal information we have collected, used, disclosed, or sold about you. You may also request a copy of the personal information we have collected about you.

The Right to Deletion: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.

The Right to Correct: You have the right to request that we correct any inaccurate personal information that we have collected from you and maintain.

The Right to Opt-Out: You have the right to opt out of the sale and/or sharing of your personal information with third parties as well as the right to opt out of targeted advertising. If you would like to opt out, please see the “Managing Your Cookie Preferences” section above.

Please see the “Exercising Your Privacy Rights” section below for details on how to submit a Right to Know and Access, Right to Deletion, and Right to Correct request.

We will not discriminate against you for exercising any of your privacy rights listed above. Unless permitted, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods and services; or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your Privacy Rights

If you are a resident of California and would like to exercise your rights as outlined, please contact us through either of the following options. Before we can process your request, we will ask you a series of questions in order to attempt to verify your identity. If you use an authorized agent to make a request on your behalf, we may ask the agent to verify their own identity and confirm with you that you provided the authorized agent permission to submit the request.

Calling us at 1-800-949-8904

Emailing us at info@broughtonpartners.com

Changes to Our Privacy Notice

We reserve the right to amend the Privacy Policy at any time and for any reason, without notice to you, other than the posting of the amended Privacy Policy. Users should check our site to see the current Privacy Policy that is in effect and any changes that may have been made to it. The provisions contained herein supersede all previous notices or statements regarding our privacy practices and the terms and conditions that govern them.

Questions

If you have questions regarding our Privacy Policy or your privacy rights as described above, please contact us at info@broughtonpartners.com.