Privacy Policy

Common Sense Publishing, LLC, dba The Frankfurt Newsletter (“The Frankfurt Newsletter,” “we”, “our” and/or “us”) knows that you care about how information about you is collected, used and shared, and we appreciate your trust that we will do so carefully and sensibly. This notice describes our Privacy Policy, which applies to The Frankfurt Newsletter. This Privacy Policy applies to information we collect from all sources, including in connection with our website located at www.thelondonletter.eu and any mobile or other website operated by us (the “Websites”), the software applications made available by us for use on or through computers and mobile devices (the “Apps”), and our publications, newsletters, memberships, portfolio solutions, webinars, conference calls, e-letters, blogs, books, electronic communications, widgets, conferences and events (collectively, the “Services”). By providing personal information to us or by using the Services, you agree to this Privacy Policy. This Privacy Policy is further subject to the The Frankfurt Newsletter Subscriber Agreement and Terms of Use (the “Agreement”) relating to the Services you purchase, use and/or access. For questions on this Privacy Policy, please contact our customer service department (“Customer Service”) by emailing [email protected] (any such request must include “Privacy Policy” in the subject line) or by calling (888) 501-2598 between the hours of 9:00 a.m. and 5:00 p.m. ET. Please note that your decision to use the Services and your choice to provide us with your personal information is voluntary. We indicate the types of personal information we request in our online, mobile and other registration forms and in other places where we request such information. You may elect not to submit certain personal information requested by us, but that election may limit or prevent our ability to provide certain Services and products to you. What Personal Information Do We Collect? The Frankfurt Newsletter collects the personal information you enter on our Websites or give us in any other way, such as via telephone, email, online or otherwise. For example, this information may be collected when you contact Customer Service for support purposes. We collect this personal information in order to offer Services you have requested or which we believe are of interest to our customers, to manage relationships we have with our customers and partners, to perform activities on your behalf, and for the security of The Frankfurt Newsletter, our Websites, Services and customers. The following describes the types of personal information we collect: Contact Information: We collect and retain personally identifiable information that you submit to us voluntarily and this includes, but is not limited to, your name, postal address (including billing and shipping address), telephone number and email address. For example, this contact information may be used to communicate with you with respect to transactions relating to the Services we provide. Additionally, we may collect contact information provided to us during any correspondence or telephonic contact relating to Customer Support, as well as in connection with the Services we offer and the Websites we operate. Financial Information: We collect and retain certain financial information from you, such as when you order our Services. For example, when you sign up for a Service that requires a paid subscription, we require you to provide a form of payment and certain information such as a credit card number and billing address before we will process that application. We will not sell, share or rent any financial information collected from you except as disclosed in this Privacy Policy or as necessary to fulfill any order for our Services, or as indicated separately at the point of collection of that information. Demographic Information: We may collect and store demographic information (such as your zip code, income, gender and age) and use this data to tailor your experience on our Websites, provide content that we think you might be interested in, perform general improvements to the Websites, and display the content according to your preferences. We may also anonymize this demographic data. Such demographic information may be shared with partners, market researchers and other third parties on an aggregate, non-personally identifiable basis. No personally identifiable information will be linked to such aggregated demographic information that is shared with third parties. Other Information: We collect and store certain types of information whenever you interact with us. For example, our servers track the type of web browser you are using and the page from which you link. Additionally, we log IP addresses (a unique number assigned to every computer on the Internet) in order to improve security, analyze trends and administer the Websites. We may track your movement within the Websites, the third-party website pages from which you were referred, access times and browser types. We use this information to gauge the effectiveness of our Services, track information for statistical purposes and to improve our Services. We may use such information for marketing purposes, and to provide you with information we believe might be of interest to you. In addition, such information may be shared with partners, market researchers and other third parties on an aggregate, non-personally identifiable basis. No personally identifiable information will be linked to such aggregated information that is shared with third parties. We may supplement the information you provide us by acquiring publicly or commercially available information as is available in the public domain or from third parties, such as data brokers, business partners, payment and delivery services, and advertising networks, for instance, to verify your address, add a telephone number, or to update your information and to create a profile of your preferences. We tie your personally identifiable information to information in the profile, in order to improve the content of the Websites for you or to inform you about Services that we think may be of interest to you. From time to time, we may also ask you to participate in surveys or other communications conducted by us or third parties designed to help us improve the Websites or the Services we provide. Cookies: The Websites may use “cookie” technology for such purposes as enhancing your online experience by making it easier for you to navigate through the Websites and making certain features work better. Cookies are text files which are commonly deposited by websites on a user’s hard drive when the user visits a website. The file identifies a user’s computer and can record the user’s preferences and other data about the user’s website visit. Your web browser may enable you to disable cookies, but please note that certain Services may not function correctly without it and your experience on our Websites may be reduced. Third-Party Advertising Companies: We may use third-party advertising companies to serve ads on our behalf across the Internet. These companies may collect and use information about your visits to this Website and other websites and your interaction with our Services in order to provide advertisements about Services that may be of interest to you. However, we do not provide personally identifiable information (such as your name, address, email address or telephone number) in connection with third-party advertisements that will be connected with such information. Such third-party advertising companies may use information about your visits to this Website and other websites to target advertisements for our Services and they may keep track of user response to each advertisement. These targeted advertisements may appear on our Websites or on other websites that you visit. The anonymous information is collected through the use of a pixel tag or cookies, which are industry standard technologies used by most major websites. To learn more about the use of this information or to choose to not have this information used by certain third-party advertising partners, please visit the Network Advertising Initiative at http://optout.networkadvertising.org/#!/ or go to https://www.adobe.com/privacy.html. Please note that if you delete your cookies, use a different browser or buy a new computer, you will need to renew your opt-out choice. Web Beacons: The Websites may contain electronic images (called a “single-pixel GIF” or a “web beacon”) that allow a website to track the effectiveness of marketing campaigns. No personally identifiable information will be transmitted via web beacons. Telephone Recording and Monitoring: To ensure that The Frankfurt Newsletter customers receive quality service, and for other operational and lawful purposes, we may record and/or monitor customers’ (and potential customers’) calls with our employees or agents. These calls between our customers (or potential customers) and our employees or agents may be evaluated by supervisors and/or other The Frankfurt Newsletter representatives. This is to ensure that prompt, consistent assistance and accurate information is delivered in a professional manner and for ongoing compliance purposes. We may also retain and use such recordings where necessary to protect our business, customers, or Services, or where required by applicable law. In contacting The Frankfurt Newsletter, creating an account with us, or by otherwise utilizing any Service, you hereby consent to any such call recording and/or monitoring. You should also note that when our Customer Service representative calls a customer (for instance, following a request for a return call), these outbound calls may also be recorded and monitored. How We Use and Share Personal Information We receive and store any personal information you enter on our Websites or give to us voluntarily in any other way, as well as information that we independently associate with you through publicly or commercially available sources that are available in the public domain or from third parties. We may use your personal information to contact you from time to time. We may also send you information or offers from time to time to the postal address or email address we have on file as further described herein. Your Email Address: From time to time, The Frankfurt Newsletter may use your personal information to contact you by email concerning our Services. We may also send you promotional materials regarding offerings from affiliates and non-affiliated third parties whose services and products we think may be of interest to you. These email communications are often intended to inform you of important information regarding your account, or about general services provided by The Frankfurt Newsletter. If you do not want to receive email from us regarding our Services, please click the “unsubscribe” link which is included at the bottom of any email you receive from us. However, in order to fulfill our service obligations to you, we will continue to send you emails regarding your account administration, as well as any necessary information, such as renewal notices and instructions. By providing us with your email address you consent to receiving communications from us electronically and all notices, disclosures and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing. Your Telephone Number: By registering on a Website or providing your telephone number to us through other methods (for instance, during an inquiry you make to our Customer Service telephone line), you agree that this action constitutes a purchase, inquiry and/or application for purposes of telemarketing laws. Regardless of the fact that your telephone and/or mobile number may be listed with the Federal Do-Not-Call Registry or your State Do-Not-Call list, you are providing your express written consent to receive future information (including telemarketing) about products and services from us, and you hereby agree and consent to our contacting you using the information you have provided and will provide to us. This means we may contact you by e-mail, phone and/or mobile number (including use of automated dialing equipment and/or pre-recorded calls), text (SMS) message, social networks or any other means of communication that your wireless or other telecommunications device may be capable of receiving (i.e., video, etc.). You further acknowledge that you are not required to agree directly or indirectly or enter into an agreement regarding our telemarketing efforts as a condition of purchasing any Services from us. Promotions: If you provide your name for a promotional offer, or to enter a sweepstakes or contest, and you win a prize, we may post a winner’s list online and/or offer such a list to those who request it by mail. Your name and city may be listed and we will file your name with governmental agencies if required by law. Testimonials and Questions from Customers: From time to time we may include customers’ questions (or a summary) and our answers to those questions that we think may have interest or applicability to others. We will not disclose the customer’s full name but may use an abbreviated form, such as “Julie K.” Please note that The Frankfurt Newsletter is a financial publisher and therefore will not provide any responses that offer individual, personalized investment-related advice to subscribers, prospective subscribers or any other type of user. In addition, we may post customer testimonials on the Websites, in newsletters, or in other formats. Again, we will not disclose the customer’s full name but may use an abbreviated form as described above. Third Parties: We may provide you with promotional materials regarding offerings from affiliates and non-affiliated third parties whose services and products we think may be of interest to you. If you choose to do business with these affiliated or unaffiliated third parties as a result of such promotions, we may share your personal information with them. These entities may then send you promotional or administrative communications, by emails or otherwise. If you do not wish to receive those communications, you should contact these entities directly. If you do not want us to use the information you provide in order to inform you of products and services we think might interest you, or do not want us to provide your information to third-party companies, it is your obligation to let us know by emailing Customer Support at [email protected] (any such request must include “Privacy Policy” in the subject line) or by calling (888) 501-2598 between the hours of 9:00 a.m. and 5:00 p.m. ET. Agents and Service Providers: We engage other companies, individuals and affiliates of The Frankfurt Newsletter to perform certain functions and/or services for our customers. Examples may include processing credit card payments, providing marketing assistance and removing repetitive information from customer lists. Your contact and financial information may either be collected by or shared with such third parties as necessary to fulfill these functions and services, and in some cases, your information may be retained or used by such third parties to fulfill these functions and services. We contract with service providers to provide us with data collection and reporting services. When you visit our Websites, those service providers may collect information on our behalf about you in order to provide us with aggregated data about our customers and to assist us in conducting our business and delivering relevant services to our customers. If you would like to opt-out of the gathering of such information, you can disable your cookies that assist in the gathering of that data, but please note that certain services and functions of our Websites may not function correctly without cookies. Service-Related Uses: We may use your personal information to contact you about the Services you have purchased, used or otherwise accessed, or for other purposes in which you have expressed an interest. For example, we will also provide you with announcements or updates relating to the Services and your account, such as if the delivery of a Service is delayed. In such an instance, we may send you an email or other message regarding such delay. Generally, you may not opt out of these communications, which are not promotional in nature. Protection of The Frankfurt Newsletter and Others: We may release account and other personal information when we are required to do so by law, court order, subpoena or other government or law enforcement authority or regulatory agency, in order to enforce or apply our Agreement or other agreements, or when we believe in good faith that disclosing this information is necessary or advisable, including for example, to protect the rights, property, or safety of The Frankfurt Newsletter, our customers and users, or others. This includes exchanging information with other individuals, companies and organizations for fraud protection, credit risk reduction or other similar purposes. Terms and Conditions/Point of Collection: We may also disclose information about you as otherwise permitted under our Agreement or as specifically disclosed when we collect information from you. Change in Business Ownership or Structure If the ownership of all or substantially all of The Frankfurt Newsletter’s business changes, or we undertake a corporate reorganization (including, but not limited to, a merger or consolidation), or a potential sale of some or all of our business or assets, or there is an event of insolvency, bankruptcy, receivership or pledging of assets, or there is any other action or transfer between or among The Frankfurt Newsletter and its affiliates, you expressly consent to The Frankfurt Newsletter transferring your information, including your personal information, to the prospective or actual new owner or successor entity. Also, information about our subscribers and users, including personal information, may also need to be disclosed in connection with a commercial transaction seeking financing, investment, support or funding. Our Advertising Our Websites and Services may contain links to other websites, including those of advertisers. We are not responsible for the claims or representations made by advertisers or third parties. We also may use service providers and other third parties to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services. This practice is based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/. You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps. Third-Party Services and Websites This Privacy Policy does not address, and The Frankfurt Newsletter has no control over or responsibility for, the privacy policies or information gathering practices of any third party operating any website or providing any product or service, including those to which we may link and those which may link to us. The inclusion of a link on our Websites or Services does not imply endorsement of the linked website or service by us. We strongly recommend that you review the privacy policies of every online service you use before submitting any personal information and direct any concerns to the site administrator of that website. In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Google, Microsoft, or any other app developer; app, social media platform, operating system or wireless service provider; or device manufacturer, including with respect to any personal information you disclose to other organizations through or in connection with any of our software applications made available by us for use on or through computers and mobile devices. Limitation of Liability The Frankfurt Newsletter ASSUMES NO RESPONSIBILITY OR LIABILITY WITH REGARD TO ANY THEFT, LOSS, ALTERATION OR MISUSE OF PERSONAL OR OTHER INFORMATION LAWFULLY PROVIDED BY The Frankfurt Newsletter TO THIRD PARTIES, OR WITH REGARD TO THE FAILURE OF ANY THIRD PARTY TO ABIDE BY THIS PRIVACY POLICY OR SUCH THIRD PARTY’S PRIVACY POLICY OR ANY AGREEMENT BETWEEN THAT THIRD PARTY AND The Frankfurt Newsletter. Choices and Opting Out You may opt out of marketing communications from us by contacting Customer Support or opting out from the opt-out link in any marketing email we send to you. We give you choices regarding our use and disclosure of your personal information for marketing purposes. You may opt out from: Receiving text alerts from us that you previously opted in to receive. You can unsubscribe from delivery of our text alerts by following the instructions in any such text messages. Our sharing of your personal information with affiliates or unaffiliated third parties for their marketing purposes. If you prefer that we not share your personal information on a going-forward basis with our affiliates or unaffiliated third parties for their marketing purposes, you may opt out of this sharing by emailing Customer Support at [email protected] (any such request must include “Privacy Policy” in the subject line) or by calling (888) 501-2598. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out. Accessing and Updating Personal Information To ensure that the personal information we maintain about you is accurate and up to date, please inform us immediately of any changes by emailing Customer Support at [email protected] (any such request must include “Privacy Policy” in the subject line) or by calling (888) 501-2598 between the hours of 9:00 a.m. and 5:00 p.m. ET. We may retain your information in our files after you terminate all your Services and/or account with us in order to resolve disputes, enforce our Agreement, to adhere to the technical and legal requirements and constraints related to the security, integrity and operation of the Services and our Websites, and to comply with applicable legal requirements such as court orders, subpoenas and other service of process. The Frankfurt Newsletter will maintain your personal information for as long as it deems necessary in its sole discretion, or as required by applicable laws, regulations, or government orders. Current and former customers may request this information by emailing Customer Support at [email protected] (any such request must include “Privacy Policy” in the subject line) or calling (888) 501-2598 between the hours of 9:00 a.m. and 5:00 p.m. ET. We will try to comply with your request as soon as reasonably practicable. Please note, however, that no financial information will be provided over the phone, and in no event will such information be provided without verification. Data Security and Integrity The Frankfurt Newsletter has reasonable security policies and procedures in place to protect personal information within our organization from unauthorized loss, misuse, alteration or destruction. Unfortunately, security cannot be absolutely guaranteed against all threats. Please be advised that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their systems, or they have a general reputation for applying such measures. You can further help to ensure your security by taking a few simple precautions. Do not include any personal information in any username or password or in any chat group or message board that you access through the Services. In addition, in order to protect against unauthorized access to your computer and to any The Frankfurt Newsletter username and password, you should sign off when you are finished using a shared computer, and not share your The Frankfurt Newsletter username and password. If you have reason to believe that your interaction with us is no longer secure, you are required to notify us in accordance with the “Contacting Us” section below. Cross-Border Transfer Our online services are U.S.-based and are controlled, operated and administered by Stanberry Research from its offices within the United States, and are made available to you on an unsolicited basis, without any marketing or promotion by The Frankfurt Newsletter regarding these online services to persons or entities outside the U.S. This Privacy Policy is provided in accordance with and subject to applicable U.S. law. If you decide to continue to access our online services from your location outside the U.S., you hereby agree that your use of those services is subject to this Privacy Policy and your personal information will be transferred or processed in the United States. Use of Services by Minors The Services and the Websites are not directed to individuals under the age of thirteen (13). The Frankfurt Newsletter does not knowingly collect personal information from such individuals and we request that they not provide personal information through the Services or the Websites. If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under the age of 13, please email Customer Support at [email protected] (any such request must include “Privacy Policy” in the subject line) or call (888) 501-2598 between the hours of 9:00 a.m. and 5:00 p.m. ET. Privacy Policy Updates We reserve the right to change, update or modify this Privacy Policy at any time at our sole discretion, and will post any new Privacy Policy here. The “Last Updated” date at the top of this page indicates when this Privacy Policy was last revised. Any such change, update or modification will be effective immediately upon posting on our Websites. If we deem any changes material (in our sole discretion), we may notify you by email at the email address that we have on record for you in addition to posting updates to this Privacy Policy. You are responsible for checking our Websites frequently to keep apprised of recent changes. By accessing our Websites or utilizing our Services following these changes, you are deemed to have agreed to our then current Privacy Policy and will be bound by its terms. If you do not agree to our then current Privacy Policy, do not use our Websites or our Services. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder of the Privacy Policy to be valid and enforceable. Your California Privacy Rights Subject to the terms herein regarding a change in business ownership or structure, we do not share personal information (as defined by California Civil Code Section 1798.83) collected by us for the Services we provide you with third parties for their direct marketing purposes without giving you the opportunity to opt in or opt out as more fully described above in the “Choices and Opting Out” section. If you are a California resident, you may request information about our compliance with California law by emailing us at [email protected] or by sending a letter to The Frankfurt Newsletter, 55 NE 5th Avenue, Delray Beach, FL 33483, Attention: Legal Counsel. Any such request must include “California Privacy Rights Request” in the subject line and include your name, street address, city, state and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this designated email address or mailing address. California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how The Frankfurt Newsletter responds to "Do Not Track" browser settings. The Frankfurt Newsletter does not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created. Contacting Us For questions about this Privacy Policy, please contact Customer Service by emailing [email protected] (any such request must include “Privacy Policy” in the subject line) or by calling (888) 501-2598 between the hours of 9:00 a.m. and 5:00 p.m. ET.