Privacy Policy

Family Office Exchange Privacy Statement

Effective Date:  August 20, 2018

Family Office Exchange (“FOX”) is committed to protecting your privacy.  We want to tell you how we use and protect your personal data. This includes informing you of your rights regarding your personal information that we hold.

Personal data is any information relating to an identified or identifiable living person.  FOX processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.  

This Privacy Statement sets out how we may use, process and store your personal data. We may get that information from you or our partners, through contracts or other legal arrangements you have with us or our partners on behalf of us, in order to deliver contractual/legal obligations. In other cases, we will get that information from you with your permission and consent, or we may receive your personal information from third parties who you have given consent to pass this information on to us.
We do not sell or rent your personal information to any third party for marketing or other purposes.

This Privacy Statement applies only to information collected online through the FOX website and does not apply to any information you may provide to us, or that we may collect, offline or through other means (for example, via telephone, through the mail, or at live events). If you have any questions about this Privacy Statement, please email us at dataprivacy@familyoffice.com.
 

  I.      Scope and Consent
II.     Types of Information We Collect 
III.    How We Use Collected Information
IV.    Reviewing and Updating Your Information
V.     Information You Post to Discussion Forums and Other Community Posting Areas of Our Site
VI.    Links to Third-Party Websites
VII.   Securing Your Information
VIII.  Protecting the Privacy of Children
IX.    Changes to this Privacy Statement
X.     EU Data Subjects Rights
XI.    Data Controller and Contact Information 

 

I. Scope and Consent

When you use the Site, you are contracting with FOX, headquarters located at 100 S. Wacker Drive, Suite 800, Chicago, IL 60606. By using the Site, you expressly consent to our collection, use, disclosure, and retention of your personal information as described in this Privacy Policy.  We also may legally process your data because we have a contract with you, you gave us permission to do so, or you purchased a product from us. 
 

II. Types of Information We Collect

 
Information You Voluntarily Supply to Us
 
We may collect and store information that you voluntarily supply to us while on our site.  This may include personally identifying information if you choose to provide it.  In accessing and using the FOX website, you may have the opportunity to voluntarily submit some or all of the following types of information:  (i) contact information, such as your name, telephone number and email address; (ii) login information, such as a username and password; (iii) communications preferences; (iv) payment information (such as a credit card number) necessary to process a requested transaction; (v) information posted in discussion areas and other interactive areas of our site; (vi) information requested in connection with online surveys on our website; (vii) event registration information; and (viii) questions or correspondence you send us through the membership inquiry and/or other forms available on our site.
 
You are not required to provide information about yourself to visit our site.  However, if you wish to access certain areas of our site, you will be required to register as a FOX member or as a user of the FOX Public Network.  
 
Information That Is Collected Automatically
 
We also may collect and store, and permit our service providers to collect and store, information that does not identify you personally that is generated automatically as you navigate through the site.  For example, we and our service providers may collect limited information about the configuration of your computer or other device through which you visit our website, including the type of browser software you use, the operating system you are running, the resolution of your computer monitor, the website that referred you, and your IP address.  (An IP address is a numerical address that identifies your computer to other computers connected to the Internet so that data – such as the web pages you want to view – can be transmitted to you.)  We use this information to make our website as useful as we can for our users.
 
Cookies and Pixel Tags
 
We may use “cookies,” a standard feature found in browser software, to enhance your experience on the site.  Cookies are small files that your web browser places on your hard drive for record-keeping purposes.  We also may use pixel tags to collect non-personally identifying information about how our visitors use our site.  By showing how and when visitors and registered users use the site, cookies and pixel tags help us identify how many unique users visit our site and various pages within our site, and anonymously track user interests, trends and patterns.  For example, we may use these technologies to collect aggregate information about the time visitors spend on each page of our site or the number of visits made to each page or section of our site.  Providers of web analytics services or software may use cookies and pixel tags to gather this sort of information on our behalf.   

 
We also may use cookies to record certain preferences that you enter or set while using the site.  For example, if you are a registered FOX member or a registered user of the FOX Public Network and you opt to have the site “remember you,” we will use cookies to automatically store your log-in information so that you will not have to re-enter it the next time you visit.
 
The help function on most web browsers contains information on how to set your browser to notify you before accepting a cookie or to disable cookies entirely.  However, if you do not accept cookies, you will not be able to take advantage of certain features on our site.  For example, we will not be able to store your log-in information, so that you do not have to log in each time you visit, unless you accept cookies.

For further information visit www.aboutcookies.org or www.allaboutcookies.org
 

 

We May Use the following Cookies and Other Similar Technologies:

Categories of Use
 
Purpose
 
 
Strictly Necessary

These cookies allow us to link the actions of a user during a browser session in order to allow navigation around web pages, access to secure areas of the Websites or Platforms and help make the services available through our Websites and Platforms work. Without these cookies, basic functions of the Websites and Platforms would not work.

On the Platforms, we use session cookies for authentication and authorization purposes and to track a visitor’s identity during a particular session.

Because these cookies are strictly necessary to deliver our services, users cannot refuse them if you wish to access our site.

You can block or delete these cookies by changing the browser settings as explained below

Preferences

These cookies are used to store choices you make and your preferences regarding our services (such as your user name, language or the region you are in, enable user interface customization). These cookies allow us to provide enhanced, more personal features (such as enabling customer support for users, for example offering live support chat). These cookies are not essential for using our services. However, without these cookies, certain functionality may become unavailable or may not function properly.

For example, on the Websites we use cookies for use in managing the display of items or content (such as PageSize, SortField).

On the Platforms, we use user interface customization cookies to store Clients’ preferences such as grid preferences (columns, sort order, etc.) or to enable certain functions, such as to prepopulate the input of the RSS feed dialog.

You can block or delete these cookies by changing the browser settings as explained below.
Analytics

These cookies allow us to recognize and count the number of visitors and to see how visitors move around the Websites and Platforms when they are using it. This helps us to improve the way our the Websites and Platforms work, for example by making sure visitors are finding what they need easily. The information collected through these cookies include anonymous traffic statistics, like number of page views, number of visitors, and time spent on each page.

In particular, we use cookies from Google Analytics, a web analytics service provided by Google Inc. (“Google”) The information collected by Google (including your internet protocol (IP) address) will be transmitted to and stored by Google on servers in the United States. Google will use this information on our behalf for the purpose of evaluating your use of the Websites, compiling reports on the Websites activity and providing further services to us relating to the Websites usage. Learn more about Google Analytics’ privacy practices, and see a copy of Google’s privacy policy, at the following link: https://support.google.com/analytics/answer/6004245?hl=en&ref_topic=2919631.

You can block or delete these cookies by changing the browser settings as explained below.
You can also prevent your data from being collected by Google Analytics on the Websites by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser at the following link: https://tools.google.com/dlpage/gaoptout?hl=en
 

When you visit or interact with our site, services, applications, tools or messaging, we or our authorized service providers may use cookies, web beacons, and other similar technologies for storing information to help provide you with a better, faster, and safer experience and for advertising purposes. We may use third parties to serve advertisements on other websites that may be of interest to you, based on information collected about your use of our site and other websites.  To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags and web beacons). 

Google Analytics Cookie.  Google Analytics is a web analytics service provided by Google Inc. ("Google"). Google Analytics uses cookies and similar technologies to analyze how users use a website. The information generated about website usage (including your shortened IP address) is transmitted to Google. This information is used to evaluate visitors’ use of the website, compile statistical reports on website activity, and provide other services related to the site and internet use. Google may also collect information about a visitors’ use of other websites. For more information about Google Analytics, or to opt out of Google Analytics, please go to: https://tools.google.com/dlpage/gaoptout.  

Google AdWords Remarketing cookie. Our website uses a remarketing advertising service (Google AdWords Remarketing) provided by Google, which uses cookies to help us deliver targeted online adverts based on past visits to our website. Google uses this information to display our adverts on various third-party websites across the internet. Google AdWords Remarketing allows us to tailor our marketing to better suit your needs and only display ads that are relevant to you. To learn more about Google Analytics’ privacy practices, please visit https://www.google.com/policies/technologies/ads/.  You may opt out of Google’s use of cookies by visiting Google’s Ads Settings.

Facebook Pixel. Facebook Pixel is an analytics tool that allows us to measure the effectiveness of our advertising by understanding the actions you take on our website. In this way, we can tailor our marketing to better suit your needs and only display ads that are relevant to you. When you visit our website and take an action (for example, downloading a white paper or clicking on a graphic), the Facebook Pixel is triggered and reports this action. To learn more about Facebook’s privacy practices, please visit https://www.facebook.com/about/privacy/. You can opt out of the use of Facebook Pixel by visiting the adverts tab in your Facebook profile settings.

LinkedIn Insight Tag. The LinkedIn insight tag allows us to perform campaign reporting and gather insights about website visitors that may come via the campaigns we run on LinkedIn.  For this purpose, our website integrates the LinkedIn Insight Tag, which enables LinkedIn to collect statistical, pseudonymous data about your visit and use of our website, and to provide us with aggregated statistics on this basis. In addition, this information is used to show you specific and relevant offers and recommendations, after you have informed yourself on the website about certain services, information and offers. The relevant information is stored in a cookie. You may object to this form of data processing by adjusting your browser settings on your computer or on any other device with which you access our services. If you do not want us to place cookies, you may decline certain cookies on the LinkedIn settings page. To learn more about LinkedIn’s Insight Tag’s, please visit https://www.linkedin.com/legal/privacy-policy.

Marketo’s Pixel and Cookie. We use third-party marketing software from Marketo, Inc. (“Marketo”) to send our emails. We use a Marketo pixel tag as part of tracking so we have information on email open rates and click through rates. We also track activity on the website. For example, visitors can download white papers from the site and we use Marketo cookies to identify who does this and if they then visit other parts of our website. When on a page, the Marketo cookies automatically gather the following information: page visits; link clicks; IP address; referrer, cookie ID. The cookies placed by the Marketo server are readable only by Marketo. For more information on Marketo privacy practices, please visit the Marketo privacy policy: http://www.marketo.com/trust/legal/privacy.  If you prefer that we do not place Marketo cookies on your web browser, you may opt out by selecting the Do Not Track (DNT) feature in your web browser.

Hotjar Tracking Cookies. We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link.

You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.

URL and IP Address 

FOX collects information about users’ IP addresses, including users’ utilization of our Websites, to help us design our Websites to better suit our Website users’ needs. We may use information about your IP address to help diagnose problems with our server, administer our Websites, analyze trends, track visitor movements, and gather information that assists us in identifying visitor preferences. We also may use your IP address to enhance our security and investigate an actual or potential security incident. For EU Data Subjects, this use of your information is necessary for our legitimate interests in understanding how the Websites and our Services are being used by you, to improve your experience on it and ensuring network and information security. 
 

III. How We Use Collected Information

We use the information we collect from you while you are using the site in a variety of ways, including, for example, to process your registration, to provide you with products, services and communications that you have requested, to send you email updates and other communications, to deliver our site content to you, to measure site traffic, to measure user interests and traffic patterns, and to improve the site and the services and features offered via the site.
 
In addition, we may use your information to contact you for membership and prospective membership service purposes, to inform you of important changes or additions to our site or the services offered over our site, to send you administrative notices and other information about our site, and to tell you about products or services offered by FOX that we think may be of interest to you.  Although we hope you will find these communications informative and useful, if you do not, you can always update your account information and preferences to no longer receive such communications.
 
When you purchase any product or service on our site, we collect the information necessary to process the requested transaction, such as your name, email address, mailing address, billing address, and credit card information.  FOX does not store your credit card information; it is sent directly to our third-party credit card processor and is secured during transmission over the Internet using industry-standard secure sockets layer (SSL) encryption.  Our credit card processor is authorized to use your credit card information only to process your requested transaction, and for no other purpose.
 
We may share anonymous tracking information that is collected through this site with our third-party service providers solely for purposes related to site administration and operation.
 
We may occasionally release information about our visitors and registered users if required to do so by law or if, in our judgment, such disclosure is reasonably necessary to comply with legal process, to enforce our Terms and Conditions, or to protect the rights, property, or personal safety of visitors to our site, our employees, our members, or others.
 
We also may make some products and services available through our site through cooperative relationships with third-party providers, where the brands of our provider partner appear on the site in connection with such products and/or services.  We may share with our provider partner any information you provide, or that is collected, in the course of visiting any pages that are made available in cooperation with our provider partner.  In some cases, the provider partner may collect information from you directly, in which cases the privacy statement of our provider partner may apply to the provider partner’s use of your information.  The privacy statement of our provider partners may differ from ours.  If you have any questions regarding the privacy statement of one of our provider partners, you should contact the provider partner directly for more information.

You have a right at any time to stop us from contacting you for marketing purposes.  If you no longer wish to be contacted for marketing purposes, please email us at dataprivacy@familyoffice.com.

Retention of Personal Information

We retain Personal Information that you provide us as long as we consider it potentially useful in contacting you about our services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements, and then we securely delete the information. We will delete this information from the servers at an earlier date if you so request, as described in "Opting Out and Unsubscribing" below.

Use of Data Processors 

Data processors are third parties who process data for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organization apart from us. They will hold it securely and retain it for the period we instruct. We use the following third-party data processors:

Acquia
OS33
Higher Logic
Microsoft
Marketo 
CVENT
Kasaya
Citrix
Scribe
Qualtrics
Cybersource/Authorize.net
Vantiv
Maxmind

Security of Processing 

We will process personal data securely, apply and maintain appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing.
 

IV.  Reviewing and Updating Your Information

If you are a registered FOX member or a registered user of the FOX Public Network, you can make changes to your account information and preferences by logging in to the site and using the account tools available via the site.  If you have any questions about modifying your account or preference information, please email us at dataprivacy@familyoffice.com.

 

V. Information You Post to Discussion Forums and Other Community Posting Areas of Our Site

Please keep in mind that whenever you voluntarily make your personal information or other private information available for viewing in discussion forums or in other posting areas of our site that information may be seen, collected and used by other registered users of our site; we are not able to control how they may use this information.  Information posted in Family Office and/or Wealth Owner member–only discussion forums will only be accessible by other family office and wealth owner members.  We cannot be responsible for any use of such information by others that have access to the posting areas.   
 

VI. Links to Third-Party Websites

Our website may provide links to third-party sites.  This Privacy Statement does not apply to any information you may provide while on such third-party sites.  We encourage you to read the privacy statements on those sites before providing any of your personal information to them.
 

VII. Securing Your Information

We use industry-leading administrative, technical and physical security measures to protect your personal information from unauthorized access and use.  However, as effective as the security measures implemented by us may be, no physical or electronic security system is impenetrable.  We cannot guarantee the security of our site’s servers or databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us or our third-party service providers over the Internet.
 

VIII. Protecting the Privacy of Children

Our website is not directed to children under the age of 13 and we will not knowingly allow anyone under the age of 13 to use this website to provide us with any personal information.  Children should always get permission from their parents before sending any information about themselves (such as their names, email addresses and phone numbers) over the Internet.  If you are under the age of 13, please do not provide any information about yourself on this website.
 

IX. Changes to this Privacy Statement

The Web is an evolving medium.  If we need to change this Privacy Statement in the future, we will post the revised Privacy Statement on our site and update the “Effective Date,” above, to reflect the date of the changes.  By continuing to use this website after we post such changes, you agree to the terms of this Privacy Statement, as modified.
 
X.  EU Data Subjects Rights

This section applies if you are an individual located in the European Union (“EU”) (“EU Data Subject”). For these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland.

Rights to Access and Control Your Personal Data

Subject to applicable law, EU Data Subjects have the following rights in relation to their Personal Data:

Access to personal data

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us at the following address at dataprivacy@familyoffice.com

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. 

Amendment of personal data

To update personal data submitted to us, you may email us at dataprivacy@familyoffice.com or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which you registered.

When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.

Withdrawal of consent

Where we process personal data based on consent, individuals have a right to withdraw consent at any time.  To withdraw consent to our processing of your personal data please email us at dataprivacy@familyoffice.com or, to stop receiving bulk emails from FOX, please click on the unsubscribe link in the relevant email received from us.  

Right to erasure 

You may ask us to delete or remove your Personal Data and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion). If we have shared your data with others, we will tell them about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly. 

Right to restrict processing 

You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of that Personal Data or object to us processing it. We will tell you before we lift any restriction on processing. If we have shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.

Right to data portability

Effective May 25, 2018, you have the right to obtain your Personal Data from us that you consented to give us or that is necessary to perform a contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.

Other data subject rights

This privacy statement is intended to provide information about what personal data we collect about you and how it is used.  As well as rights of access and amendment referred to above, individuals may have other rights in relation to the personal data we hold, such as a right to erasure/deletion, to restrict or object to our processing of personal data and the right to data portability.  

If you wish to exercise any of these rights, please send an email to dataprivacy@familyoffice.com.  

Complaints

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to dataprivacy@familyoffice.com.  We will look into and respond to any complaints we receive.

You also have the right to lodge a complaint with the Information Commissioner's Office (“ICO”) (the UK data protection regulator).  For further information on your rights and how to complain to the ICO, please refer to the ICO website.

To exercise any of these rights, please contact us at dataprivacy@familyoffice.com or by mail to Family Office Exchange, 100 S. Wacker Drive, Suite 800, Chicago, IL 60606 USA, Attention: DPO. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.


XI.  Data Controller and Contact Information 

The data controller is Family Office Exchange, a Delaware limited liability company.

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Data Protection Officer
Family Office Exchange
100 S. Wacker Drive
Suite 800
Chicago, IL 60606

Email: dataprivacy@familyoffice.com
Phone: 1-312-327-1200