Internet Privacy Policy

Introduction

WE Family Offices LLC (“Company” or “We”) respects your privacy and are committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit the website https://www.wefamilyoffices.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to any information we collect:

  • On this Website including, without limitation, on data collection forms linked to third-party applications that store data on third-party websites; and
  • In email, text, and other electronic messages between you and this Website.

It does not apply to information collected by:

  • us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
  • any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy, below). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

  • that is about you but individually does not identify you; and/or
  • about your internet connection, the equipment you use to access our Website and usage details;
  • Unless you elect to complete our contact form, we do not collect information by which you may be personally identified, such as your name, postal address, e-mail address, telephone number, or social security number (“personal information”);

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies including, without limitation, screen capture.

Information You Provide to Us.

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of requesting further services. We may also ask you for information when you report a problem with our Website.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical data and does not include personal information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies).
    A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies.
    Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
  • Web Beacons.
    Pages of our the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
  • Screen Capture.
    If you enter our Website, we may use a software application that allows us to record and replay anonymized data of your website visit to allow us to make website and webpage usage heat maps and improve the Website’s design and ease of use.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • For any other purpose with your consent.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this privacy policy to check for any changes.

Privacy Policy Notice for California Residents

Your California Privacy Rights

If you are an eligible California resident, the California Consumer Privacy Act (“CCPA”) provides you with specific rights with respect to our collection and use of personal information. This California Privacy Rights Section supplements our Privacy Policy and applies solely to eligible residents of California as of January 1, 2020. Any terms not defined in this section have the same meaning as defined in the CCPA.  This statement does not apply to information collected, processed or disclosed pursuant to the Gramm-Leach-Bliley Act, its implementing regulations or the California Financial Information Privacy Act. 

(a) Information We Collect:

We collect personal information. We have collected the following categories of personal information from our consumers within the last twelve (12) months: 

Please note that some of the categories of personal information described in the CCPA overlap with each other; for instance, your name is both an Identifier and a type of data described in Cal. Civil Code 1798.80(e).

Personal information does not include publicly available information from government records or any deidentified or aggregated consumer information. In addition, the CCPA excludes the following from its scope: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.  You may receive separate notices about your rights under other applicable laws as required by those laws. 

We collect this information directly from you when you provide it to us and automatically as you use the Service. This information may include usage details, IP addresses, browser type, location information, and information collected through cookies and other tracking technologies; and from third parties. 

(b) Use of Personal Information:

We may use or disclose the personal information we collect for the purposes described above in the Section titled HOW WE USE AND SHARE THE INFORMATION WE COLLECT. 

(c) Sharing Personal Information:

The Company may disclose your personal information to third parties for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who access the personal information we hold from reselling it unless you have received explicit notice from the third-party with an opportunity to opt-out of the sale. 

We share your information as described in the section above titled Sharing of your Personal Information. In the preceding twelve (12) months, the Company has disclosed the following categories of personal information for a business purpose: identifiers; California Customer Records personal information categories; protected classification characteristics under California or federal law; commercial information; internet or other similar network activity; professional or employment-related information; and inferences drawn from other personal information.  

(d) Sales of Personal Information:

The Company does not sell your personal information to any third parties. 

(e) Your Rights & Choices If You Are an Eligible California Resident:

  • Right to Know About Personal Information Collected, Disclosed, or Sold

If you are an eligible California resident, you have the right to request that we provide certain information to you about our collection and use of your personal information over the past twelve (12) months. Specifically, you have the right to request disclosure of the categories of personal information and specific pieces of personal information we have collected about you over the last 12 months. Upon the submission of a verifiable consumer request (see Exercising your California Privacy Rights), we will disclose to you: 

  • The categories of personal information we collected about you;
  • The categories of sources from which personal information was collected;
  • Our business or commercial purpose for collecting personal information;
  • Our business or commercial purpose for disclosing or selling personal information; and
  • The categories of third parties with whom we shared personal information.

We will also provide the specific pieces of personal information we collected about you, subject to certain exceptions under applicable law, if you also request access to such information. 

  • Right to Request Deletion of Personal Information

If you are an eligible California resident, you also have the right to request that we delete any of your personal information that we collected or maintain about you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will conduct a reasonable search of our records in order to locate any personal information we have collected about you that is eligible for deletion and delete such personal information. To the extent we have shared any personal information collected about you with service providers that is eligible for deletion, we will direct those service providers to delete that personal information as well. For the sake of clarity, however, the Company may not be able to comply entirely with your request to delete all of your personal information as set forth under the CCPA. For example, if you placed an order with us, the CCPA allows us to keep records related to these types of transactions in order to complete a transaction for which your personal information was collected. Specifically, we are not required to delete any personal information we have collected about you that is necessary for us and our service provider(s) to: 

  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between the Company and you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
  • Debug to identify and repair errors that impair existing intended functionality.
  • Exercise free speech ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  • Comply with a legal obligation, such as retaining records for a period of time as set out in local, state, or federal laws.
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided your information.

Following a deletion request, any personal information about you that was not deleted from our systems will only be used for the purposes provided for by the applicable exceptions. Thus, all personal information about you that is not subject to a deletion exception will either be (1) permanently deleted on our existing systems (with the exception of archived or back-up systems maintained for emergency disaster recovery and business continuity purposes); (2) de-identified; or (3) aggregated so as to not be personal to you.

  • Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you for exercising any of your privacy rights. Unless in compliance with applicable law, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • 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 California Privacy Rights

If you are an eligible California resident, to exercise your CCPA rights described above, please submit a verifiable consumer request to us by either:

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may, however, make a verifiable consumer request on behalf of your minor child if necessary. Additionally, you may only make a verifiable consumer request for access twice within a 12-month period. 

Your verifiable consumer request must: (i) provide sufficient proof of your identity; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

  • Response Timing and Format

If you are an eligible California resident, we will make our best effort to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Within ten (10) days of receiving the request, we will confirm receipt and provide information about its verification and processing of the request. The Company will maintain records of consumer requests made pursuant to the CCPA as well as our response to said requests for a period of at least twenty-four (24) months.

If you have an account with us, we may require you to take delivery of our written response through that account. If you do not have an account with us, we will deliver our written response electronically, though you may alternatively choose to receive delivery by mail. The response will also explain the reasons we cannot comply with a request, if applicable.  For requests for specific pieces of information that we have collected about you will be sent in a portable, readily usable format that you may transmit to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

Date: September 1, 2020

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us