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Privacy Policy

ATTENTION: PLEASE READ THIS CHARTWELL WEBSITE PRIVACY POLICY (“PRIVACY POLICY”) CAREFULLY. THIS PRIVACY POLICY PERTAINS TO YOUR ACCESSING, DOWNLOADING, OR USING THE https://www.chartwellfa.com WEBSITE (THE “WEBSITE”), AND YOUR ACCESSING ANY ASSOCIATED CONTENT, INCLUDING ALL CONTENT AVAILABLE THROUGH THE WEBSITE. IF YOU HAVE RIGHTS AS A RESIDENT OF NEVADA, PLEASE SEE THE YOUR NEVADA PRIVACY RIGHTS SECTION BELOW. IF YOU HAVE RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT, PLEASE SEE THE CCPA SUPPLEMENT BELOW.

The Website is operated by Chartwell Financial Advisory, Inc., 150 South Fifth Street, Suite 2700, Minneapolis, MN 55402, for itself and on behalf of CCS Transactions, LLC (“Chartwell”, “We” or “Us”). This Privacy Policy describes the information collected through your (“Your”) use of the Website, how We use it, how We share it, how We protect it, and the choices You can make about Your information.

This Website and content available within is for informational purposes only. Neither the Website nor the content available within constitutes legal, financial, accounting, or other professional advice, and neither should be relied upon by You or any third party, including to operate or promote Your business, secure financing or capital in any form, obtain any regulatory or governmental approvals, or otherwise be used in connection with procuring services or other benefits from any entity. Chartwell assumes no liability for readers’ use of the information herein and please note, before making any decision or taking any action, You should consult with legal and professional advisers.

Chartwell hereby authorizes You to display on your computer, download, and print pages of this Website, subject to the following provisions: (i) the copyright notice appears on all such printouts; (ii) the information will not be altered in any manner; and (iii) the content is only to be used for personal educational and non-commercial use and will not be redistributed, broadcast, or copied to any other media.

ACCESSING OR USING THE WEBSITE INDICATES THAT YOU ACCEPT AND AGREE TO BE BOUND BY THIS PRIVACY POLICY IN FULL. IF YOU DO NOT ACCEPT THIS PRIVACY POLICY, DO NOT ACCESS OR USE THE WEBSITE. You acknowledge (a) that You have read and understood this Privacy Policy; (b) that this Privacy Policy shall have the same force and effect as a signed agreement; and (c) that by agreeing to this Privacy Policy, You consent to receive notifications regarding security incidents to the email address We have on file for You.

Unless explicitly stated otherwise, any new features that augment or enhance the current Website shall be subject to this Privacy Policy. Please review the Privacy Policy each time You use the Website. BY USING THE WEBSITE, YOU AGREE TO BE BOUND BY THE MOST RECENT VERSION OF THE PRIVACY POLICY.

We value Your privacy and are committed to complying with the applicable data privacy and security requirements in the states in which We operate. This Privacy Policy applies to our collection and use of Your personal data when You visit Our website, when You apply for employment with Us, or when We provide financial advisory, corporate finance, transaction opinion, and valuation services.

Data Collection

Chartwell collects the following categories of personal data:

  • Contact data and other identifiers: We may collect information about data subjects such as name and contact details (email, phone number, mailing address) in order to communicate and facilitate the provision of our services with our clients or potential clients and to respond to Your requests.
  • Services data: Personal data may be provided to Us by clients to the extent required to perform the services. Chartwell may also acquire personal data from a third party at the direction of our client as required to perform services.
  • Employment Information: We collect the information You choose to disclose if You apply for potential employment with Chartwell, such as Your educational history, professional experience, and certain sensitive information such as citizenship or any disabilities You may have.
  • Website visitor information and statistical analysis: When You visit Our website, our third-parity analytics providers may collect information about Your visit such as Your IP address and the pages You visited. When You use Our services We may collect information on how You use those services. We may use cookies to collect this information. We use Google Analytics to help Us gather statistical information about the visitors to Our website and how they use the website on an anonymous, aggregate basis. We will not associate this data with Your personally identifiable data unless required to do so to cooperate with law enforcement activity or other governmental request or to comply with law. Depending on the type of browser and device that You use, You may have the ability to control the type of information that Google Analytics uses. 
  • Marketing information: We may collect information to respond to inquiries regarding Our services or to provide You with information, reports, or updates. This information includes the contact data and website visitor information described above as well as information about Your occupation or employer if You provide it to us.

How we Use Your Information

We use the information that We collect for several purposes, including:

  • The purposes for which it was provided;
  • To provide information and respond to requests for services;
  • To process and respond to customer inquiries and comments;
  • To send periodic emails. If email recipients choose, the email address they provide may be used to send them occasional news, updates, related product or service information, etc. Note: If at any time email recipients would like to unsubscribe from receiving future commercial emails, We include unsubscribe instructions at the bottom of each email; 
  • To generate and review reports and data about our user base and Website usage patterns;
  • To analyze the accuracy, effectiveness, usability, or popularity of the Website;
  • To compile aggregate data for internal and external business purposes;
  • To prevent fraud and abuse of the Website and to otherwise protect You and our business;
  • To assist law enforcement and respond to subpoenas; and
  • To perform other business activities as needed, or as described elsewhere in this Privacy Policy.
  • As explained elsewhere in this Privacy Policy, personal information We collect may be processed by our partners in providing services related to the Website (such as administration services, technical services relating to the maintenance, servicing, and upgrading of software, hosting services, customer service, data migration services, and analytical services, among others). 

How Information is Disclosed

Information may be disclosed to third parties in accordance with our Privacy Policy. Please note that a user may choose not to share certain information as described in the Analytics section below.

Third-Party Service Providers and Business Partners. We may use third-party service providers and business partners to perform functions in connection with the Website, such as social sharing, marketing, site analytics, relationship management, functions related to analyzing and improving the Website usefulness, reliability, user experience, and operation, storing data, and as otherwise described in this Privacy Policy.

Customer Relations Management Platforms. We may share Your information with third-party service providers and business partners to perform functions in connection with customer relations.

Social Media Platforms. If you decide to access social media platforms through buttons on the Website, We may be deemed in essence to share your information with social media platforms, including information related to Your IP address, browser, operating system, cookie information, device, the websites and webpages You visit, the purchases You make, the ads You view, and how You use the Website. 

Video Hosting and Sharing Platforms. By using third-party service providers and business partners who in turn may access some of Your information when you visit the Website, We may in effect be deemed to share Your information with third-party service providers and business partners in order for them to perform functions in connection with video hosting and sharing, including Your name, email address, address, title, industry, IP address, user ID, device ID, browser and device information, time of visit, pages visited, geolocation, queries searched, ads viewed, videos watched, and user names.

Business Changes. If We become involved in a merger, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction, or if the ownership of all or substantially all of our business otherwise changes, We may transfer Your information to a third party or parties in connection therewith. 

Affiliates. We may also share Your information with our affiliates for purposes consistent with this Privacy Policy. Our affiliates will be required to maintain that information in accordance with this Privacy Policy.

Investigations and Law. We may disclose information about You to third parties if We believe that such disclosure is necessary to:

  • Comply with the law or guidance or cooperate with government or law enforcement officials or private parties;
  • Investigate, prevent, or take action regarding suspected illegal activities, suspected fraud, the rights, reputation, safety, and property of us, users, or others, or violations of our policies or other agreements with us;
  • Respond to claims and legal process (for example, subpoenas); and/or 
  • Protect against legal liability.

Aggregated Information. We may share aggregated information relating to users of the Website with affiliated or unaffiliated third parties. This aggregated information does not contain personal information about any user.

Analytics. We use third-party analytics tools to better understand who is using the Website and how people are using it. These tools may use cookies and other technologies to collect information about Your use of the Website and Your preferences and activities. These tools collect information sent by Your device or the Website and other information that our third-party analytic vendors may use to assist us in improving the Website, such as Website pages visited, places where users click, time spent on each Website page, Internet Protocol address, type of operating system used, language preference, location-based data, device ID, search traffic, gender, and age. This information may be used to analyze and track data, determine the popularity of certain content, and better understand Your online activity. Our analytics providers may track Your activity over time and across websites.

Security

We implement a variety of security measures to protect the safety of Your personal information when You enter, submit, or access Your personal information. 

While We take reasonable measures to protect the information You submit via the Website against loss, theft, and unauthorized use, disclosure, or modification, We cannot guarantee its absolute security. No Internet, email, or mobile application transmission is ever fully secure or error free. Email or other messages sent through the Website may not be secure. You should use caution whenever submitting information through the Website and take special care in deciding with which information You provide us.

We cannot guarantee that transmissions of Your personal information will be fully secure and that third parties will never be able to defeat our security measures or the security measures of our partners. WE ASSUME NO LIABILITY FOR DISCLOSURE OF YOUR INFORMATION DUE TO TRANSMISSION ERRORS, THIRD-PARTY ACCESS, OR CAUSES BEYOND OUR CONTROL.

If you use our Website outside of the United States, You consent to having Your data transferred to the United States. 

Data Retention Policy, Managing Your Information

We will retain Your information for as long as You use the Website and for a reasonable time thereafter. We may maintain anonymized or aggregated data, including usage data, for analytics purposes. We may retain and use Your information as necessary to comply with our legal obligations, resolve disputes, and/or for the period required by laws in applicable jurisdictions. Please note that some or all of the information We have collected may be required for the Website to function properly.

Links to Other Services or Applications

This Privacy Policy applies only to the Website. The Website may contain links to other websites or apps or may forward users to other websites or apps that We may not own or operate and to which this Privacy Policy does not apply. The links from the Website do not imply that We endorse or have reviewed these websites or apps. The policies and procedures We describe here do not apply to these websites or apps. We neither can control nor are responsible for the privacy practices or content of these websites or apps. We suggest contacting these websites or app providers directly for information on their privacy policies. Nonetheless, We seek to protect the integrity of our Website and welcome any feedback about these linked websites and mobile applications.

Your Choices Regarding Your Information

You have choices regarding the use of information by the Website.

  • Changing Your Information – To change Your information, You may contact us at www.chartwellfa.com/contact. 
  • Closing Your Account – You may close Your account by contacting us at www.chartwellfa.com/contact. If the email account associated with Your email address is not active, We may close Your account without notice.

Children

Our Website is not intended for children under 18 years of age. We do not knowingly collect personal information from an individual under age 18. If You are under the age of 18, please do not submit any personal information through the Website. If You have reason to believe that We may have accidentally received personal information from an individual under age 18, please contact us immediately at www.chartwellfa.com/contact. 

Changes to Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this Privacy Policy periodically, and especially before You provide any information. This Privacy Policy was made effective on the date indicated above. 

Business Continuity Disclosure

CCS maintains a business continuity plan, which addresses interruptions to our normal course of business. This plan is reviewed annually and updated, as necessary. Our disclosure statement is available in written form upon request.

The plan outlines the actions CCS will take in the event of a single-building, citywide or regional business interruption, including the use of an office location not affected by the interruption, retrieval of off-site back up data, use of primary and alternate vendors for continued communication, notification of active clients to provide interim information and relocation of personnel to an unaffected site.

USA Patriot Act Identity Verification Notice

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who, or entity that, establishes an account. While there are exceptions to this requirement, We will ask for certain investor information such as legal name, legal address and/or principal place of business, state of incorporation, Taxpayer Identification number, Social Security number, date of birth, etc. that will allow Us to demonstrate compliance with these regulations. In some cases, We may also ask for additional documents.

Securities Investor Protection Corporation (SIPC) Disclosure

Although CCS does not maintain customer accounts or accept customer funds or securities, We are a member of SIPC. To obtain more information about SIPC, including a SIPC brochure, You may contact SIPC directly by telephone at 201-371-8300 or refer to www.sipc.org. 

How to Contact Us

Please feel free to contact us at www.chartwellfa.com/contact if You have any questions about this Privacy Policy.

Your Nevada Privacy Rights 

The Nevada Revised Statutes (NRS 603A.300 et seq.) permit a Nevada consumer to direct an operator of an Internet website or online service to refrain from making any sale of any covered information the operator has collected or will collect about that consumer. As noted below in Our California Supplement, We do not “sell” any consumer information in the traditional sense of the definition of “sell”. Nevertheless, in order to remove all doubt, You may submit a request pursuant to this directive by contacting us at data.privacy@chartwellfa.com. We will provide further information about how We verify the authenticity of the request and Your identity.

Supplement for California Residents – Last Updated June 2021

California residents have the following additional rights. You will not need to create an account to exercise Your rights. To exercise one of these rights, please provide a verifiable consumer request by contacting us at data.privacy@chartwellfa.com. While We do not collect personal information, and thus do not “sell” Your personal information in the traditional and common understanding of selling or providing information in exchange for monetary compensation, California has defined ‘sell’ much more broadly to mean sharing Your information to any third party under circumstances where We may derive some benefit. Accordingly, in order to remove all doubt, the following incorporate this much broader definition of the word “sell.”

  • If it is determined that We may have in fact collected such information about You, request that We delete such personal information.
  • If it is determined that We may have in fact collected such information about You in the preceding 12 months, request that We disclose, free of charge (unless Your requests are manifestly unfounded or excessive), the categories of personal information that We have collected about You, the categories of sources from which the personal information was collected, the business or commercial purpose for collecting or selling personal information, the categories of third parties with whom We share personal information, and the specific pieces of personal information We have collected about You. 
  • If it is determined that We may have in fact collected such information about You, request that, for personal information that it is determined that We have sold or disclosed such information for a business purpose in the preceding 12 months, We disclose, free of charge (unless Your requests are manifestly unfounded or excessive), the categories of personal information that We have collected about You, the categories of personal information that We have sold about You, the categories of third parties to whom each category of personal information was sold, the categories of personal information that We have disclosed about You for a business purpose, and the categories of third parties to whom each category of personal information was disclosed. 
  • If it is determined that We may have in fact collected such information about You, Direct us, at any time, not to sell Your personal information. We may sell Your personal information within the meaning of the California Consumer Privacy Act of 2018 (“CCPA”). Under the CCPA, “sell” means sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration. The law contains exceptions to this definition which may limit how We respond to your direction. To exercise this right to opt out, You may contact us at data.privacy@chartwellfa.com.

Before We can fulfill the requests to know and delete noted above, We must verify Your identity. We will require You to provide us with Your name, telephone number, home address, and email address, together with a signed declaration under penalty of perjury that You are the consumer whose personal information is the subject of the request. We will match this information to the personal information We maintain.

You can also authorize another person, called an agent, to exercise Your rights on Your behalf. You must provide the authorized agent written and signed permission to act on Your behalf. We may deny requests to opt out from an authorized agent who does not submit proof that he or she has been authorized to act on Your behalf. Furthermore, We may require You to verify Your identity directly with us. We may also require You to directly confirm with us that You have provided the authorized agent permission to submit a request on Your behalf. An authorized agent can make a request on Your behalf by contacting us at data.privacy@chartwellfa.com.

We may not discriminate against You because You exercised any of Your rights under the CCPA, including, but not limited to, by:

(A) Denying goods or services to You.

(B) Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.

(C) Providing a different level or quality of goods or services to You.

(D) Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

Information Notice

This notice, in summary form, is intended to inform You who has access to the above mentioned information once We receive it. Chartwell considers all information We have about You to be confidential and pursuant to any existing or potential business relationship with you, including the fact that You may be a client of Chartwell Financial Advisory, Inc. and/or CCS Transactions, LLC. We restrict access to information about you to those employees who need to know that information in order to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with applicable regulatory standards to maintain the confidentiality of your information.

Last modified: 7/8/21

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