Privacy Policy

Last Updated: [09/02/2020]

When you visit our investment blog (the “Blog”) and website (the “Site” or “Website”), you trust the author (“we,” “us,” or “our”) with your personal information. We take your privacy very seriously. In this Privacy Policy, we seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. We hope you take the time to read through it carefully, as it is important. By using the Site, you are agreeing to the collection and use of information in the manner described in this Privacy Policy. If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Site. 

We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regard to your personal information, please contact us at info@ritholtzwealth.com.

Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your personal information with us.

  • WHAT INFORMATION DO WE COLLECT?
  • HOW DO WE USE YOUR INFORMATION?
  • WILL YOUR INFORMATION BE SHARED WITH ANYONE?
  • WHO WILL YOUR INFORMATION BE SHARED WITH?
  • DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  • WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
  • HOW LONG DO WE KEEP YOUR INFORMATION?
  • HOW IS YOUR INFORMATION STORED?
  • DO WE COLLECT INFORMATION FROM CHILDREN?
  • WHAT ARE YOUR PRIVACY RIGHTS?
  • CONTROLS FOR DO-NOT-TRACK FEATURES
  • DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  • DO WE MAKE UPDATES TO THIS POLICY?
  • HOW CAN YOU CONTACT US ABOUT THIS POLICY?
  • HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU

WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you voluntarily provide to us.

We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about the Blog, us, or otherwise contacting us. If you communicate with us by email, post messages to any of our chat groups, bulletin boards, or forums, or otherwise complete online forms, surveys, or contest entries, any personal information provided in such communication may be collected as personal information.

The personal information we may require you to provide to us in order for you to access certain services or use certain Site functionality include the following: (1) Contact Information (such as your name, mailing address, and email address); (2) Financial Information (such as your credit card information); and (3) Demographic Information (such as your zip code, age, and income). Contact Information, Financial Information, and Demographic Information shall be referred to as Personal Information. 

We do not collect any Personal Information about you unless you voluntarily provide it to us. You are under no obligation to provide us with Personal Information of any kind, however your refusal to do so may prevent you from using certain features of the Site. 

Information automatically collected

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Site.

We automatically collect certain anonymous information when you visit, use, or navigate the Site. This information does not reveal your specific identity (like your name or mailing address), but may include device and usage information, such as the following: IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, information about how and when you use our Site, and other technical information (collectively, “Traffic Information”). This information is primarily needed to maintain the security and operation of the Site, and for our internal analytics and reporting purposes. We also use Traffic Data for marketing purposes or for improving your experience on the Site.

Like many businesses, we, through our third-party advertisers, also collect information through cookies and similar technologies to customize content specific to your interest. Please see the section titled “WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?” for more information.

HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent. 

We use your information for a variety of business purposes described below. We process your information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below. 

We use information we collect or receive from you:

  • To send you newsletters, marketing, and promotional communications. We and/or our third-party marketing partners may use the Personal Information you send to us for marketing purposes if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time as discussed further below. 
  • Deliver targeted advertising to you. We may use your Personal and Traffic Information through our third-party advertisers to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. Please see the section titled “WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?” for more information.
  • To protect our Site. We may use your Personal and Traffic Information as part of our efforts to keep our Site safe and secure (for example, for fraud monitoring and prevention).
  • To enforce our terms, conditions and policies. We may use your Personal and Traffic Information in order to enforce our terms, conditions, and policies as needed.
  • To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the Personal and Traffic Information we hold to determine how to respond.
  • Processing payment. We only collect but will not use your Financial Information for any purpose. Our third-party business partner(s) will use your Financial Information to process payment.
  • For other business purposes. We may use your Personal and Traffic Information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Site, Blog, marketing, and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information for other business purposes without your consent.

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your information based on the following legal basis:

  • Consent: We may process your Personal Information if you have given us specific consent to use such information for a specific purpose.
  • Legitimate Interests: We may process your Personal Information when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of a Contract: Where we have entered into a contract with you, we may process your Personal Information to fulfill the terms of our contract.
  • Legal Obligations: We may disclose your Personal Information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests: We may disclose your Personal Information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situation involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

WHO WILL YOUR INFORMATION BE SHARED WITH?

In Short: We only share information with the following third parties.

We only share and disclose your information with the following categories of third parties. We have categorized each party so that you may easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.

  • Vendors, Consultants, and Other Third-Party Services Providers. We may share your Personal Information with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include sharing Contact Data with business partners who assist with data analysis, data storage and security, email delivery, hosting services, customer service and marketing efforts; sharing Demographic Data with third parties who assist us with advertising; and sharing Financial Data with business partners who assist with payment processing and billing. We may allow selected third parties to use tracking technology on the Site, which will enable them to collect data about how you interact with the Site over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand online activity. Unless described in this Privacy Policy, we do not share, sell, rent, or trade any of your information with third parts for their promotional purposes.
  • Business Transfers. We may share or transfer your Personal Information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Site. These companies may use information about your visits to our Site and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you. Please see the section titled “WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?” for more information.
  • Affiliates. We may share information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

More specifically, we currently only share and disclose your Personal and Tracking Information to the following third parties:

  • Communicate and Chat with Users: MailChimp
  • Content Optimization: MailChimp widget plugin
  • Web and Mobile Analytics: Google Analytics and Quantcast Measure
  • Hosting: Flywheel
  • Advertising: AdThrive

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) through third-party advertisers to access or store information. Please see the section title “WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?” for more information.

WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our Site.

Except as otherwise discussed in this Privacy Policy, this Privacy Policy only addresses the use and disclosure of information we collect from you. Other sites accessible through our site have their own privacy policies and data collection, use and disclosure practices. Please consult each site’s privacy policy. We are not responsible for the policies or practices of third parties. 

Additionally, other third-party companies which place advertising on our site may collect information about you when you view or click on their advertising through the use of their cookies or other tracking technologies, which may include delivering targeted advertisements and marketing messages based upon the third party websites that you visit, or other purposes. We cannot control this collection of information and are not responsible for the privacy policies and data collection, use and disclosure practices of these third-party advertisers. You should contact these third-party advertisers directly if you have any questions about their use of the information that they collect from you. 

Also, if you would like more information about this practice and to know your choices about not having this information used by these companies, please see: http://www.networkadvertising.org/consumer/opt_out.asp

ADVERTISING PRIVACY STATEMENT

This Site is affiliated with AdThrive, LLC (“AdThrive”) for the purposes of placing advertising on the Site.  AdThrive uses standard and widely-available tools for the placement and serving of ads, including those provided by Google, Inc. and its affiliates. We publish interest-based advertisements on the Site; that is, ads that are tailored to reflect your interests. To help understand your interests, AdThrive, Google and our other advertising partners will track your behavior on our website and on other websites across the Internet using cookies.

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.  Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

By using this Site, you consent to the use of such cookies and the sharing of data captured by such cookies with AdThrive, Google, and our other third party partners. You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the network cookie using those settings or using the Network Advertising Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained.

This Site is affiliated with CMI Marketing, Inc., d/b/a CafeMedia (“CafeMedia”) for the purposes of placing advertising on the Site, and CafeMedia will collect and use certain data for advertising purposes. To learn more about CafeMedia’s data usage, click here: www.cafemedia.com/publisher-advertising-privacy-policy

For European Economic Area Residents

If you reside in a country in the European Economic Area (EEA), then under the GDPR and applicable data protection laws you have the rights, among other things, to access your personal data, have us erase it, and/or restrict its further processing.  If you wish to access or delete your personal data (if any) maintained by us or AdThrive related to advertising on the Site, you can contact us at awealthofcommonsense@gmail.com and contact AdThrive at info@adthrive.com. If you wish to see a list of the advertising partners we work with or change which of those partners track your behavior using cookies, click the ad preferences link at the bottom of the site. (Available in the EU.)

For California Residents

California law gives residents the right to opt out of the “sale” of their personal information to third parties, including for advertising purposes. Under California law, the sharing of your information with a service provider for advertising purposes could be considered a “sale.” To opt out of the sharing of your information for advertising information, click the opt out link provided in the footer of this page. You also have the right to request from us the categories of personal information that we have shared and the categories of third parties to whom the information was provided. To make such a request, please contact us at info@adthrive.com. To be clear we do not share your name, contact information, or any other sensitive information with third parties, and the categories of third parties that we share information with for advertising purposes are supply side platforms, programmatic advertising exchanges, and demand side platforms.

HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law or unless you request that we delete your information.

We will only keep your Personal Information for as long as it is necessary for the purposes set forth in this privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your Personal Information for longer than one (1) year.

When you provide us with your Financial Information, it will immediately be transferred to and stored with our third-party payment processing party. We will not retain any of your Financial Information in our database. 

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

HOW IS YOUR INFORMATION STORED?

In Short: On secure servers. 

We will store your Personal Information on secure servers, and will take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your Personal Information. 

DO WE COLLECT INFORMATION FROM CHILDREN?

In Short: We do not knowingly collect Personal Information from children under the age of 13.

In compliance with Children’s Online Privacy Protection Act (“COPPA”), this Site is not directed at children under the age of 13 and we do not intend to collect any personally identifiable information, such as name, home address, e-mail address, telephone number, or social security number, from children under the age of 13. If you are under the age of 13, please do not provide us with your personal identifiable information. If you have any reason to believe that a child under the age of 13 has provided us with his or her personally identifiable information, please contact us immediately for removal of that information from our databases.

WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time. You may have additional rights if you are an EU resident. You may also adjust your browser settings to remove or reject cookies.

If you are a resident in the European Economic area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisor authority. You can find their contact details here: https://edpb.europa.eu/about-edpb/board/members_en

Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Site. To-opt-out of interest-based advertising by advertisers on our Site visit http://www.aboutads.info/choices/. 

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preferences not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about the practice in a revised version of this Privacy Policy.

DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared Personal Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Site, you have the right to request removal of unwanted data that you publicly post on the Site. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Site, but please be aware that the data may not be completely or comprehensively removed from our systems.

DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Last Updated” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this Privacy Policy, you may email us at the info@ritholtzwealth.com or by post at 24 West 40th Street, 15th Floor, New York, NY 10018.

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the laws of some countries, you may have the right to request access to the Personal Information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by emailing info@ritholtzwealth.com. We will respond to your request within 30 days.