We value your privacy and your desire to know how we handle and use your information. Therefore, we provide this Privacy Statement, which explains our information practices. This statement applies to personal information we obtain from and about individuals interacting with Lombard Letter its website(s), and products and services.
The purpose of this Privacy Statement is to explain the types of information we collect, how it is obtained, how it is used, how it may be shared with others, and your choices about its use and disclosure.
The types of information we collect from and about you include:
Contact and demographic information collected online and offline (such as your name, telephone number, and email)
Data gathered by technology when you visit our Site (such as cookies)
Marketing data from third parties that includes contact information
Any information you publicly post on our Site forums or comment sections
Click To Optin Subscriptions
One of the ways that subscribers join our email newsletter database is through ‘Click To Optin’ technology. All of the methods subscribers can subscribe to our newsletters are US CAN SPAM compliant. These methods allow subscribers to subscribe to newsletters they find interesting quickly and easily. Opting out from our publications is easy and fast. Simply click on the unsubscribe link in the footer of any email and follow the steps to unsubscribe.
The Click To Optin process operates as follows. A person sees a report, newsletter or publication they are interested in receiving and choose to subscribe to such publication to receive the deliverable by email. When they click the ‘Click To Optin’ link within the email they received promoting the offer for the deliverable they are interested in, the subscription to the chosen publication is at that point complete and their email address and IP address are automatically transferred to our email platform and/or advertising tracking technology. Click To Optin may utilize Bonus Addon Publications as described below.
We may also make available to advertisers ‘Click To Optin’ advertisements that would allow them to generate subscribers to their newsletters using the same ‘Click To Optin’ process described above.
Bonus Addon Publications
The subscriber may also be subscribed to up to two (2) additional internal or external advertiser newsletters, as per the disclosure in the email advertisement or optin page. This process is called Bonus Addon Publications. From that point on, the subscriber will continue to receive emails from the publication he subscribed to as well as email communications from up to two (2) additional publications. If the subscriber wishes to unsubscribe from any of the publications to which they are subscribed (including the Bonus Addon Publications), they can just open a recent email and click on the unsubscribe link the footer of such message. They will then be removed from the corresponding email list or publication.
We regularly send content via email newsletters we believe is valuable to the subscriber, including 3rd party paid advertisements.
If at any point the subscriber wishes to unsubscribe from any of our publications or Bonus Addon Publications, they can simply click on the unsubscribe link in the footer of any such email and follow the steps to unsubscribe.
How We Gather Information from Users and Our Use of Such Information
How we collect and store information including email address depends on the page you are visiting, the activities in which you elect to participate and the services provided. The following describes the types of personal and other information we may collect about you, and how we use and maintain that information:
Click to Opt In (One click subscription) and Traditional Opt In Pages:
One way that we generate subscribers to its database is via a method called “Click To Opt In”. All email subscription, lead generation methodologies conform to U.S. CANSPAM law and allows people to subscribe to newsletters they find interesting, quickly and easily.
The Click To Opt In process is as follows: A person sees a report or newsletter in which they are interested in receiving and must first subscribe to the relevant publication of ours in order to receive the deliverable via email. When they click on the “Click to Opt In link” within the email they received promoting the offer for the deliverable, their subscription to the email publication is at that point complete and their email address and IP address are automatically transferred into our email platform as well as into our advertising tracking technology.
Standard Opt In Pages: we also utilize traditional opt in pages to generate leads. A traditional opt in page utilizes traditional opt in practices and will include a description of what the subscriber is opting in to receive.
We regularly sends content via email that should be perceived as valuable by the subscriber, including paid, 3rd party advertisements.
If at any point the subscriber would like to unsubscribe from the publication, any other brand within our network of sites and publications, they can simply click the unsubscribe link from a marketing email they receive from and follow the directions to manage their subscriptions.
When you unsubscribe from one of our publications, you should stop receiving emails from any of the brands from which you unsubscribed within 2-10 days.
Alternatively, you may also send physical mail to the mail address below. Please include your email address so that we can unsubscribe the email address from our list. This process will take up to 30 days after receiving your request.
We process your information for the following purposes:
To provide you with E-Newsletter information from our brands
To present to you via email, 3rd party advertisements
To track subscriber engagement of both E-Newsletters and 3rd party advertisements in order to optimize the content being distributed to our subscribers.
We will retain your personal information for as long as you remain subscribed to our publications
In general, you may visit our Website without revealing any individual user information. However, certain sections of our Website are only available to users who register or subscribe to our Website. We collect your contact information when you register for or subscribe to our Website or other services and features we provide, when you transmit information via our Website or by email, and when you otherwise use our Website. Specifically, we may collect and store in a database your name, mailing address, phone number, email address and any other information you provide to us when registering with our Website.
With Whom We Share Your Information
We may share your information during the following situations:
To identify your geography in order to comply with any laws, such as GDPR
In connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets
In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset
If another company acquires our company, business, or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Privacy Statement
Except as noted in this Privacy Statement (e.g., pursuant to an acquisition or merger) we will not sell your personal information to any third parties.
Our Website collects and stores information that is generated automatically as you navigate through the Website. This aggregate information is collected site-wide, and includes anonymous website statistics. This information is aggregated and may not personally identify you. It is collected to help us improve the Site and the services we offer. For example, we may use IP addresses to monitor Site usage to better prepare for anticipated traffic patterns. We may also gather user information that we save on your computer (not on our server) as cookies in order to streamline the Site experience.
Aggregated information may be used in many ways. For example, we may combine information about your usage patterns with similar information obtained from other users to help enhance our Website and services (e.g., to learn which pages are visited most or what features are most attractive).
When you browse our Website, our system automatically collects information such as your web request, Internet Protocol (IP) address, browser type, browser language, domain names, referring and exit pages and URLs, platform type, number of clicks, landing pages, pages viewed and the order of these page views, the amount of time spent on particular pages, the date and time of your request and one or more cookies that may uniquely identify your browser. This information is used to analyze trends, administer the Website, improve the design of our Website, track user movement, and otherwise enhance the services we provide.
We also use advertising providers that use targeting cookies and ads, to tailor information presented to you, and which link to services provided by third parties. Targeted advertising may collect personal information about users’ online activities over time and across different websites.
For more detailed information about cookies visit www.allaboutcookies.org.
Do Not Track
Some browsers have incorporated Do Not Track (DNT) preferences. Most of these features, when turned on, send signals to the website you are visiting that you do not wish to have information about your online searching and browsing activities collected and used. As there is not yet a common agreement about how to interpret DNT signals, we do not honor DNT signals from website browsers at this time. However, you may refuse or delete cookies as described above.
Affiliated Sites, Linked Sites and Advertisements
If you wish to subscribe to our E-newsletter(s), we will use your name and email or mailing address to send the newsletter to you. Out of respect for your privacy, we provide you a way to unsubscribe.
Regarding Citizens of the European Union (EU)
We do not target European Citizens in order to build their email subscription lists.
If you are a resident of a country within the European Union (EU), or a long term resident of the European Union you are expressly prohibited to subscribe to any of our brands.
By subscribing to one of our publications, via any method, be it through co-registration, opting in through any page on its website, click to opt in, or otherwise, the subscriber agrees that he or she is not a resident of the European Union.
By opting into one of our publications you are affirming that you are not a resident of a country within the European Union, and further affirming and consenting that If you relocate to the European Union at any point after opting into one of our publications, you agree to unsubscribe from all email lists within 24 hours of relocation.
While we do not target residents of the European Union, regular screening will occur within within our subscriber base to identify email addresses with IP addresses indicating they are located within the European Union. Email addresses believed to be associated with residents of the European Union will immediately be unsubscribed.
Choice and Opt-out
We provide you the opportunity to opt-out of having your personally identifiable information used for certain purposes.
If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication. You may also contact us via postal mail at the mail address below. This method will take up to 30 days after receiving the request via postal mail.
The personal information collected by ourselves is stored in secure operating environments that are not available to the general public. However, no data transmission over the Internet, electronic communication between parties, or networks and associated storage available over the Internet can be guaranteed to be 100% secure. Consequently, while we strive to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us.
If you have any questions about security on our Website, you can contact us at the contact information provided above.
We do not knowingly collect or solicit personally identifiable information from or about children under 18. If we discover we have received any information from a child under 18 in violation of this policy, we will delete that information immediately. If you believe we have any information from or about anyone under 18, please contact us at the address listed above.
California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of personally identifiable information to third parties for their direct marketing purposes in the preceding calendar year (e.g., requests made in 2017 will receive information about 2016 sharing activities). We comply with this law by giving users the ability to tell us not to share personally identifiable information with third parties for their direct marketing purposes. To make such a request you may contact us via postal mail at at the mail address below. This method will take up to 30 days after receiving the request via postal mail.
Please list California Privacy Rights within the letter along with a detail of what you are specifically requesting. We may need additional information to process your request.
If you have questions or concerns regarding this statement, you should first contact us via postal mail at Lombard Letter, 61 Bridge Street - Kington - HR5 3DJ, England, United Kingdom or by email on [email protected]
Changes to This Privacy Statement
We may update this Privacy Statement from time to time. In the event that we merge with, or are acquired by another company, a change to this Privacy Statement may result. Whenever a change to this Privacy Statement is significant, we will place a prominent notice on our Website.