This CTM Asset Management Online Privacy Notice (“Online Privacy Notice”) describes the personal information CTM Asset Management (“CTM,” “we,” “us,” or “our”) collects or receives from or about you when you visit www.ctmasset.com (“Website”) and the ways in which we use and share it. This Online Privacy Notice does not apply to information we collect from you offline such as when you submit an application or other form to us or one of our affiliates via mail or by telephone.
If you are a prospective, current or former client of CTM or an investor in a fund managed by us, some of the information we may collect from you online constitutes “non-public personal information.” Our collection, sharing and use of non-public personal information is governed by the privacy notice we deliver to you pursuant to federal law.
We collect information about you in various ways. Some of this information may be considered “personal information” under applicable law. The personal information that you provide and that we collect or receive from you depends on the context of your interaction with us and our Website, the choices you make when you use our Website, and the features that you use.
You may provide information to us directly. We collect and receive information from you directly when you contact us via the form on our Website. This information may include your name and contact details.
You may provide information to third parties who act on our behalf. We collect and receive information when you provide your information to our third party service providers and other partners who we engage to assist us in providing services to you. Such third parties may include website providers and entities that assist us in hosting our Website and managing our communications. The information collected by such entities may include your name, contact details, IP address and other online identifiers.
We collect information from you automatically through tracking technologies. When you visit our Website we collect certain information from you automatically. We may collect this information through cookies, pixels, web beacons, tags and scripts and other tracking technologies. We may combine this information with other information we collect about you on our Website or via other sources.
The information we collect automatically may include the following:
For more information regarding how we and third parties we engage may collect information from you automatically via cookies and other tracking technologies, please see Cookies and Online Tracking Technologies below.
We may use the information we collect from you in a variety of ways, including:
We may share the information that we collect pursuant to this Online Privacy Notice as follows:
In addition, please note that if CTM or any of its affiliates, subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of or dissolved, including through merger, consolidation, sale or divestiture of assets, the relevant customer database, including personal information we may possess about you, and information collected pursuant to this Online Privacy Notice, may, in whole or in part, be sold, disposed of, transferred, divested, or otherwise disclosed as part of that transaction or proceeding.
We and third-party partners we engage may use cookies (i.e., small text files that are stored on your browser, computer, or mobile device), web beacons, pixels, tags, browser analysis tools, server logs and other tracking technologies to automatically collect information, including personal information such as your IP address, from your browser.
Our Website uses both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use our Website.
Our Website uses cookies and other tracking technologies for a variety of purposes. For example, we, our service providers and other partners we engage use cookies and other tracking technologies:
Our website may use Google Analytics, a web analytics service offered by Google. You may learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy at https://www.google.com/policies/privacy/partners.
You can generally manage your cookie and tracking technology preferences through your web browser. For more information regarding how to manage your preferences, please consult the information made available by your particular browser or visit www.allaboutcookies.org.
With respect to Google Analytics, you can also view Google’s currently available opt-out options at https://tools.google.com/dlpage/gaoptout in an effort to opt-out of being tracked by Google Analytics.
Please note that if you choose not to accept cookies or other tracking technologies, you may be unable to use certain features of our Website.
Our Website contains links to third-party sites and services whose privacy practices may be different than ours. We may also allow you to connect with other third-party sites and services. We are not responsible for the privacy practices of third-party sites and services and you should consult the other third-party sites’ and services’ privacy notices in order to better understand their privacy practices.
We use a combination of safeguards designed to help prevent unauthorized access to your personal information and maintain data security. However, no system can be completely secure, and we do not guarantee that unauthorized disclosures and access will not happen. As such, we cannot assure you that your personal information or other information will never be disclosed in a manner that is inconsistent with this Online Privacy Notice.
Our Website is not intended for users under the age of 13, and we do not knowingly collect information from anyone under the age of 13. No one under the age of 13 is permitted to access or use this Website or provide us with personal information.
From time to time, we may update or revise this Online Privacy Notice. If there are changes to the terms of this Online Privacy Notice, documents containing the revised policy on the relevant website(s) will be updated.
If you have any questions or concerns about this Online Privacy Notice, please contact us at info@ctmasset.com.