Last Updated: May 25, 2018

Willett Advisors LLC and its affiliates, as applicable (“Willett” or “we”) respect the privacy rights of our users and are strongly committed to protecting your privacy. This Privacy Policy applies to personal information collected through this web site (“this Site”) and other Willett web sites and products or services as expressly indicated by Willett, including by providing a link to this Privacy Policy or otherwise displaying these terms. This Privacy Policy does not apply to any other web sites, products, or services of Willett, unless otherwise expressly indicated by Willett.

Personal Information We Collect

Willett, or where relevant a designated service provider, collects personal information through this Site, such as during registration, when you request certain services or products, or submit information, which may include your name, phone number, email address, etc. If you do not provide certain personal information, not all functionality on this Site will be available.

Do not provide information about others unless you are authorized to do so and consent to have all information used, disclosed, and transferred in accordance with this Privacy Policy. By submitting the information about others, you represent and warrant that you are authorized to do so and that you have received authorization from the person about whom you are providing the information and that person has consented to have all information used, disclosed, and transferred in accordance with this Privacy Policy.

Willett or a designated service provider may use “cookies,” web server logs, web beacons, or other electronic tools to collect information about you, such as your IP address, browser type, language, operating system, computer platform, and the state or country from which you accessed this Site. Willett or a designated service provider may also use cookies, web server logs, web beacons, or other electronic tools to collect and compile statistical and other information about your use of this Site and other websites and the services provided on this Site, such as the web pages visited, the date and the time of your visit, the web sites you visited immediately before and after visiting this Site, the number of links you click within this Site, the functions you use on this Site, the databases you view and the searches you request on this Site, the data you save on or download from this Site, etc. To opt-out of Google Analytics, please click https://tools.google.com/dlpage/gaoptout.

A cookie is a small text file placed on your computer. Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. The help function on most browsers contains instructions on how to set your browser to notify you before accepting cookies or to disable cookies entirely. However, note that this Site will not function properly if you disable cookies.

How We Use and Disclose Your Personal Information

Willett uses this information for carefully considered business purposes which also benefit our customers and which include some or all of the following:

You may instruct Willett at any time not to use your personal information collected in connection with the product you requested to provide you with offers and promotions by contacting us at legal@willettadvisors.com. Please also note that these processes may take some time to complete, consistent with applicable law. Please note that if you exercise choice in this manner, you will continue to receive communications concerning your account and products and services you requested, and in response to any requests for information by you.

To assist us with the uses described in this Privacy Policy, information we or our designated service providers have collected about you through this Site, including your use of this Site, may be aggregated, analyzed or enhanced with personal or other information about you that we have from other sources.

Willett may disclose your personal information to our affiliates (including affiliated websites and other products under common ownership or control) and our service providers, including for the purposes set out in this Privacy Policy, and to the party who authorized your use of this Site, such as your employer. Willett may disclose to other third parties, including other users of this Site, information about your use of this Site and on this Site or other websites, but only in an aggregated and unattributed manner. Willett may also share your personal information collected in connection with the product you requested with a sponsor or other third party (“Third-Party Providers”) that provides you with offers or promotions that may be of interest to you. You may instruct Willett at any time not to share your personal information collected in connection with the product you requested with such Third Party Providers by contacting us legal@willettadvisors.com. Please note that (i) this process may take some time to complete, consistent with applicable law; and (ii) even after such process is completed, your personal information may continue to be shared with our affiliates (including affiliated websites and other products under common ownership or control) and designated service providers.

Willett may also disclose your personal information to unaffiliated third parties if we believe in good faith that such disclosure is necessary to: (a) to comply with the law or in response to a subpoena, court order, government request, or other legal process; (b) to produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings; (c) protect the interests, rights, safety, or property of Willett or others; (d) monitor compliance with and enforce any terms of service on this Site; (e) to provide our services and products (including allowing a purchaser of Willett to continue to serve you); (f) perform other activities related to such services and products, including billing and collection; (g) provide you with offers or promotions from Willett; or (h) operate the systems that provide our services and products properly.

The collection, further use, and/or disclosure of your information by Third-party Providers or by other third parties is not the responsibility of Willett. Rather, such collection, use, and/or disclosure is governed by the third parties’ privacy policies.

Accuracy, Security, and Retention of Your Personal Information

Any of your personal information collected by Willett through this Site is kept on secure servers. Willett uses security measures appropriate to the provision of the relevant product or service, such as reasonable administrative, technical, personnel, and physical measures to protect your personal information on such servers. To help us protect your privacy, you should maintain the secrecy of any username and password you set up in connection with your participation in this Site’s service, if any. Personal information is retained for as long as is necessary for the purpose for which it is collected, including legitimate business reasons, and/or legal and regulatory requirements.

Rights with respect to Your Personal Information

Depending on the jurisdiction, you may have the right to access, correct, delete, or restrict use of certain personal information covered by this Privacy Policy. Depending on the jurisdiction, you may also have the right to request that we refrain from processing personal information. Please bear in mind that if you make such a request this may affect our ability to provide our products and services. For inquiries about your personal information, please contact us at legal@willettadvisors.com. All requests must include the following information: first name, last name, e-mail address, and “Privacy” in the Subject line. While Willett will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests, if allowed or required by applicable laws. Please note that it may take some time to process your request, consistent with applicable law.

Transfer of Your Personal Information To Other Countries

Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer and processing of your personal information to and in various countries that may have different levels of privacy protection than your country. By using our products and services, you consent to such transfers and processing, including to and in the United States.

Links to Third-Party Web Sites

Willett may provide links to third-party web sites. Since we do not control third-party sites and are not responsible for any information you may provide while on such sites, we encourage you to read the privacy policies on those web sites before providing any of your information on such sites.

Questions Regarding This Privacy Policy

If you have questions regarding this Privacy Policy, please contact us at legal@willettadvisors.com and include the name of the relevant web site or product in the Subject line of your inquiry. If you have complaints about Willett’s processing of your personal information, you may have the right to contact the applicable supervisory authority.

Modifications to This Privacy Policy

Willett reserves the right to change this Privacy Policy at any time by posting revisions on this web page.

Such changes will be effective upon posting.

Privacy Policy