Conning & Company, Conning, Inc., Goodwin Capital Advisers, Inc., Conning Investment Products, Inc., Conning Asset Management Limited, Conning Asia Pacific Limited, Conning (Germany) GmbH and Octagon Credit Investors, LLC are all direct or indirect subsidiaries of Conning Holdings Limited (each of which may be referred to individually or collectively as “Conning,” as applicable).  Conning Holdings Limited hosts Conning’s websites.  Conning respects the privacy rights of users (hereinafter “users” or “you”) of Conning websites and is committed to protecting your privacy online.  This Privacy and Social Media Policy (this “Privacy Policy”) applies to the websites owned and/or operated by Conning and certain authorized clients, licensees and other users and does not apply to other products or services of Conning.

READ THIS PRIVACY POLICY CAREFULLY BEFORE USING CONNING’S WEBSITES.  YOUR USE OF CONNING’S WEBSITES CONSTITUTES YOUR ACKNOWLEDGEMENT THAT YOU HAVE READ THIS PRIVACY POLICY, YOU EXPRESSLY AGREE WITH THIS PRIVACY POLICY AND EXCEPT AS PROHIBITED BY APPLICABLE LAW, YOU expressly consent to the collection, processing and/or other use of your personal information that you or CONNING may transmit over CONNING’S WEBSITES.  do not use CONNING’S websites If you do not agree WITH THIS PRIVACY POLICY.

CONNING reserves the right to change, MODIFY, ADD OR REMOVE PORTIONS OF this privacy POLICY without notice at any time FOR ANY REASON.  CONNING SUGGESTS THAT YOU REVIEW this privacy POLICY PERIODICALLY FOR CHANGES.  SUCH CHANGES SHALL BE EFFECTIVE IMMEDIATELY UPON POSTING.  YOU ACKNOWLEDGE AND EXPLICITLY AGREE THAT BY ACCESSING CONNING’S WEBSITES AFTER CONNING HAS POSTED CHANGES TO this privacy POLICY, YOU ARE AGREEING TO this privacy policy AS MODIFIED.

Collection and Use of Personal Information

Except as may be prohibited by applicable law, Conning and its third party vendors collect personal information that you voluntarily provide on Conning’s websites, which may include such information as your name, address, e-mail address, phone number, employer information, issues of interest, credit card number, billing information, etc.  Conning may also collect and store personal information that you have provided through other means. You are not required to provide the personal information requested, but if you choose not to do so, in many cases Conning will not be able to provide you with products or services or respond to any inquiries you may have.  For example, Conning collects personal information when you register to receive certain services or products, purchase products and/or services, or submit information to receive marketing or other promotional materials. Conning uses this information to communicate with you and to provide you with your requested service and/or product.  Conning may also provide you with information, special offers and promotions.

Conning Library Website Opt-Out Process.  If you provided your personal information for access to the Conning Library Website, you may instruct Conning at any time not to use your personal information to provide you with information, special offers or promotions distributed or offered by the Conning Library Website by e-mailing Conning at Questions@ConningResearch.com.  All requests must include the following information: first name, last name, and e-mail address.  Please note that this opt-out process may take up to thirty (30) days to complete and afterwards you will no longer remain an active user on the Conning Library Website.

Conning Software Documentation Website Opt-Out Process.  If you provided your personal information for access to the Conning Software Documentation Library Website, you may instruct Conning at any time not to use your personal information to provide you with information, special offers or promotions distributed or offered by the Conning Software Documentation Website by e-mailing Conning at risksolutions@conning.com.  All requests must include the following information: first name, last name, and e-mail address.  Please note that this opt-out process may take up to thirty (30) days to complete.

Opt-Out Process for other Conning Materials:  If you no longer want to receive materials that are distributed or sent to you by Conning through means other than the Conning Library Website or Conning Software Documentation Website, then please see the opt-out procedures described in those materials and follow the instructions for opting-out therein.

Please note that some Conning websites allow the use of credit cards to pay for services.  These credit card transactions are processed by a third party vendor and at no time does Conning have access to the personal information you submit for these credit card transactions, nor does Conning store any personal information related to these credit card transactions.

 

Accessing and Updating Your Personal Information

Conning Library Website Access and Updating Process. If you have provided personal information in the past in connection with the Conning Library Website, publications, products and/or services and would like to access and update this information, please send an e-mail to Questions@ConningResearch.com.  If you would like to render your Conning Library Website account inactive, please send an e-mail to Questions@ConningResearch.com.  All requests must include the following information: first name, last name, and e-mail address.

Conning Software Documentation Library Website Access and Updating Process.  If you have provided personal information in the past in connection with the Conning Software Documentation Library Website, publications, products and/or services and would like to access and update this information, please send an e-mail to risksolutions@conning.com.  If you would like to render your Conning Software Documentation Library Website account inactive, please send an e-mail to risksolutions@conning.com. All requests must include the following information: first name, last name, and e-mail address.

While Conning will make reasonable efforts to accommodate your request, Conning also reserves the right to impose certain restrictions and requirements on such access requests, if permitted or required by applicable laws.  Conning may decline to process any requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.  Conning does retain personal information from inactive accounts to comply with law, prevent fraud, collect any fees owed, resolve disputes, enforce the website terms of use and click-through agreements which incorporate this Privacy Policy and to facilitate audits.

Disclosure of Personal Information

Unless prohibited by applicable law, Conning may disclose your personal information to affiliated or unaffiliated third parties if Conning believes in good faith that such disclosure is necessary to: (a) comply with the law or in response to a subpoena, court order, government request or other legal process; (b) protect the interests, rights, safety or property of Conning or others; (c) enforce any terms of use on Conning’s websites; or (d) provide you with information, special offers or promotions from Conning to which you consented.  Conning makes reasonable efforts to limit its designated service providers’ disclosure of your personal information in the same manner as set forth in this paragraph.

Security of Personal Information

Any personal information you provide to Conning through the Conning’s websites is kept on secure servers.  Conning uses reasonable administrative, technical, personnel, electronic and physical measures to: (a) safeguard personal information against loss, theft, unauthorized use, disclosure or modification; and (b) ensure the integrity of the personal information.

To make sure your personal information is secure, Conning has instituted companywide policies to protect and secure personal information as it relates to its users and clients.  These policies (a) provide guidance as to how personal information is collected, processed and stored and (b) require multi-level controlled access to such personal information.  To help Conning protect your privacy, you should maintain the secrecy of the username and password that may have been set up in connection with your participation in any Conning websites.

Use of Cookies

Conning and its third-party vendors, may use cookies together with similar electronic tools to collect information to enhance your experience with Conning’s websites.  A cookie is a small text file placed on your computer that collects information about your use of a website, such as the web pages visited and the date and time of a visit, and enables the website to recall your preferences and settings between visits.  Conning treats information collected by cookies and other technologies as non-personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered person information by local law, Conning also treats those identifiers as personal information.  Similarly, to the extent that non-personal and personal information is combined, Conning treats the combined information as personal information for the purposes of this Privacy Policy.

Most browsers are set to accept cookies by default.  If you prefer, you can usually set your browser to disable cookies, only accept cookies from certain websites, 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, because cookies allow you to take advantage of some of a website's essential features, Conning recommends that you leave acceptance of cookies turned on or allow acceptance of cookies on Conning’s websites.  For instance, if you block or otherwise reject Conning cookies, you may not be able to access any of Conning’s website products and services that require you to sign in.

Social Media

Conning may maintain profiles and/or pages on various social media websites including but not limited to Facebook, LinkedIn, Twitter and YouTube.  If you choose to "Follow" Conning on Twitter, or take any similar action on another social media website, you are providing your consent to receive information updates from Conning.  "Following" Conning on Twitter or other social media websites is enables you to receive relevant, up-to-date information about Conning.  Conning generally will only use Conning’s handle to send out information and does not have the ability to respond or reply to tweets or messages sent to Conning.  To stop receiving this information from Conning on a social media website, you must follow the procedure established by the website.  For example, on Twitter, you must "Unfollow" on the Conning profile page.

When posting you should avoid investment specifics.  Also you should not post testimonials; investment advice; or recommendations about specific securities, products, or services, and do not send or post personal information or account information via social media.

Conning reserves the right to remove and moderate comments on its social media pages, and reserves the right to restrict users who don’t follow the guidelines herein, have online pages containing offensive content or serving as promotional sites, or for any other reason.

Comments and opinions posted by users are the responsibility of the person who posted them. Conning does not adopt, endorse, or guarantee the accuracy of content posted by others, and such content does not represent the views of Conning.

Followers who have a business relationship with Conning or other beneficial interest in commenting are responsible for adhering to any restrictions for interacting online and any obligations to disclose that relationship or interest in their posts.

Conning will never ask you to disclose your social security number, financial account information, passwords or PINs via Twitter or any other social media website.  Twitter, You Tube and LinkedIn are third party social media websites unaffiliated with Conning.  Conning is not responsible for the privacy or security policies or practices on Twitter or any of the third party websites that we may link to.  You should review the privacy and security practices of Twitter and all such third party websites.  

For all linked third party website content, Conning has not reviewed the entirety of those websites and therefore does not endorse any or all other content posted to those websites.  Conning also does not warranty nor guarantee the accuracy of any linked third party website content.

As a follower of @ConningNews or other Conning owned or operated social media websites, you consent to receive news and\or other company information from Conning that Conning thinks Conning followers will find useful.  If you do not wish to receive these notifications, please do not follow Conning’s social media websites.  Conning is not soliciting ideas; therefore, if you send Conning ideas, Conning shall then own them and they shall become the intellectual property of Conning, and you will not receive compensation for any ideas sent to Conning.

Questions

If you have any questions or concerns about Conning’s Privacy Policy or if you would like to make a complaint about a possible breach of local privacy laws, please contact us at 860-299-2000.

Last Updated: December 17, 2016