Privacy Policy

Last updated on October 11, 2017

Index
1. Who We Are
2. Information Collected
3. Information Use
4. Disclosing Information
5. Your Options
6. Data Security
7. Children
8. Service Provider Relationships
9. Changes to this Policy
10. Contacting Us

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  1. Who We Are

EF Hutton, Inc. and EF Hutton Investments LLC (collectively “EF Hutton” or “we”) operate the website at www.efhutton.com. EF Hutton Inc. and EF Hutton Investments LLC are both subsidiaries of HUTN Group, Inc. EF Hutton is committed to protecting any and all data that we collect concerning our clients (or “you”). By using any service provided by EF Hutton or an affiliate thereof, you agree to the use of the data that we collect in accordance with this Privacy Policy (the “Policy”). The purpose of this Privacy Policy is to enable you to understand what personal information of yours is collected, how and when we might use or share your information, and how you can correct any inaccuracies in the information. This Privacy Policy also explains our online information practices and the choices you can make about the way your information is collected and used.

 

  1. Information Collected

In providing services to our clients, EF Hutton collects certain types of confidential personal information, both identifying and non-identifying (collectively “Information”). We collect the following types of Information in order to provide you with a wide range of products and services, both those that you purchase or use, and those that we can later develop. We may collect any or all of the Information via both automated means such as communications profiles or cookies as well as direct polling or surveys of our clients.  Due to the nature of the services we provide, it may at times be necessary to share the information we collect with certain third parties as described herein.  In order to use certain services, you may be required to consent to such disclosures, should you choose to opt-out of having collected information shared, then you may not be able to utilize the services offered by EF Hutton.  Notwithstanding anything in this Policy, EF Hutton will never sell your personal information to third parties.

Personal Information. The exact personal information we collect depends on the type of service being provided, and may include but is not necessarily limited to your name, address, telephone number, fax number, email address, dates of service provided, types of service provided, payment history, manner of payment, amount of payments, date of payments, domain name, credit card or other payment information, and any other information deemed helpful or necessary by EF Hutton in its sole discretion. The financial information we collect is only used to bill you for the products and services you purchased. If you purchase by credit card, this information may be forwarded to your credit card provider. When transferring personal information on the internet, a security icon will appear in your browser.

Cookies and Tracking. Your Internet browser has the in-built facility for storing small text files – “cookies” – that hold information which allow a website to recognize your account. We use cookies to save your preferences and login information, and to provide personalized functionality. We may use cookies to collect, store, and sometimes track information for statistical purposes to improve the products and services we provide and to manage our telecommunications networks. More specifically, we use different types of cookies for different purposes: (i) “required cookies” are necessary for our website to work properly, (ii) “performance cookies” allow us to analyze how Visitors use our website so we can measure and improve the performance of our website, (iii) “functional cookies” allow us to remember choices you may have made on our website, and (iv) “advertising cookies” are used to present ads that are relevant to your interests. We may utilize cookies to track referrals from internal and external affiliates, as well as advertising campaigns. We may also use a third party service provider to send emails that you have agreed to receive. Pixel tags and cookies may be used in those email messages to help us measure the effectiveness of our advertising and to enable us to provide more focused marketing communications to you. You can reject cookies by changing your browser settings, but be aware that this will disable some of the functionality of our various websites and internet services.

Customer Surveys. We may periodically conduct customer surveys. Participation in our customer surveys is generally voluntary. However, we encourage you to participate in these surveys because they provide us with important information that helps us improve the types of services we offer and how we provide them to you. Surveys generally do not require the disclosure of personally identifying information, however if such information is provided, said information provided to EF Hutton will remain confidential consistent with this Policy.  Personally identifiable information provided to third parties is treated in accordance with the third parties’ privacy policy and you are encouraged to review said privacy policy prior to providing any personally identifiable information to a third party.

Social Media. Our services may include certain social media features. These features may collect your IP address and which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Social media features and widgets may be hosted by a third party or directly on our website. Your interactions with these features are governed by the privacy policy of the company providing the feature.

Data and Information Submitted to Third Parties on Our Network. This Privacy Policy does not apply to data or personal information that may be submitted to, or collected by, third-parties by any means. This includes information submitted on any websites hosted by or linked to or from any EF Hutton affiliated website. You should independently evaluate the privacy policies of such third-party websites before submitting data or personal information to them.

 

  1. Information Use

Personal Information. The Information we collect is used for billing and to provide service and support to our customers. We may study this Information to determine our customers’ needs and to promote certain products and services or additional support. We may also generate non-identifying and aggregate profiles from information that our customers provide during registration (such as the total number of customers in a given category). This aggregated and non-identifying information may be used for a variety of business reasons. Information we collect is also used for risk control and fraud detection, and may be necessary to comply with applicable laws and regulations.  EF Hutton may also use the information you provide to contact you regarding our regular periodicals or other products or services that we think may be of interest.

We take reasonable precautions to prevent unauthorized access to your information. Accordingly, we may require you to provide additional forms of identification should you wish to obtain information about your account details.

Log Files. We use IP addresses to analyze trends, administer our site and servers, track access, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information. However, it is possible that personal information about a customer may be included in the log files due to the normal functions of IP addresses and Web browsing.

Customer Surveys. We may use the contact and other information provided to follow up with customers who respond to our customer surveys to help resolve issues internally or with our third party partners.  Customers responding to surveys who do not wish to be contacted may indicate such on the survey or respond anonymously.

 

  1. Disclosing Information

Partners and Sponsors. Some products or services may be offered or promoted to our customers in conjunction with a third party, often referred to as a partner or sponsor, or another brand or company within our corporate family. We may share your information with these parties to offer the product or service or to facilitate your use of additional amenities included with your hosting account.
We may also disclose aggregate, anonymous data based on information collected from users to potential partners, reputable third parties and other companies or brands within our corporate family. We will only share your information with third parties that agree to maintain your information in confidence and to use it solely for purposes of providing the product or service as agreed to by EF Hutton.

Service Providers. We may transfer (or otherwise make available) your personal information to third parties that help us provide our services or provide services on our behalf. Your personal information may be maintained and processed by our third party service providers in the United States or in other jurisdictions. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes. Due to the nature of these business relationships, you may not opt out of these disclosures.

Non-Affiliated Third Parties: EF Hutton will not share your personally identifiable personal information with non-affiliated third parties which are third parties outside the EF Hutton family of companies and/or its affiliates that are also not Joint Marketers or Joint Service Providers. Although we may freely share non-personally identifying aggregated information with these companies, you may opt-out of any of your information being shared with these companies.

 

Online Advertisements. We do not share personally identifiable information about individual customers with advertisers. We may display online advertisements and we may share aggregated and non-identifying information about our customers that we collect with certain advertisers. In some instances, we use this aggregated and non-identifying information to deliver tailored advertisements.

Customer Surveys. We may share customer information obtained from customer surveys within EF Hutton and our corporate family, and with trusted third parties to develop or provide products and services that we believe would be of interest to our customers.

Law Enforcement and Special Cases. We cooperate with government and law enforcement officials to enforce and comply with the law. We will disclose any information about users upon a valid request by government or law officials as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal processes, to protect your property and rights, or the property and rights of EF Hutton or a third party, to protect the safety of the public or any person, or to stop activity that we consider illegal or unethical.

Correcting/Updating Personal Information. If a customer’s information changes, or if a customer no longer desires our services, it is the responsibility of the customer to notify us of the change or cancellation. This can be done via our Website or other similar arrangement that shall be made available to the customer.

Public Forums. Any information you may disclose or post on public areas of our websites or the Internet, is public information. Customers should exercise caution when deciding to disclose personal information in these public areas. To request removal of your personal information from our community forums or testimonials, contact us at privacy@EFHutton.com. Depending on the circumstances, EF Hutton may not be able to remove information posted publicly.

 

  1. Your Options

Opt Out. By default, customers will receive invoices, any system updates, EF Hutton newsletters and other mailings. Customers are able to opt out of newsletters and mailings by using the unsubscribe link in any promotional email or as otherwise provided in the communication.  Please note that customers may not opt out of receiving important system notifications or emails about their accounts.  Customers who wish to opt out may do so on the Website.  Customers who later wish to change their opt-out choice must do so on the Website.

 

  1. Data Security

EF Hutton uses technical security measures to prevent the loss, misuse, alternation or unauthorized disclosure of information under our control. EF Hutton uses security measures including and not limited to: physical, electronic and managerial procedures to safeguard and secure the information we collect online. All sensitive information is collected on a secure server. When we ask customers or users to provide financial information (such as a credit card number) that data is protected using Secure Sockets Layer (“SSL”) technology.

 

  1. Children

This website is not directed towards minors and we do not seek to collect any personal information from individuals under the age 13. The services are for people 18 years of age and older. If we become aware that personal information from a child under the age of 13 has been collected, we will use all reasonable efforts to delete such information from our database.

 

  1. Service Provider Relationships

In addition to all of the terms and conditions set forth above, the following terms apply to Service Provider (“Provider”) relationships only.

Data Retention. We retain personal data we process on behalf of our Provider for as long as needed to provide services under the relationship. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

  1. Changes to this Policy

We reserve the right to revise, amend, or modify this Privacy Policy at any time and in any manner with or without notice to you.   Changes will be posted to the Website, and you are agree to regularly check for updates. However, should any change modify how EF Hutton plans to treat previously collected personally identifying information, we will provide you with advance notice prior to the change becoming effective and provide you with an opportunity to opt-out of the updated policy.  Note that opting out may preclude your continued use of EF Hutton services. We encourage you to periodically review this page for the latest information on our privacy practices.

 

  1. Contacting Us

Inquiries regarding this Policy, or any other privacy-related matters may be sent by mail at the address below or by sending a message to: info@efhutton.com

EF Hutton

One Main Street

Attn: Privacy

Springfield, Ohio 45502
United States of America