Lovell Minnick Partners (“LMP”), along with its affiliates, values your privacy and is dedicated to protecting your personal information. This Privacy Policy is designed to inform you about our practices regarding the collection, use, and disclosure of information when you visit our website, income-partners.net. We encourage you to read this policy carefully to understand how we handle your data.
At Lovell Minnick Partners, we are committed to maintaining the confidentiality and security of your personal information. This policy outlines our obligations and your rights concerning the data we collect. For the purposes of relevant data protection laws in the European Union, Lovell Minnick Partners acts as the data controller for any personal information gathered through this website.
We may update this Privacy Policy periodically to reflect changes in our data handling practices, technological advancements, or legal requirements. In the event of significant changes, particularly concerning the collection or use of your personal information in a manner different from what was stated when collected, we will prominently announce these changes on our website’s homepage. Your continued use of the website after such updates constitutes your acceptance of the revised Privacy Policy. We will always handle your personal information in accordance with the Privacy Policy that was in effect when the information was initially collected.
How Lovell Minnick Partners Collects Your Information
Our website primarily collects information in two ways: aggregate data and information you voluntarily submit.
Aggregate Data Collection
Similar to many websites, we automatically gather certain non-personal information about website usage. This aggregate data includes details such as the number of visitors, frequency of visits, and browsing patterns. This information may encompass the websites accessed immediately before and after visiting income-partners.net. We analyze this data in an anonymized and aggregated form to understand website traffic and improve user experience. This data is statistical and does not identify you personally.
Voluntarily Submitted Information
We collect personal information when you willingly provide it through our website. This typically occurs when you:
- Request to receive our newsletter: If you subscribe to our newsletter, we collect your email address and potentially other contact details to fulfill your request and manage your subscription.
- Contact us through website forms or contact details: When you use the “Contact Us” form, or reach out via email, postal address, or phone number provided on our website, we collect the information you provide. This may include your name, employer, address, title, job title, position, phone number, and email address.
It’s important to note that our “Client Login” page, which provides access to the Investment Caf portal, has its own separate privacy notice governing data collection and processing within that portal. If you access the Investment Caf portal, please refer to the privacy notice available there or provided to you during your investment process.
How Lovell Minnick Partners Uses Your Personal Information
The personal information we collect is used for legitimate business purposes, including:
- Providing Requested Services and Products: To deliver services or financial products you have specifically requested from us. This use is based on contractual necessity.
- Maintaining Relationship Records: To keep records of your interactions and relationship with Lovell Minnick Partners. This serves our legitimate interests and is necessary for contractual obligations.
- Verifying Identity: To verify your identity for security and compliance purposes, including anti-money laundering regulations. This is a legal requirement and serves our legitimate interest in preventing fraud.
- Conducting Due Diligence: To perform due diligence in connection with potential corporate transactions or investments. This processing is based on our legitimate interest in evaluating and executing investment opportunities.
- Preventing Fraud and Abuse: To prevent fraudulent activities and misuse of our services and website. This is a legal requirement and protects our legitimate interests.
- Managing Litigation and Audits: For litigation management and conducting internal audits and investigations to ensure compliance and manage risks. This is necessary for legal compliance and our legitimate interests.
- Administering and Protecting Our Business and Website: To manage, operate, and secure our website and business operations. This serves our legitimate interest in ensuring the smooth and secure operation of our business.
- Sending Marketing Communications: To send you newsletters and marketing communications about Lovell Minnick Partners, but only with your consent or based on our legitimate interests where we have an existing relationship with you.
- Responding to Inquiries: To respond to your requests and inquiries submitted via email, post, or telephone. This is based on our legitimate interest in addressing user queries and providing support.
Lovell Minnick Partners does not employ automated decision-making processes, including profiling, when processing your personal information.
Marketing Communications Preferences
We are committed to responsible marketing practices. You will only receive direct marketing communications, such as our newsletters, if you have provided your explicit consent or if we have a pre-existing relationship with you and believe you might be interested in similar services.
You have the right to manage your marketing preferences at any time. You can opt-in to specific types of marketing communications and modify your preferences, including unsubscribing entirely, by contacting us at [email protected]. Additionally, all our marketing emails include an “opt-out” or “unsubscribe” link for your convenience.
Disclosing and Transferring Your Information
To effectively operate our website and business, we may share your personal information with the following categories of recipients:
- Affiliates: Your information may be shared with our affiliated entities for the purposes outlined in this Privacy Policy.
- Service Providers: We engage third-party service providers to perform functions on our behalf, such as website hosting, data analysis, IT services, and professional advisory services (legal, consulting, etc.). These providers are contractually obligated to protect your personal information and can only use it for the specific services they are contracted to perform. This includes data hosting providers, professional advisors, consultants, and in certain cases, placement agents and fund administrators.
- Legal and Regulatory Authorities: We may disclose your personal information to government bodies, regulators, law enforcement agencies, or in response to legal processes (subpoenas, court orders, etc.) when required by applicable law or to comply with regulatory requests.
- Business Transaction Context: In the event of a merger, acquisition, takeover, divestment, or any other corporate restructuring, your personal information may be disclosed or transferred to the new owners or relevant parties and their advisors as part of the transaction.
When we transfer your personal information to countries outside the European Economic Area (EEA), we ensure that such transfers comply with applicable data privacy laws. This includes implementing appropriate safeguards, such as standard contractual clauses approved by the European Commission, to protect your data. For further details about the safeguards employed in specific transfers, please contact us at [email protected].
We do not sell, trade, or rent your personal information to third parties for marketing purposes.
Security of Your Personal Information
Lovell Minnick Partners takes data security seriously and implements robust measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include:
- Technical Security Measures: We utilize firewalls, encryption technologies, and secure server infrastructure to protect our systems and data.
- Procedural Security Measures: We have implemented internal policies and procedures to govern the handling of personal information, including access controls, data minimization practices, and regular security audits.
- Access Limitation: Access to your personal information is restricted to authorized employees, agents, contractors, and third-party service providers who have a legitimate business need to know the information to perform their duties. All such individuals are subject to confidentiality obligations.
- Data Breach Procedures: We have established procedures to address any suspected personal data breaches, including protocols for investigation, containment, notification to you and relevant supervisory authorities as legally required.
While we strive to maintain the highest standards of data security, it’s important to acknowledge that no security system is entirely impenetrable. We continuously monitor and enhance our security measures to mitigate risks and protect your information to the best of our ability.
Data Retention
Lovell Minnick Partners retains your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is mandated or permitted by law. The specific retention period depends on the purpose for which the information was collected and legal obligations.
For example, we may retain your information for as long as you subscribe to our newsletter, or as needed to provide you with requested services. We also consider legal and regulatory requirements that necessitate data retention for specific periods (e.g., for audit, tax, or compliance purposes).
For more detailed information about specific data retention periods, please contact us at [email protected].
Website Intended for Adults
This website is intended for use by individuals who are at least 18 years of age. We do not knowingly collect personal information from individuals under the age of 18 without parental consent. If we become aware that we have inadvertently collected personal information from a child under 18, we will take immediate steps to delete that information from our records.
Your Data Protection Rights
You have specific rights regarding your personal information under applicable data protection laws. These rights include:
- Right of Access: You have the right to request confirmation from us as to whether or not personal data concerning you is being processed, and, where that is the case, to request access to the personal data and information including the categories of data, processing purposes, categories of recipients, and retention period.
- Right to Rectification: You have the right to request the correction of inaccurate or incomplete personal data we hold about you.
- Right to Erasure (“Right to be Forgotten”): You have the right to request the deletion of your personal data under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, or if you withdraw your consent (where applicable). Note that this right is not absolute and may be subject to legal obligations.
- Right to Restriction of Processing: You have the right to request the restriction of processing of your personal data in certain situations, such as when you contest the accuracy of the data, for a period enabling us to verify the accuracy.
- Right to Object to Processing: You have the right to object to the processing of your personal data based on legitimate interests, including direct marketing and profiling.
- Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and have the right to transmit that data to another controller, where technically feasible and when processing is based on consent or contract.
- Right to Withdraw Consent: If we process your personal data based on your consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
To exercise any of these rights, please contact us at [email protected]. We may require you to verify your identity before processing your request to protect the security and confidentiality of your information. We will respond to your request within the timeframes set out by applicable data protection laws, typically within one month, although this may be extended in complex cases.
Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please do not hesitate to contact us at:
Complaints to Supervisory Authority
If you believe that our processing of your personal information infringes data protection laws, you have the right to lodge a complaint with a supervisory authority in the country of your habitual residence, place of work, or place of the alleged infringement.
California Residents: Your California Privacy Rights
This section supplements our general Privacy Policy and provides specific disclosures for California residents as required by the California Consumer Privacy Act (CCPA). If you are a California resident, this section applies to you.
Categories of Personal Information Collected
In the past twelve months, we have collected the following categories of personal information from California residents through our website:
- Identifiers: Such as name, postal address, email address, online identifiers, Internet Protocol address, account names, etc.
- Customer Records Information: Such as phone number, and other information you provide when seeking account access or support.
- Commercial Information: Including account data and transaction information if applicable.
- Professional or Employment-Related Information: If you provide this information when contacting us in a professional capacity.
- Education Information: If you provide this information in the context of inquiries related to your professional background.
- Internet or Network Activity Information: Including browsing history, search history, interactions with our website, cookies, analytics data, and information about devices used to access our website.
For detailed examples of the specific data points we collect within these categories, please refer to the sections above in this Privacy Policy.
Sources of Personal Information
We collect personal information from the following sources:
- Directly from you: When you submit information through our website forms, subscribe to our newsletter, contact us via email or phone, or interact with our website features.
- Indirectly from you: Through automated data collection technologies such as cookies and website analytics tools that track your browsing activity on our website.
- Publicly available sources: We may collect information from publicly accessible sources, such as professional networking sites, to supplement the information you provide directly.
Purposes of Processing Personal Information
We use the categories of personal information listed above for the business and commercial purposes described in detail in the “How Lovell Minnick Partners Uses Your Personal Information” section of this Privacy Policy. These purposes include: providing services, improving our website, communication, record keeping, operations, security, compliance, and marketing (with consent where required).
Disclosure of Personal Information
In the past twelve months, we may have disclosed each of the categories of personal information listed above to the categories of third parties described in the “Disclosing and Transferring Your Information” section of this Privacy Policy, including affiliates and service providers for business purposes.
We do not sell personal information of California residents.
Your CCPA Rights
As a California resident, you have the following rights under the CCPA:
- Right to Request Deletion: You have the right to request the deletion of your personal information that we have collected about you, subject to certain exceptions.
- Right to Request Disclosure (Right to Know): You have the right to request to know certain information about our data practices in the preceding 12 months, including:
- The categories of personal information we have collected about you.
- The categories of sources of personal information.
- The business or commercial purposes for collecting personal information.
- The categories of third parties to whom we have disclosed your personal information.
- The specific pieces of personal information we have collected about you.
- Right to Non-Discrimination: You have the right not to be discriminated against for exercising your CCPA rights. We will not deny you services, charge you different prices, or provide a different quality of services if you choose to exercise your CCPA rights.
Exercising Your CCPA Rights
To exercise your CCPA rights, please contact us through one of the following methods:
- Phone: Call us toll-free at 844-250-5175.
- Online Form: Submit a request through our online form at www.lmparners.com/ccpa.
- Email: Email us at [email protected].
When you contact us to exercise your rights, we may need to verify your identity to protect your privacy and security. We may request information from you to confirm your identity and residency. If you use an authorized agent to submit a request, we will require proof that you have authorized the agent to act on your behalf.
We will endeavor to respond to your request within 45 days of receipt, as required by the CCPA. If we require more time, we will inform you of the extension and the reasons for the delay.
For any questions or concerns about your California privacy rights or this California Privacy Notice, please contact the Chief Compliance Officer of Lovell Minnick Partners LLC at [email protected].
