Hamilton Capital Management - Registered Investment Advisor

Privacy Policy

Thank you for visiting Hamilton Capital Management's Internet web site ("Site") located at the URL www.HamiltonCapital.com. This Privacy Policy details certain policies implemented throughout Hamilton Capital Management governing Hamilton Capital Management's use of personally identifiable information about users of our Site and users of services available through this Site (the "Services").

Privacy Policy Updates

Due to the Internet's rapidly evolving nature, Hamilton Capital Management may need to update this Privacy Policy from time to time. If so, Hamilton Capital Management will post its updated Privacy Policy on our Site located at www.HamiltonCapital.com and we may send registered users an email, so you are always aware of what personally identifiable information we may collect and how we may use this information. If any modification is unacceptable to you, you shall cease using this Site and the Services. If you do not cease using this Site and the Services, you will be deemed to have accepted the change.

Information Collection and Use

You can generally visit our Site without revealing any personally identifiable information about yourself. However, in certain sections of this Site and when you use our Services, we may invite you to contact us with questions or comments or request information, provide or upload documents and other content, contact us with feedback, participate in surveys, questionnaires or complete a registration form. Due to the nature of some of these activities, we may collect personally identifiable information that you submit in your profile, such as your email address, phone number and city. We may also collect additional personally identifiable information that you voluntarily include in your profile or transmit with your communications to us. We may use your personally identifiable information to register you to use our Site and Services, deliver certain services, provide notices regarding services, and verify your authority to enter our Site, improve the content and general administration of the Site and our Services.

Children's Privacy

Hamilton Capital Management recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children's online activities and interests. This Site is not intended for children under the age of 18. Hamilton Capital Management does not target its Services or this Site to children under 18. Hamilton Capital Management does not knowingly collect personally identifiable information from children under the age of 18.

Cookies

We may use small text files called cookies to improve overall Site experience. A cookie is a piece of data stored on the user's hard drive containing information about the user. Cookies generally do not permit us to personally identify you.

Aggregate Information

The Site may track the total number of visitors to our Site, the number of visitors to each page of our Site, browser type, and IP addresses, and we may analyze this data for trends and statistics in the aggregate, but such information will be maintained, used and disclosed in aggregate form only and it will not contain personally identifiable information. We may use such aggregate information to analyze trends, administer the Site, track users' movement, and gather broad demographic information for aggregate use.

Disclosure

We do not disclose any non-public personal information about our customers or former customers to anyone, except as permitted or required by law, or as necessary to provide services to you. In accordance with Sections 248.13 through 248.15 of Regulation S-P, we may disclose all of the information we collect to certain non-affiliated third parties such as, but not limited to, attorneys, accountants, auditors and persons or entities that are assessing our compliance with industry standards. We enter into contractual agreements with all nonaffiliated third parties that prohibit such third parties from disclosing or using the information other than to carry out the purposes for which we disclose the information.

Webinar Users

We may provide your personally identifiable information and the data generated by cookies and the aggregate information to the vendors and service agencies that we may engage to assist us in providing our Services to you. Such third party entities may be obligated to use your personally identifiable information solely to provide the services to us. We will disclose your personally identifiable information if we reasonably believe we are required to do so by law, regulation or in cooperation with any governmental investigation. We will not sell your personally identifiable information to any company or organization except we may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization in which Hamilton Capital Management participates or to a purchaser of all or substantially all of Hamilton Capital Management's assets to which this Site relates.

Security

We may employ procedural and technological security measures that are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. Hamilton Capital Management may use encryption, password protection, and other security measures to help prevent unauthorized access to your personally identifiable information.

Notice to European Users

The information you enter on this Site or otherwise provide to Hamilton Capital Management may be transferred outside of the European Union to the United States of America which does not offer an equivalent level of protection to that required in the European Union. In particular, you are advised that the United States of America uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. Article 26 of the European Union's Data Protection Directive (Directive 95/46/EC, 1995 O.J. (L 281) 31) allows for transfer of personal data from the European Union to a third country if the individual has unambiguously given his consent to the transfer of personal information, regardless of the third country's level of protection. By agreeing to the terms of use and this privacy policy, you consent to the transfer of all such information to the United States of America which may not offer an equivalent level of protection to that required in the European Union and to the processing of that information by Hamilton Capital Management on its servers located in the United States of America as described in this Privacy Policy.

Correction/Updating Personally Identifiable Information

Hamilton Capital Management provides you with the ability to review, correct and delete any of your user profile. Information you post in other areas of the Site cannot be deleted. If you wish to review or correct any profile information you have provided to us, you may submit a request to us at the contact email below or access your account online.

If you have any questions regarding this Privacy Policy please contact us via email at
This Privacy Policy was last updated: February 17, 2011
This Privacy Policy is effective as of: February 17, 2011
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