IMPORTANT DISCLOSURE INFORMATION
Hamilton Capital, LLC (“Company”) is an SEC registered investment adviser located in Columbus, Ohio. A copy of the Company’s current written disclosure Brochure discussing our advisory services and fees continues to remain available upon request and/or on this web site at www.hamiltoncapital.com.
Company may only transact business in those states in which it is registered, or qualifies for an exemption or exclusion from registration requirements. Company’s web site is limited to the dissemination of general information pertaining to its advisory services, together with access to additional investment-related information, publications, and links. Accordingly, the publication of Company’s web site on the Internet should not be construed by any consumer and/or prospective client as Company’s solicitation to effect, or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation, over the Internet. Any subsequent, direct communication by Company with a prospective client shall be conducted by a representative that is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides. A copy of Company’s current written disclosure Brochure discussing Company’s business operations, services, and fees is available from Company upon written request. Company does not make any representations or warranties as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to Company web site or incorporated herein, and takes no responsibility therefore. All such information is provided solely for convenience purposes only and all users thereof should be guided accordingly.
Please remember that different types of investments involve varying degrees of risk, and there can be no assurance that the future performance of any specific investment or investment strategy (including those undertaken or recommended by Company), will be profitable or equal any historical performance level(s).
Certain portions of Company’s web site (i.e. newsletters, articles, commentaries, etc.) may contain a discussion of, and/or provide access to, Company (and those of other investment and non-investment professionals) positions and/or recommendations as of a specific prior date. Due to various factors, including changing market conditions, such discussion may no longer be reflective of current position(s) and/or recommendation(s). Moreover, no client or prospective client should assume that any such discussion serves as the receipt of, or a substitute for, personalized advice from Company, or from any other investment professional. Company is neither an attorney nor an accountant, and no portion of the web site content should be interpreted as legal, accounting or tax advice.
Please Note: Limitations: Neither rankings and/or recognitions by unaffiliated rating services, publications, media, or other organizations, nor the achievement of any professional designation, certification, degree, or license, membership in any professional organization, or any amount of prior experience or success, should be construed by a client or prospective client as a guarantee that he/she will experience a certain level of results if Company is engaged, or continues to be engaged, to provide investment advisory services. Rankings published by magazines, and others, generally base their selections exclusively on information prepared and/or submitted by the recognized adviser. Rankings are generally limited to participating advisers (see participation criteria/methodology). Unless expressly indicated to the contrary, Company did not pay a fee to be included on any such ranking. No ranking or recognition should be construed as a current or past endorsement of Company by any of its clients. ANY QUESTIONS: The Company’s Chief Compliance Officer remains available to address any questions regarding rankings and/or recognitions, including the criteria used for any reflected ranking.
To the extent that any client or prospective client utilizes any economic calculator or similar interactive device contained within or linked to Company’s web site, the client and/or prospective client acknowledges and understands that the information resulting from the use of any such calculator/device, is not, and should not be construed, in any manner whatsoever, as the receipt of, or a substitute for, personalized individual advice from Company, or from any other investment professional.
Each client and prospective client agrees, as a condition precedent to his/her/its access to Company’s web site, to release and hold harmless Company, its officers, directors, owners, employees and agents from any and all adverse consequences resulting from any of his/her/its actions and/or omissions which are independent of his/her/its receipt of personalized individual advice from Company.
PRIVACY POLICY
Thank you for visiting Hamilton Capital’s Internet web site (“Site”) located at the URL www.HamiltonCapital.com. This Privacy Policy details certain policies implemented throughout Hamilton Capital governing Hamilton Capital’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 may need to update this Privacy Policy from time to time. If so, Hamilton Capital 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 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 does not target its Services or this Site to children under 18. Hamilton Capital 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 participates or to a purchaser of all or substantially all of Hamilton Capital’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 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 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 on its servers located in the United States of America as described in this Privacy Policy.
Correction/Updating Personally Identifiable Information
Hamilton Capital 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.
This Privacy Policy was last updated: February 17, 2011
This Privacy Policy is effective as of: February 17, 2011