This is the Privacy Statement and Policy (“Privacy Statement”) for Holding Advisory LLC. and its affiliates ("HA"). This Privacy Statement was last updated in January 2023. 

HA understands that your privacy is important. HA is committed to protecting your privacy and personal information you provide or as you access and use materials on holdingadvisory.com (the "Site"). In addition, information that you submit to HA in response to an email request for information or other outreach from HA, will be treated in accordance with this Privacy Statement. If you are a California resident, please see the California Addendum at the end of this Privacy Statement for further details on how we handle your information and how to exercise your rights.

HA may, in its discretion, amend this Privacy Statement from time to time. To ensure you are able to remain informed about the information we collect and how we use it, material changes to our statement will be reflected here. This Site may contain links to external sites which are not governed by this Privacy Statement. HA does not take responsibility for the privacy practices of any third-party sites to which we link. We encourage you to review the privacy policies of any such sites before you submit information there.

Please read this Privacy Statement carefully. By browsing the Site or expressly consenting, where required under applicable privacy laws, you agree to be bound by this Privacy Statement.

HA collects information from you when you create your account for the Site, request copies of publications, subscribe for email newsletters and press releases, seek additional information regarding our services, and for marketing communications (via emails, social media platforms) from HA based on your consent, where required under applicable privacy laws.

Personal information that we collect includes names, addresses, e-mail addresses, phone numbers, IP, geo location, subject areas of interest and/or demographic information.

If you do not provide such information, you may not be able to create an account for the Site, request copies of publications, subscribe for email newsletters and press releases, seek additional information regarding our services or employment opportunities.

The purposes and uses of your personal information will depend on the use of the Site and the personal information provided. We process your personal information:

For the purposes of safeguarding the legitimate business interests pursued by HA. This includes:

• Communicate with you and manage your requests in relation to your account, subscriptions to HA newsletters, publications, events and survey participations
• Tailoring your experience at the Site with relevant HA materials
• Understanding the Site’s user population, identifying subject areas of interest, and determining whether the Site is designed to work with the computer settings of a majority of our visitors
• Measuring and improving the effectiveness of HA marketing programs across different channels
• Improving our web content and navigation
• Informing you about updates to the service and notifying you about other products and services offered by HA that may be of interest to you, including information regarding publications and events and track email engagement activity for internal use only.

For compliance with a legal obligation. This includes anti-fraud and anti-money laundering measures as well as tax and social security requirements.

The third parties with whom we may need to share personal information to help us provide services and products to you and to run our Site include:

• Our subsidiaries or affiliates
• Our advisors
• Our third-party service providers who process information on our behalf to help run some of our internal business operations including email distribution, IT services, the Site security and marketing and events services
• Law enforcement bodies in order to comply with any legal obligation or court order
• HA may disclose your contact information in response to inquiries by bona-fide rights owners in connection with allegations of infringement of copyright or other proprietary rights arising from information that you have posted on the Site or otherwise provided to HA

HA retains your personal information for so long as is necessary to fulfil the purpose for which it was collected. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using our services) and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations)

In our marketing communications with you we monitor and comply with applicable data privacy laws and if, at any time, you prefer not to receive further communications from us in any or all forms you will have the ability to unsubscribe from such communications by means of a link provided in every e-mail that is sent to you by us. When subscribing to HA e-mail newsletters, you are given the opportunity to select which promotions, news, and information you would like to receive at the time of sign up, and you will have the opportunity to unsubscribe from such communications.

HA may use cookies on this Site and in our communications with you to keep track of your visit to our Site and our communications with you. A “cookie” is a small amount of data sent from a Web server to your browser and stored on your computer’s hard drive. Other tracking technologies work similarly to cookies and place a small amount of data on your devices to monitor your website activity to allow us to collect information about how you use our Site and our services. With most internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored on your computer. Please refer to your browser instructions or you can visit https://www.aboutcookies.org/ which will give you more information. Once you have given your consent to use cookies, we shall store a cookie on your computer or device to remember this for next time. If you wish to withdraw consent at any time you will need to delete our cookies using your web browsers settings. Please be advised that certain sections or functionalities of the Site may be inaccessible to you if your browser does not accept cookies. We do not currently respond to browser do-not-track signals.

HA has in place appropriate technological and operational security processes designed to protect personally identifiable information from loss, misuse, alteration, or destruction. Only authorized employees and contractors will have access to any data provided by you, and that access is limited by need. Each employee or contractor having access to any personally identifiable information is obligated to maintain its confidentiality. Although we take steps that are generally accepted as industry standard to protect your personally identifiable information, HA cannot guarantee that your personally identifiable information will not become accessible to unauthorized persons and HA cannot be responsible for any actions resulting from a breach of security when information is supplied over the internet or any public computer network.

This Site contains links to other Web sites that are not operated by HA.

HA is not responsible for the privacy practices or the content of any non-HA web sites to which we link from the Site. We are not responsible for the protection and privacy of any information you provide whilst visiting other websites and sites not governed by our Privacy Statement. We cannot control the content or security of such websites. We cannot be held responsible for any loss or damage incurred by a user as a result of visiting such websites. No links are intended to be, nor should be construed as, an endorsement of any kind by us of that other website.

HA complies with all applicable data privacy laws. HA may be compelled to surrender personal user or customer information to legal authorities if presented with a court subpoena or similar legal or administrative order, or as required or permitted by the laws, rules and regulations of any nation, state or other applicable jurisdiction. Also, in the event of a violation of the terms and conditions of use of the Site or a violation of any restrictions on use of materials provided in or through the Site, we may disclose personal user information to our affected business partners or legal authorities.

In accordance with applicable data privacy laws, including but not limited to the GDPR and the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), you have a right to request a copy of the personal information we hold about you and details of how we use that information. If any of the information held about you is incorrect or out of date, you have the right to amend or rectify it, please follow the process outlined below and we will amend our records where appropriate. You also have the right to request that we erase your personal information, stop processing your personal information, restrict the processing of your personal information, and provide your personal information in a portable format. Where processing is based on your consent, you may withdraw your consent to processing. This may not apply if there are other legal justifications to continue processing. If you think we may have incorrect personal information, or would like a copy of the personal information we hold on you, or to exercise any other data protection right, please contact us. Please note that we need you to prove who you are before we can provide you with any information.

You also have a right to lodge a complaint with a relevant supervisory authority.

HA understands the importance of protecting children's privacy, particularly in their online interactions. This Site is not designed for and does not intentionally target or solicit to children 18 years of age and younger.

Your access to and use of the Site are subject to this Privacy Statement and certain other terms and conditions.

For further questions you may contact the appropriate data protection point of contact:

Data Protection Office

3695 Green Road, Suite 22329

Beachwood, OH 44122
310-906-5716
admin@holdingadvisory.com

This California Addendum applies to California residents and supplements the information provided above in the Privacy Statement. This Addendum does not apply to our job applicants, employees, or contractors where the personal information we collect about those individuals relates to their current, former, or potential role with us.

The following list details which categories of personal information we collect and process both online and offline, as well as which categories of personal information we disclose to third parties for our operational business purposes, including within the 12 months preceding the date this Privacy Statement was last updated. The list also details the categories of personal information that we “share” for purposes of cross-context behavioral advertising, including within the preceding 12 months.

We may share the following information with ad networks for cross-context behavioral advertising:

• Identifiers, such as IP address, and online identifiers
• Geolocation data, such as approximate location derived from IP address
• Internet or network activity information, such as browsing history of HA sites, assets or prior visits, and interactions with our online properties
• Inferences drawn from any of the personal information listed above to create a profile about, for example, an individual’s preferences or characteristics

• Identifiers, such as name IP address, and online identifiers, contact information, unique personal identifiers,
• Internet or network activity information, such as browsing history of HA sites, assets or prior visits, search history and interactions with our online properties
• Geolocation Data, such as approximate location derived from IP address
• Inferences drawn from any of the personal information listed above to create a profile about, for example, an individual’s preferences or characteristics or for statistics and visitor tracking
• Browser fingerprint and IP address
• Audio/Video Data. Audio, electronic, visual, and similar information

• Identifiers such as name and contact information

We do not sell and have not sold personal information, including your sensitive personal information, in the preceding 12 months. Without limiting the foregoing, we do not sell the personal information, including the sensitive personal information, of minors under 16 years of age.

We collect this personal information directly from you and from third-party sources, such as public databases, joint marketing partners, and social media platforms, where permitted under applicable local laws.

We collect, use, or share personal information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including to:

• Develop, improve, operate repair, and maintain our products and services
• Provide support and respond to requests for information
• Advertise and market our products and services, and personalize user experiences
• Conduct research, analytics, and data analysis
• Operate and maintain our facilities and infrastructure
• Undertake quality and safety assurance measures, and conduct security control and monitoring
• Detect and prevent fraud and perform identity verification
• Facilitate and implement any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings)
• Maintain records, comply with law, legal process, and internal policies, and exercise and defend legal claims.

We may use sensitive personal information of account log-in, password, or credentials allowing access to an account which qualify as sensitive personal information for purposes of performing services for our business, providing goods or services as requested by you, ensuring security and integrity, short term transient use such as displaying first party, non-personalized advertising, order processing and fulfilment, servicing accounts, providing service, verifying client information, and activities relating to quality and safety control or product improvement.

You may, subject to applicable law, make the following requests:

You may request that we disclose to you the following information:

• The categories of Personal Information we collected about you and the categories of sources from which we collected such personal information
• The business or commercial purpose for collecting or sharing personal information about you
• The categories of personal information about you that we shared (as defined under the applicable privacy law) and the categories of third parties to whom we shared such personal information; and
• The categories of personal information about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such personal information (where applicable)

• You may request to correct inaccuracies in your personal information
• You may request to have your personal information deleted
• You may request to receive the specific pieces of your personal information, including a copy of the personal information you provided to us in a portable format
• You may request to opt out of the “sharing” of your personal information for purposes of cross-context behavioral advertising

We will not unlawfully discriminate against you for exercising your rights under applicable privacy law. To make a privacy request, contact us via admin@holdingadvisory.com or call 310-906-5716. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request. We may need to request additional personal information from you, such as copy of your driver’s license, utility bill in order to verify your identity and protect against fraudulent requests. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information.

If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted in the section entitled “Individual Requests.” As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Individual Requests” or confirm that you provided the agent permission to submit the request.

Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify the information.

1. Unless it is subject to your consent where required under applicable privacy laws.

2. CPRA defines sensitive personal information as personal information that reveals an individual’s social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, citizenship, immigration status, or union membership; the contents of mail, email, and text messages unless HA is the intended recipient of the communication; genetic data; The processing of biometric information for the purpose of uniquely identifying an individual; Personal information collected and analyzed concerning an individual’s health; and Personal information collected and analyzed concerning an individual’s sex life or sexual orientation.