Privacy Policy

Last Updated: This Privacy Policy was last updated on January 4, 2021.

This Privacy Policy describes how Graham Partners (“Graham Partners”, “we”, “our”, or “us”) will use and share the information we collect or receive from or about you when you visit (“Website”) and any of our websites that link to this Privacy Policy (collectively, the “Services”). This Privacy Policy does not apply to other third party services, websites and applications accessed by or through our Website or other websites that we may operate but on which a link to this Privacy Policy does not appear. We are committed to protecting your personal information. If you have any questions or concerns about our Privacy Policy, or our practices with regards to information we collect from or about you, please contact us at Please read our Privacy Policy carefully. By using our Services, you consent, where required, to the practices described in this Privacy Policy.

Information We Collect

We collect information about you in various ways. For example, you may provide personal information directly to us, we may collect certain information about you automatically through your use of the Services, or we may obtain information about you from third parties who are acting on our behalf.

Information You Provide To Us

When you interact with us through our Services, we may collect or receive information about you. For example, you provide information to us when you submit a form through the “Contact Us” page, express interest in obtaining information about us or our Services, or when you use our Services. When you are navigating through our Website, we record your IP address. Generally, you control the amount and type of information you provide to us when using our Services. Some of the information you provide to us is “personal information.” The personal information that we collect from you depends on the context of your interaction with us and our Services, the choices you make when you use our Services, and the products and features you use. The personal information we collect or receive may, for example, include the following:

  • Name
  • Job title
  • Telephone or fax number
  • Address
  • Email address
  • Social Security Number

Information We Obtain From Other Sources

We may also engage service providers, such as investment data companies, to collect information from or about you on our behalf.

Information We Collect Automatically

When you use our Services, we automatically collect certain information about you when you visit our web pages, open our emails, or otherwise use the Services. Automatically collected information may, for example, include the following:

  • Your IP address.
  • The type of browser and operating system you are using.
  • The domain name of your Internet service provider.
  • Information about the content you view and the features you access on our Services, including your activity and behavior on our Website.
  • Information regarding when you access our Services, including information regarding the duration of your engagement with certain aspects of the Services.

This data may be combined and linked with data from other sources.

We use cookies to collect and store information when you visit our Services. For more information, please see Cookies and Other Tracking Technologies below.

How We Use Information

We may use the information collected pursuant to this Privacy Policy in the following ways:

  • To operate and provide the Services to you, or to fulfill any other purpose for which you provide us with information.
  • To deliver the information, products or services you have requested from us.
  • To create and share aggregate statistics and reports regarding visitors to our Services and users of our Services.
  • To reach out to you about and promote new information, products or services to you that we believe you may be interested in.
  • To help us to improve our Services and to deliver a better and more personalized experience, including by enabling us to estimate our audience size and usage patterns, store information about your preferences and recognize you when you use our Services.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and Graham Partners and as we believe is necessary or appropriate to protect, enforce or defend the legal rights, privacy, safety or property of the Services, its employees or agents, or other users or to comply with applicable law.
  • To communicate with you, including to notify you about changes to our Services. In any other way we may describe when you provide the information, or otherwise at your direction or with your consent.
  • As permitted by law or as we may notify you.

How We Share Information

We may share the information that we collect about you or that you provide to us, including any personal information, as follows:

  • We may share the following categories of information with service providers, including our business partners and vendors, for one or more business purposes:
      • Personal identifiers, such as your name, address, email address, social security number, IP address, and online identifiers
      • Financial information, such as your account name and number; and
      • Internet or other network activity information, such as browser, device type, and website interaction information.

We share those categories of information with service providers to fulfill the following business purposes:

      • Providing you our Services;
      • Providing us cloud-computing and web analytics services; and
      • Providing us marketing and advertising services.
  • We will disclose information we collect about you when required to do so by law, for example, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency’s request.
  • We may share your information with our affiliates.
  • We may share your information where necessary and permitted by law for the establishment, exercise, or defense of legal claims, to protect the rights and property of Graham Partners and its affiliates and their respective agents, customers, and others, including to enforce our agreements, policies, and terms of use, or to protect the personal safety of any person.
  • With your permission or upon your direction, we may disclose your information to interact with a third party or for other purposes.

In addition, please note that if Graham Partners or any of its affiliates, subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of or dissolved, including through merger, consolidation, sale or divestiture of assets, information collected pursuant to this Privacy Policy and any other information we possess about you, including personal information, may, in whole or in part, be sold, disposed of, transferred, divested, or otherwise disclosed as part of that transaction or proceeding.

We do not sell your information.

Cookies and Other Tracking Technologies

Our Website uses cookies and may employ other tracking technologies such as those described below. These tracking technologies may be deployed by us and/or our by our service providers or partners on our behalf. Cookies. Cookies are small text files that may be placed on your computer or device when you visit our Website. A cookie assigns a unique numerical identifier to your web browser or device, and may enable us or third parties to recognize you as the same user who has used the Services, and relate your use of the Services to other information about you, such as your usage information and personal information. We may use cookies in a variety of ways. For example, we may use cookies to:

  • Track and record information about your activities on our Website (including your preferences and behaviors, as well as your navigation on the Website).
  • Personalize your experience on our Services (e.g., to recognize you when you return to our site).
  • Provide us with information about which portions of our Website are the most popular by enabling us to see what web pages a user visits and how much time a user spends on each page.

Cookies, by themselves, do not tell us your email address or other personal information about you unless you choose to provide this information to us. Once you choose to provide us with personal information, this information may be linked to the data stored in the cookie. Most browsers automatically accept cookies. You can generally set your browser options so that you will not receive cookies and you can also delete existing cookies from your browser. However, you may find that some parts of the Services will not function properly if you have refused cookies or similar tracking technologies and you should be aware that disabling cookies or similar tracking technologies might prevent you from accessing some of our content. If you wish to block cookies, go to to find out how, or check your browser’s instructions.

Local Shared Objects. Local shared objects, such as “Flash cookies” also may be stored on your computer or device. Local shared objects operate a lot like cookies because they are stored on your device and can be used to store certain information about your activities and preferences; however, they cannot be managed in the same way as cookies. Depending on how local shared objects are enabled on your computer or device, you may be able to manage them using software settings. For information on managing Flash cookies, for example, see

HTML 5. HTML5, the language some websites are coded in, may be used to store information on your computer or device about how you use the Services. This information may be retrieved by us to help us manage the Services, and may give us information about how the Services are being used by our visitors, how they can be improved, and how we can customize the Services for users.

Cache Cookies. Cache cookies, such as eTags, may be used to identify your computer or device as the same computer or device that visited our Website or Services in the past. Web Beacons. A web beacon is an electronic image called a single-pixel or “clear gif” that is a small piece of code that is used to collect anonymous and aggregate advertising metrics, such as the counting of page views, promotion views, or advertising responses. Web beacons can recognize certain types of information, such as a user’s cookie number, time and date of a page view, and description of the page where the web beacon is placed. These web beacons may be used to deliver cookies.

Analytics. We also use Google Analytics, which is a web analytics tool, to help us understand how you engage with our website. Learn more about Google Analytics here.

Do Not Track Signals. Your browser settings may allow you to transmit a “Do Not Track” signal when you visit various websites. Our Site is not configured to respond to “Do Not Track” signals received from browsers.

Accessing, Correcting, and Deleting Your Personal Information

We take reasonable steps to accurately record the personal information that you provide to us pursuant to this Privacy Policy and any subsequent updates to such information. We encourage you to review, update, and correct the personal information that you provide to us pursuant to this Privacy Policy. Please contact us at in order to do so.

California Residents

If you are a California resident, you have certain rights in relation to your personal information under the California Consumer Privacy Act (“CCPA”). To exercise these rights see the “Exercising Your California Privacy Rights” section.

  • Right to Know. You have the right to know and see what data we have collected about you over the past 12 months, including:
    • The categories of personal information we have collected about you;
    • The categories of sources from which the personal information is collected;
    • The business or commercial purpose for collecting your personal information;
    • The categories of third parties with whom we have shared your personal information; and
    • The specific pieces of personal information we have collected about you.
  • Right to Delete. You have the right to request that we delete the personal information we have collected from you (and direct our service providers to do the same). There are a number of exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:
    • Complete your transaction;
    • Provide you a good or service;
    • Perform a contract between us and you;
    • Protect your security and prosecute those responsible for breaching it;
    • Fix our system in the case of a bug;
    • Protect the free speech rights of you or other users;
    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
    • Comply with a legal obligation; or
    • Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
  • Other Rights. You can request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year. You also have the right not to be discriminated against for exercising any of the rights listed above.
  • Exercising Your California Privacy Rights. To request access to or deletion of your personal information, or to exercise any other data rights under California law, please contact us using one of the following methods:
    • Contact Us Webform: Submit your request here.
  • Response Timing and Format. We may require certain information from you in order to verify your identity and respond to your request. We aim to respond to requests for access or deletion within 45 days of receipt. If we require more time, we will inform you of the reason and extension period in writing.

Links to Third Party Websites

Our Website and some of our Services on which a link to this Privacy Policy appears contain links to third party sites and services whose privacy practices may be different than ours. We also allow you to connect with other third party sites and services. We are not responsible for the privacy practices of third party sites and services and you should consult the other third party sites’ and services’ privacy notices in order to better understand their privacy practices.


We have put in place reasonable administrative, technical, and physical safeguards to help prevent unauthorized access, maintain data security and correctly use the information we collect from and about you. However, no system can be completely secure and we do not guarantee that unauthorized disclosures and access will not happen. Although we take reasonable measures to safeguard against unauthorized disclosures of information, we cannot assure you that your personal information or other information will never be disclosed in a manner that is inconsistent with this Privacy Policy.

Children’s Privacy

Our Services are not intended for users under the age of 13, and Graham Partners does not knowingly collect information from anyone under the age of 13. No one under the age of 13 is permitted to access or use the Services or provide Graham Partners with personal information.

Changes to this Privacy Policy

This Privacy Policy may be changed by Graham Partners or its affiliates at any time and such changes will apply to information we collected from you pursuant to a previous version of the privacy policy. The revised Privacy Policy will be posted on the appropriate portion(s) of our Website or Services and will indicate at the bottom when it was most recently updated. We encourage you to periodically check back to review this Privacy Policy so that you know what information we collect, how we use it and with whom we share it.

How to Contact Us

If you have any questions or concerns about this Privacy Policy or its implementation, please contact us at