PRIVACY POLICY

Updated November 6, 2020

General Statement:

Evergreen-Partners, LLC d/b/a Evergreen Trading (“ET”) has implemented this Privacy Policy to provide our clients and other visitors (collectively, “Users”) who use the website (www.evergreentrading.com) (the “Website”) with information regarding the collection and use of Information (as defined below) that we collect either through the Website or in our other business operations. For purposes of this Privacy Policy, “you” or “your” refers to you as a User of this Website. “We”, “our” or “us” refers to ET.

Collected Information:

ET collects two types of information on this Website: (i) User Information; and (ii) Technical Information. Each of these is defined and explained below and sometimes is collectively referred to herein as “Information.” In its business operations, ET collects certain Personal Information concerning its employees and business contacts. ET does not generally collect Personal Information from or concerning consumers. In this regard, Personal Information means any information that can reasonably identify an individual or household, as defined under relevant law.

User Information:

From time to time in the course of your use of this Website, we may ask you to provide your name, email, address, telephone number and other personal identifying information (collectively, “User Information”). You may also provide ET with third-party personal information, such as first and last names, email, address, phone numbers and similar information about other individuals such as your employer, colleagues or clients. You should only provide information about another person if you have his or her permission to do so. That information will only be used for the purpose for which it was collected and will also be treated as User Information.

Technical Information: 

ET also uses cookies and web beacons (also known as “clear gifs”—small single-pixel image files that can be used to recognize a user’s navigation through a website) to collect information for record-keeping purposes and to make it easier to navigate the Website. Cookies are small text files that are stored on Users’ computers. For more information about cookies and web beacons, please see www.allaboutcookies.org. ET uses both “session ID cookies” and “persistent cookies.” A session ID cookie expires when you close your browser. Persistent cookies stay on your computer from one session to the next and enable ET to recognize you when you return to the Website. You may choose not to receive cookies from ET by following instructions in your web browser’s “help” file, but this may make certain features of the Website inaccessible to you.

ET also collects Users’ IP addresses and basic log file information (such as browser type and language, number of clicks, domain names of web sites visited, pages viewed, the amount of time spent on particular pages, the date and time of visits and page views). This Information, including information about cookies, is referred to as “Technical Information” in this Privacy Policy. ET uses Technical Information (and may combine it with User Information) to help locate potential problems with our server, improve and customize your experience on the Website and other purposes described in the “How We Use Your Information” section below.

Web Analytics: 

ET may use Google Analytics to collect information about your use of the Website. Google Analytics collects certain information, such as how often you visit the Website, the pages you visit, and the other websites you use prior to visiting the Website. ET may use the information received from Google Analytics to improve the Website. Google Analytics collects only the IP address assigned to you on the date you visit the Website, rather than your name or other identifying information. ET does not combine the information collected through the use of Google Analytics with any other information collected from you. Although Google Analytics stores a permanent cookie on your machine to identify you as a unique user the next time you visit the Website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use available at http://www.google.com/analytics/tos.html and the Google Privacy Policy available at http://www.google.com/intl/en/analytics/privacyoverview.html. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.

How We Use Your Information:

If you provide User Information to us, then we use this Information to operate, maintain provide and improve the features and functionality of the Website and any products or services requested. We use the Personal Information we collect concerning employees and business contacts for our business purposes, such as communicating with our clients and providing our employees with benefits.

ET will contact you using the email address you have provided to send you messages if you have agreed to receive them, including advertising, information about changes to ET features and any special offers.

We use Technical Information, such as Website use date and IP addresses, to improve the quality and design of the Website and to create new features and services by storing, tracking and analyzing your preferences and trends. We may use such Information to: (i) remember information so that you will not have to re-enter it during your current or subsequent visits to the Website; (ii) provide customized content and information; (iii) monitor the effectiveness of our marketing campaigns and aggregate metrics such as total number of visitors and traffic; (iv) diagnose or fix technology problems; (v) access information about you after you log onto the Website; (vi) market our Website to advertisers and other third parties; (vii) aggregate general User statistics including demographic and geographic information; and (viii) comply with such other lawful purposes so long as your personal identity is not revealed by such use.

As part of this process, ET uses third parties to provide it with aggregated Technical Information about how Users interact with the Website and may set cookies, web beacons or other tracking technologies for this purpose. The use of cookies by our service providers (e.g., Google) is not covered by our Privacy Policy. We do not have access or control over these cookies.

We also have testimonials on our Website. All personal information contained in testimonials has been pre-approved by the applicable individual prior to posting on our Website. If you wish to update or delete your testimonial, you can contact us at marketing@evergreentrading.com.

Communications:

Promotional Emails:

If you wish to subscribe to our promotional mailings, we will use your name and email address to send such mailings to you. These mailings will include an unsubscribe option that you can use at any time. If you wish not longer to receive these mailings, you can also e-mail us at marketing@evergreentrading.com.

Service-Related Announcements:

On rare occasions when it is necessary to do so, for example if our service is temporarily suspended for maintenance, we might send you an email or post an announcement on the Website.

When We Share Information:

Except as expressly described below, ET will not share your Information with advertisers or unaffiliated third parties without first obtaining your express permission or as required by law.

We may provide Information to our subsidiaries, affiliated companies, subcontractors and third parties with whom we have entered into a co-marketing, partnering or similar commercial arrangement so that such parties may, among other things: (i) help us to provide services and/or process Information on our behalf; (ii) use the Information to offer greater functionality and enhanced services through the Website or to provide you with additional product and service opportunities; and (iii) communicate these opportunities to you on our behalf. When we do this, the recipients of your Information have bound themselves to privacy requirements that are at least as restrictive as this Privacy Policy. We do not share, sell, rent or trade Personal Information with third parties for their promotional purposes.

We may also provide Information to third parties if we reasonably believe that such Information is necessary to: (i) satisfy any applicable law, regulation, legal process or enforceable government request; (ii) enforce this Privacy Policy or any applicable terms of service; (iii) detect, prevent or otherwise address fraud, security or technical issues; and (iv) protect against harm to the rights, property or safety of ET, or others.

We may share Technical Information (such as Website use data) with third parties to assist them in understanding our Website, including Users’ use of our Website and services. The Technical Information provided will not identify you by name.

ET reserves the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to require that the transferee use the Personal Information in a manner that is consistent with this Privacy Policy.

ET does not and will not sell your Personal Information.  ET does not and will not sell the Personal Information of a California resident it has actual knowledge is under the age of 16.

Links to Third-Party Sites:

Our Website includes links to other web sites whose privacy practices may differ from those of ET. After you choose to follow the link and leave the Website, ET is not responsible for the content of those websites, or their privacy policies. If you submit personal information to any of those sites, your information will be governed by their privacy policies. We encourage you to carefully read the privacy policy of any web site you visit. ET cannot be held liable for what information they collect, or how they choose to use that information, as their respective privacy policies control your use of their website.

Blog/Forum:

Our Website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected and used by others who access the blogs or forums. To request removal of your personal information from our blog or community forum, contact us at marketing@evergreentrading.com.

Social Media Widgets:

Our Website includes Social Media features, such as “Facebook” and “Twitter” buttons. These features may collect your IP address and which page you are visiting on our Website, and may set a cookie to enable the feature to function properly. Social Media features and widgets are either hosted by a third party or hosted directly on our Website. Your interaction with these features is governed by the privacy policy of the company providing it.

Tracking Disclosure:

We do not respond to web browser “do not track” signals or other similar mechanisms.

Our Commitment to Children’s Privacy:

Protecting the privacy of young children is especially important and is mandated by applicable law. For these reasons, ET does not knowingly collect User Information on the Website from persons under 13 years of age and no part of our Website is directed to persons under 13. If you are under 13 years of age, then you must not use or access the Website at any time or in any manner or provide any information to the Website. If your child has submitted User Information to us, please contact us as provided under the section “Contact Information” below so we can arrange to remove your child’s User Information from our database. Do not supply to us or disclose on the Website any Information of any person under 13 years of age as we do not intend to collect information from anyone under 13 or invite them to use this Website.

International Users:

The Website is hosted in the United States. If you are accessing the Website from outside the United States, you are transferring your Information to the United States and you consent to that transfer. If you do not want your Information transferred to the United States, you should not share your information with us or make use of this Website.

Your Rights:

You may decline to submit User Information to the Website, in which case, you may not be able to utilize all of the features and functionality of this Website and ET may not be able to provide certain information, services or products to you.

Except with respect to notices required by law, transaction and service-related emails, you may opt out of receiving any promotional correspondence by clicking on the “Unsubscribe” link at the bottom of every email we send to you, or by sending your request in writing via email to marketing@evergreentrading.com.

Data Rights

Subject to applicable law, you may have the right to request and obtain information about, or copies of, your personal information that we process, where we obtained your information, the business or commercial purpose for collecting your information, and the third parties with whom your information is shared. Lastly, you may ask us to delete personal information that we have collected from you, depending on the situation and applicable laws.

All of our processing is in support of our business. Where we process your data based upon your consent, we recognize that you may withdraw consent if you wish to do so, and that you retain a right to your own data.

Residents of California have the following rights with respect to their personal information, in certain circumstances:

• The right to know the categories and specific pieces of personal information we have collected about you in the past 12 months, the sources from which the personal information was collected, and the business purpose for collecting such information;
• The right to know whether and how we sell or disclose your personal information, to whom we sell or disclose your personal information, and the business purpose for disclosing your personal information;
• The right to request a copy of the specific pieces of personal information we have collected about you in the past 12 months;
• The right to request that we not sell your personal information;
• The right to request that we delete the personal information that we have collected from you, in certain circumstances; and
• The right not to receive discriminatory treatment for the exercise of your privacy rights.

You may enquire about these rights by contacting us at marketing@evergreentrading.com.

Currently, the vast majority of personal information that ET collects is not subject to the rights noted above, but it may be in the future. If that occurs, we will provide you relevant notice in a revised Privacy Policy.

Upon receipt of a request to exercise your rights, we may request additional information in order to verify your identity. To the extent possible, we will utilize information already in our possession to verify your identity. Any information you provide in connection with such verification will be deleted as soon as practicable following your request.

You may designate an authorized agent to make a request on your behalf. If you submit a request through an authorized agent, we may require that the authorized agent provide proof that the authorized agent has been authorized by you to act on your behalf and may still require you to verify your identity in accordance with the above.

The chart below summarizes our practices in relation to your personal information over the preceding 12 months.

Passwords:

We may assign to you, or ask you to select, a password and username in connection with your use of certain features of the Website or the provision of products or services to you. You can change your password and username at any time. If we assign a password to you, you should change that password as soon as possible to ensure that your password is something you will remember and that is unique to you. You acknowledge that you are responsible for protecting your password and ensuring that you do not disclose your password to others. If your password is disclosed to others, they will be able to access your User Information and otherwise interfere with your use of this Website and any products or services. If you become aware that your password has been improperly disclosed or used by others, you should immediately change your password. If you believe someone is, or has been, using your username or password for unlawful or improper purposes, please contact us as provided under the section “Contact Information” below.

Our Commitment to Data Security:

We follow commercially reasonable standards to protect the Information submitted to us both during transmission and once we receive it., including administrative, technical and physical protections concerning such Information. However, no method of transmission over the Internet or method of electronic storage is 100% secure, and therefore we cannot guarantee that unauthorized third parties will never be able to access and use your Information for improper purposes. Accordingly, you acknowledge that you provide your Information at your own risk.

Notification Procedures:

It is ET’s policy to provide notifications where such notifications are required by law to Users via email notice, written or hard-copy notice or through conspicuous posting of such notice on our Website, as determined by ET in its sole discretion. ET reserves the right to determine the form and means of providing notification required by law to our Users, provided you may opt out of certain means of notification as described in this Privacy Policy.

Contact Information:

Evergreen-Partners, LLC d/b/a Evergreen Trading

99 Hudson Street, 14^th Floor

New York, NY 10013

Attention: Website Support

Email: marketing@evergreentrading.com

Changes to Privacy Policy Statement:

ET reserves the right to modify this Privacy Policy at any time. When it does, ET will revise the “last updated” date on the first page of the Privacy Policy and will post the changes on our Website.