Effective Date: March 22, 2024

1. Introduction

We at Red Clover Advisors, LLC or our affiliates (“Red Clover,” “we”, “our” or “us”) are committed to protecting your privacy and keeping your information safe. This Privacy Notice (“Notice”) describes how Red Clover handles and protects your Personal Information, our purposes for collecting Personal Information and the rights you have over it. If you have questions about this Notice or our practices, please contact us at info@redcloveradvisors.com.

2. Scope

This Notice applies to www.redcloveradvisors.com, including all subdomains that link to this Notice (“Site”); or any time you interact with us or use our services online or in-person. We refer to all of the above as our “Services.” For the purpose of this Notice, “Personal Information” means any information that identifies, relates to or can reasonably be linked to an identified or identifiable individual, as defined by applicable legislation. By using our Sites or otherwise using our Services, you acknowledge this Notice and agree to our Terms of Service (“Terms”).

3. What Information We Collect

Red Clover only collects Personal Information that is relevant and reasonably necessary for us to provide our Services to you. The chart below shows what types of Personal Information we collect, the purpose for the collection, from whom we have collected it and with what types of organizations we share it.

The categories of Personal Information we collect from you depends on how you interact with our company, your “persona.”

Personas

  • Clients: Individuals who have created an account with us and currently use or have used our Services.
  • Prospects: Individuals who have visited our Site, attended events or otherwise interacted with Red Clover marketing, social and networking events, digital ads and content, emails, or other communications under our control.
  • Website Visitors: Individuals who visit our website and do not fall into the personas above and about whom we may collect information through tracking technologies, site analytics tools, information they may include in a webform.

Information You Provide

As you interact with our Site or Services, we may collect the following Personal Information via the webforms or inputs/uploads on our Site, and through telephone calls, letters, emails and other communications with you:

  • Contact and account information. We may collect information such as your first and last name, email address, home or business address, telephone numbers, mobile numbers and password;
  • Financial information. Related to our services performed, we may collect information such as your credit card or debit card number, bank account information and your payment, service and purchase history;
  • Social media information. We may collect information such as social media handles, content and other data shared with us through third-party features that you use on our Site or Services (such as tools, widgets and plug-ins offered by social media services like LinkedIn, Facebook, Instagram, X and YouTube) or posted on social media pages (such as our social media page or other pages accessible to us); and/or
  • Other information. We may collect other information that could reasonably be used to identify you personally or identify your household or device.

Category of Personal Information

Personas

Examples

Purpose(s) for collection

Sources

Categories of third parties with which we disclose or sell PI

Identifiers and contact information Clients
Prospects
Website Visitors
Real name, alias, postal address, unique personal identifier, online identifier, Internal Protocol address, email address, account name.
  • To provide, improve and market our products and Services
  • To provide information you requested
  • To identify potential customers
  • To verify identity
  • To prevent fraud
  • To comply with law
You Service Providers
Commercial information Clients Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • To provide, improve and market our products and Services
  • To provide information you requested
  • To identify potential customers
  • To verify identity
  • To prevent fraud
  • To comply with law
You Service Providers
Internet or other electronic network activity information Prospects
Website Visitors
Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
  • To provide, improve and market our products and Services
  • To provide information you requested
  • To identify potential customers
  • To verify identity
  • To prevent fraud
  • To comply with law
Automatically Service Providers
Sensory data Clients
Prospects
Audio, electronic, visual, thermal, olfactory, or similar information.
  • To provide, improve and market our products and Services
  • To provide information you requested
  • To identify potential customers
  • To verify identity
  • To prevent fraud
  • To comply with law
Automatically N/A
Professional /  employment-related information N/A Current or past job history or performance evaluations N/A N/A N/A

We do not collect the following categories of Personal Information: Characteristics of Protected Classifications, Biometric Information, Geolocation Data, Non-Public Education Information, Inferences Drawn from other Personal Information or Sensitive Personal information.

Information Collected Automatically

Like many businesses, we and our service providers may automatically collect and/or store certain information when you visit or interact with the Site or Services (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. Usage Information may include:

  • Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
  • Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);
  • Referring and exit web pages and URLs;
  • The areas within the Site that you visit and your activities there, including remembering you and your preferences;
  • Your Device location or other location information, including the zip code, state or country from which you accessed the Site or Services;
  • Your Device characteristics (such as device type (computer vs. mobile) and ID, operating system, hardware);
  • Certain other Device data, including the time of day you visit our Site or other information used to provide analytics or other usage information;
  • Information about your engagement with our emails; and
  • Statistical information about how both unregistered and registered users, collectively, use the Site and Services. This aggregate information is derived from Personal Information but cannot be tied back to you or your web browser.

Information Collected from Third Parties

The Site may include functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we might obtain information about the traffic and usage of our Site from third parties. These third parties also use cookies and other tracking technologies to capture information about your interactions with Red Clover. Red Clover does not have control over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.

Information You Provide 

As you interact with our Site or Services, we may collect the following Personal Information via the webforms or inputs/uploads on our Site, and through telephone calls, letters, emails and other communications with you:

  • Contact and account information. We may collect information such as your first and last name, email address, home or business address, telephone numbers, mobile numbers and password;
  • Financial information. We may collect information such as your credit card or debit card number, bank account information and your payment, service and purchase history; 
  • Social media information. We may collect information such as social media handles, content and other data shared with us through third-party features that you use on our Site or Services (such as tools, widgets and plug-ins offered by social media services like Facebook, Instagram, Twitter and YouTube) or posted on social media pages (such as our social media page or other pages accessible to us); 
  • Employment information. If you apply for employment with us, we may collect information such as your current or past employment or educational information, as well as references and referrals provided to us; and/or
  • Other information. We may collect other information that could reasonably be used to identify you personally or identify your household or device.

Information Collected Automatically 

Like many businesses, we and our service providers may automatically collect and/or store certain information when you visit or interact with the Site or Services (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. Usage Information may include:

  • Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
  • Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);
  • Referring and exit web pages and URLs; 
  • The areas within the Site that you visit and your activities there, including remembering you and your preferences;
  • Your Device location or other location information, including the zip code, state or country from which you accessed the Site or Services;
  • Your Device characteristics; 
  • Certain other Device data, including the time of day you visit our Site or other information used to provide analytics or other usage information;
  • Information about your engagement with our emails; and
  • Statistical information about how both unregistered and registered users, collectively, use the Site and Services. This aggregate information is derived from Personal Information but cannot be tied back to you or your web browser.

Information Collected from Third Parties

The Site may include functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we might obtain information about the traffic and usage of our Site from third parties. These third parties also use cookies and other tracking technologies to capture information about your interactions with Red Clover. Red Clover does not have control over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.

4. Our Purposes And Legal Bases For Collecting Information

Business Purposes for Processing Personal Information

Red Clover only collects Personal Information where we have identified a business purpose for the collection and we only collect information that is proportionate, relevant and necessary for that purpose. We collect Personal Information in order to:

  • Provide our services and process payments
  • Communicate with you, respond to inquiries, engage with comments on our Site, send you information on our products, promotions, and events.
  • Improve our Site, or Services, analyze the use of our Site to improve user experience, collect information about our Services and your satisfaction with them.
  • To create profiles that help us provide you with advertisements relevant to your interests.
  • To detect, prevent and investigate illegal activity, security vulnerabilities and fraud.
  • To comply with applicable laws and regulations
  • To enforce our terms, agreements or policies
  • Any other purpose with your consent

Legal Bases For Processing Personal Information

We rely on the following legal bases for processing your Personal Information:

  • Contract: To conclude or perform a contract with you; for example:
    • To provide our Services;
    • To manage our accounts and records;
    • To handle your inquiries and requests;
  • Legitimate Interests: We process your Personal Information for our legitimate interests, where they do not override your rights and freedoms. You have the right to object to processing that is based on our legitimate interests, as described in the “Your Privacy Rights” section of this Notice. Examples of legitimate interests include:
    • To respond to your customer service inquiries and requests for information;
    • To maintain, improve, and analyze our Site and Services we offer;
    • To conduct marketing activities;
    • To detect, prevent, or investigate security breaches or fraud; and
    • To facilitate the functionality of our Site;
  • Legal Compliance: To comply with our legal obligations; for example:
    • To maintain appropriate records for internal administrative purposes and as required by applicable law, and
  • Consent: We process your Personal Information where you have given us permission to do so. For example, we will only send you information on sales and promotions where you have opted in to receiving those communications. Whenever processing is based on consent, you may withdraw your consent at any time.

5. Cookies And Other Tracking Technologies

We use cookies, pixels and other tracking technologies (“Tracking Technologies”) to recognize your browser or device, learn more about your interests and deliver our Site and Services to you. Tracking Technologies may set, change or modify settings or configurations on your device.

We may use the following types of cookies:

  • Strictly necessary cookies. These cookies are essential for you to browse the Sites and use its features, such as accessing secure areas of the site.
  • Functionality cookies. Also known as “preference cookies,” these cookies allow the Sites to remember choices you have made in the past, like what language you prefer, or what your user name and password are so you can automatically log in.
  • Analytics cookies. Also known as “performance cookies,” these cookies collect information about how you use a website, like which pages you visited and which links you clicked on. Their purpose is to improve website functions. This includes cookies from third-party analytics services if the cookies are for the exclusive use of the owner of the website visited.
  • Advertising cookies. These cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These cookies can share that information with other organizations or advertisers. These are persistent cookies and almost always of third-party provenance.

The Site may contain links to other websites. Red Clover is not responsible for the privacy practices of such other websites. None of the links on the Site should be deemed to imply that Red Clover endorses or has any affiliation with the links. To learn about the ways these other sites handle your Personal Information read their respective privacy notices.

Controlling Cookies

You can opt out of non-essential cookies by enabling an opt-out preference signal on your browser or opting-out of cookies in our Sites’ cookie preference centers.

You can control the use of cookies on most web browsers, use the links below to modify your web browser’s settings on the most popular browsers:

You can block Google Analytics from accessing your online activity with a browser add-on here.

To opt out of targeted advertising cookies, please update your Cookie Settings. More resources are also available from the Digital Advertising Alliance or the Network Advertising Initiative. We do not control these opt-out links or whether any organization chooses to participate in these opt-out programs.

Note that if you turn cookies off, you may not be able to benefit from the full functionality of our Sites. Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, ads based on the website you are viewing (e.g., contextually based ads), or ads that are not targeted at you and may be less relevant. Also, if your browser (like some Safari browsers) is configured to reject opt-out cookies when you opt out on the DAA or NAI websites, your opt-out may not be effective.

6. Disclosures Of Personal Information

Services Providers

We share your Personal Information with our third-party service providers who provide services such as website hosting, data analysis, information technology, email delivery, online advertising, auditing, and other services.

Third Party Advertising

We share information about your use of our Site and Services, and your interaction with our ads on other websites with our advertising partners to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other technologies (which you may consent to, depending on your location).

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s educational page here.

You can opt out of targeted advertising by visiting the following:

Other

We may also share Personal Information in the following circumstances:

  • As part of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in bankruptcy or similar proceedings).
  • Where required to do so by law or in the good faith belief that such action is appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
  • For any other purpose with your permission or as directed by you.
  • Where the information is aggregate information that does not identify or otherwise relate to an individual, unless we are prohibited from doing so under applicable law.

7. Your Choices About the Information We Collect

Communications Preferences

We prefer to keep your Personal Information accurate and up to date. If you would like to change your contact information, please contact us using the information in the Contact Us section below. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).

You can opt out of receiving marketing emails from us at any time. You will still receive transactional messages from us. To manage your email preferences with us, please click on the Unsubscribe link in any email you receive from us or contact us using the information in the Contact Us section below. Your choice will not affect our ability to share information in the other ways described in this Policy.

Do Not Track

Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally agreed upon standard for what an organization should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here.

Opt-Out Preference Signals

Some browsers and browser extensions support opt-out preference signals such as the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. In certain regions, when we detect such a signal, we will make reasonable efforts to respect your choices as required by applicable law.

8. Retention Of Personal Information

Red Clover will retain your Personal Information only for as long as is necessary for the purposes it was collected as explained in this Notice or as legally obligated.

We utilize the following criteria to determine the length of time for which we retain Personal Information:

  • The nature and length of our relationship with you;
  • The business purposes for which the information was collected;
  • Legal obligations or contractual commitments;
  • As necessary to defend against potential legal claims;
  • As necessary to detect or prevent potential illegal activity, secure our systems and online environment, or protect health and safety;
  • The privacy impact on individuals of ongoing retention; and

9. Children’s Privacy

Our Site is not intended for use by children under the age of 18. We do not request, or knowingly collect, any personally identifiable information from children under the age of 18. If you are the parent or guardian of a child under 18 who you believe has provided her or his information to us, please contact us using the information in the Contact Us section below to request the deletion of that information.

10. Visitors To The Site Outside Of The United States

This Site is operated in the United States. If you are visiting the Site from a location outside of the U.S., your Personal Information will be maintained on web servers and systems located within the U.S. The data protection laws in the United States may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States.

11. Security

We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from the Site, and you provide us with your information at your own risk.

12. Your Privacy Rights

Certain regions provide data subject rights (“Privacy Rights”) to individuals resident in them; for example, the EU, Canada, the U.K., and certain U.S. states. Depending on where you reside, you may have the following rights:

  • To know whether we process your Personal Information;
  • To know the categories of Personal Information we collect about you, the purposes for the collection, how long we retain your Personal Information, and whether that information is sold or shared or disclosed and to whom;
  • To request access to your Personal Information, request a copy of your Personal Information or have your Personal information transferred to another controller;
  • To request deletion of your Personal Information;
  • To request rectification of your Personal Information;
  • To opt out of the sale or sharing of your Personal Information;
  • To limit the use of your Sensitive Personal Information;
  • To opt out of some types of Automated Decision-Making (ADM), including profiling, or to request human intervention or information about how ADM is conducted;
  • Not to be discriminated against for exercising your privacy rights; and
  • To withhold or withdraw consent for the processing your Personal Information

Right To Access And Portability

Some individuals have the right to request access to their Personal Information and to obtain a copy of their Personal Information.

Right To Deletion

You may have the right to request that we delete some or all of the information that we hold about you. Depending on the applicable laws, the type of information and the method of collection, there are exceptions to the right to deletion. For example, we may have a legal obligation to retain your Personal Information for tax or other reasons.

Right To Rectification

You may have the right to request that we correct the information we hold about you (rectification). We encourage you to regularly review your information, as we aspire to have only accurate, relevant and up-to-date information. If you feel that the Personal Information we hold about you is inaccurate or incomplete you may change it by logging into your account or submitting a request using the methods below.

Right to opt out of sale, sharing, targeted advertising and other processing

You may have the right to opt out of certain uses of your Personal Information, for example, selling, sharing, direct marketing or targeted advertising. You can see what information we sell or share in the Disclosures of Personal Information section above.

We do not sell Personal Information, but we recognize that some privacy laws define “Personal Information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.” To opt-out of this, please update your Cookie Settings.

Right To Limit Use Of Sensitive Personal Information

You may have the right to limit the use of Sensitive Personal Information. Currently, Red Clover does not collect Sensitive Personal Information about Clients, Prospects or Website Visitors.

Right Not To Be Discriminated Against

We will not discriminate against you for exercising any of your privacy rights. For example, unless the difference is reasonably related to the value of your Personal Information to Red Clover, we will not

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

13. Exercising Your Privacy Rights

You or your authorized agent may make a request to exercise your rights over your Personal Information by contacting us using the information in the Contact Us section below.

You may use an authorized agent to submit your privacy rights request; however, we are obligated to ensure you have properly authorized the agent to act on your behalf and we may require proof of the written authorization.

In order to honor your rights requests, we may require you to confirm your identity and your residency or location. If we are unable to verify your identity, we may not honor your request. Where we deny a privacy rights request, we will notify you of the reason for the denial within 30 days of receiving the request.

If you disagree with our decision not to honor your privacy rights request, you may appeal the decision using the contact information provided below or submit a complaint to your local privacy or data protection regulator.

14. Data Sharing for Direct Marketing Purposes

California Civil Code §1798.83 further permits California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your Personal Information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at info@redcloveradvisors.com.

15. Changes To This Privacy Notice

We may change this Privacy Notice at any time. We will post all changes to this Notice on this page and will indicate at the top of the page the modified Notice’s effective date. We encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy practices. If required by the applicable law, we will notify you of the changes.

16. Contact Us

If you have any questions or suggestions regarding this Notice, please contact us as follows:

Red Clover Advisors
4780 Ashford Dunwoody Road, Suite 540 #207
Atlanta, Georgia 30338

Email: info@redcloveradvisors.com