Wintergreen Advisers values the trust placed in us by our clients, not only with regard to assets under management, but also with certain personal and financial data. We collect only information that is needed to serve you and administer our business.
In the process of serving you, we become stewards of your "nonpublic personal information" - information about you that is not available publicly. This information comes to us from the following sources:
- Information you provide on documents that you may deliver to us and obtained in the course of providing advisory services for you (such as your name, social security number, address, phone number, assets, income, date of birth, occupation, etc.).
- Information we receive from third parties (such as your broker, financial planner or other intermediary you hire).
We limit the collection and use of nonpublic personal information to that which is necessary to administer our business and provide superior service.
We carefully limit and control the sharing of your information.
In order to protect customer privacy, we carefully control the way in which any information about you is shared. It is our policy to not disclose any nonpublic personal information about you or former customers to anyone, except as permitted or required by law.
We may use all of the information we collect as described above to provide advisory services to you, to open an account for you, to process a transaction for your account or otherwise in furtherance of our business. In order to service your account and effect your transactions, we may provide your personal information to other firms that assist us in servicing your account and have a need for such information, such as a fund administrator.
We require third party service providers with which we have administrative arrangements to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them. We do not otherwise provide information about you to outside firms, organizations or individuals except to our attorneys, accountants and auditors and as permitted or required by law.
We are committed to the privacy of your nonpublic personal information and use strict security standards to safeguard it.
We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your nonpublic personal information. Our operational and data processing systems are in a secure environment that protects nonpublic personal information from being accessed inappropriately by third parties.
Wintergreen Advisers uses all features of Google Analytics for Display Advertisers. That includes obtaining specific visitor cookie data, such as the source, medium and keyword used to visit our website. Google Analytics does not store any visitor specific data and we will not use visitor specific data in any way related to Google Analytics, Google Adwords, and Remarketing.
Wintergreen Advisers uses remarketing with Google Adwords and analytics to display content specific advertisements to visitors that have previously visited our site when those visitors go to other websites that have the Google Display Network implemented.
Wintergreen Advisers and other third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on visitor`s past visits to our website.
We take our users` privacy very seriously. We feel that certain personal information should always be kept private, so we`ve developed restrictions around the types of ads where we don`t allow remarketing. When creating remarketing lists, we can`t use any sensitive information about users. This includes information such as their financial status, sexual orientation, and other sensitive categories.
As adwords advertisers, we are restricted from and will not perform the following actions:
(a) Running ads that collect Personally Identifiable Information (PII) including, but not limited to, email addresses, telephone numbers, and credit card numbers
(b) Creating a remarketing list or creating ad text that specifically targets users in ways that are outlined as "prohibited" in the categories below
Visitors can opt out of Google Analytics for Display Advertisers and opt out of customized Google Display Network ads by visiting the Ads Preferences Manager.
"User" means a unique instance of a browser, application or similar technology.
"User Cookie" means the User identifier (of which a cookie is one example) associated with a User for remarketing or similar audiences.
"Remarketing Lists" means a list of User Cookies created or otherwise obtained by you and used in connection with remarketing or similar audiences.
"Similar Audiences Lists" means a list of Users created by Google based on a Remarketing List for use in connection with similar audiences.
"Properties" means properties or content on which advertisements are shown.
Creation, Migration and Use of Remarketing Lists
You must have all rights necessary to create or otherwise obtain Remarketing Lists, migrate Remarketing Lists to, and use Remarketing Lists or Similar Audience Lists on the Properties. Google will not allow another advertiser to use your Remarketing Lists or Similar Audiences Lists without your consent.
Data, Selection and Targeting Restrictions
You may not (a) send to Google information or (b) use Remarketing Lists or Similar Audience Lists to select or target advertisements (i) based on past or current activity by Users on adult or gambling sites, government agency sites, or sites directed at children under the age of 13 years or (ii) based on other inferred or actual sensitive information (including without limitation, health or medical history or information, financial status or other detailed information pertaining to a person`s finances, racial or ethnic origins, religious beliefs or other beliefs of a similar nature, the commission or alleged commission of any crime, political opinions or beliefs, trade union membership, or sexual behavior or orientation).
You may not, for the purpose of serving Ads, transmit personally identifiable information including, but not limited to, email addresses, telephone numbers, and credit card numbers ("PII") with the User Cookie without robust notice of, and the User`s prior affirmative (i.e., "opt-in") consent.
Advertising Cookies Policy; Third Party Ad Serving; Conflicts
Your use of the User Cookie via Remarketing Lists is subject to this Interest Based Advertising Policy and the Google Advertising Cookies Policy. Google`s use of Remarketing Lists is also subject to this Interest Based Advertising Policy and the Google Advertising Cookies Policy. If you`re using third-party ad serving in order to serve Interest-Based Advertisements, then you need to comply with both the Third-Party Ad Serving Policy and this Interest Based Advertising Policy. To the extent there is any conflict between this Interest Based Advertising Policy and either the Google Advertising Cookies Policy or the Third-Party Ad Serving Policy then you need to comply with the version of the conflicting provision in this Interest Based Advertising Policy.
DoubleClick Remarketing (formerly known as Doubleclick Boomerang) and other Remarketing List Services
You may not use a Remarketing List created via DoubleClick`s Remarketing or other Remarketing List services on the Properties unless the properties from which those User Cookies were compiled (i) properly disclose the data collection and usage contemplated by this Interest Based Advertising Policy and (ii) comply with the privacy and notice requirements of this Interest Based Advertising Policy.
Remarketing List Transparency
You grant to Google the right, should Google elect to do so, to display to any end user that is part of your Remarketing Lists that the User is on at least one of your Remarketing Lists, along with displaying your domain or display name.
In Ads Notice Labeling
Google may also, should Google elect to do so or should Customer request Google to do so, label advertisements served based on Remarketing Lists or Similar Audience Lists with notices or overlays intended to advise Users that the advertisements are based on Remarketing Lists or Similar Audience Lists, and you may not modify or obscure these labels.
Policies applicable to Advertisements based on Google-defined interest categories
In Ads Notice Labeling
Google may also, should Google elect to do so or should Customer request Google to do so, label advertisements served based on Google defined interest-categories with notices or overlays intended to advise Users that the advertisements are based on Google defined interest-categories, and you may not modify or obscure these labels.