Privacy & Cookie Statement

While we do our best to protect your personal information, TheEarly Investor cannot ensure or warrant the security of any information youtransmit to us, and you do so at your own risk. What does all of this mean?Just as in the investing world, you must protect yourself. You are responsiblefor maintaining the secrecy of any password and/or account information. Pleasebe careful and responsible whenever you are online, especially when using acomputer that other people can use also or if you are on an unsecured network.

Many of our advertisers or partners, such as brokerages,merchants, or data providers, link from our site to areas on their own siteswhere they sell their own products and services. If you follow links from oursite to others, you should be aware that you are doing business with thoseother sites, which have their own privacy and data collection practices. TheEarly Investor has no responsibility or liability for these independentpolicies (and we may not even know what they are). For more informationregarding a site and its privacy policies, check that site.

1. Information We Collect About You

We will collect and process the following personal data fromyou:

1.1 Information you give us

This is information about you that you give us directly whenyou interact with us.

  1. Signing     Up for Content Delivered via Email: When you sign up for a report or other     content delivered by email, we will ask for your email address. We may     also ask for your name as well as capture your IP address.
  2. Subscribing     to a Service: When subscribing to any of our newsletter or portfolio     services, or purchasing a special report, we need to know the sort of     information typically used for credit card transactions, such as your     name, address, telephone number, and credit card number and expiration     date. We encrypt all of this information using Transport Layer Security     (TLS), the replacement for the deprecated Secure Socket Layers (SSL)     technology.
  3. Stock     Information: If you rate stocks on our CAPS platform, we will save that     information and may use it to identify content that we think is relevant     to you. We may also use that information in the aggregate to help us     better understand what our community and our premium members are     interested in, so we can create and target our content better.
  4. Other     Services: We may also ask for additional information when providing other     services. If you don’t want to give us the information requested, you     certainly don’t have to, but you will not be able to take advantage of     such offerings. For example, if we launch a text alert feature, we     wouldn’t be able to send you any alerts unless you provide us with your     mobile number. Or, you may not be able to gain access to certain areas of     our site unless you register and/or subscribe. On occasion, we may also ask     you for other personal information in connection with surveys, contests or     other promotional offers running on our site, but again, your     participation in these features is purely voluntary.
  5. Information     About Others: If you use our recommendation service to email one of our     articles to a friend, you will need to provide us with your friend's email     address and your email address as a return address. We will automatically     send this person a one-time email, with the recommended article attached,     as well as invite your friend to visit and register with our site. We will     not use these email addresses for any other purpose.

1.2 Information we collect about you from using our site:

  1. While     on our site, we automatically log certain information about how you’re     using our site. This information may include the URL that you just came     from, your IP address (or a partially anonymized IP address), details     about your browser, device, OS, or probable location, and the pages you     visit while on our site.
  2. When     you visit our sites we will assign you a unique identifier so we can     recognize you across different portions of our sites. You may have one or     more of these, and they may persist between visits to our sites, so we can     recognize you when you come back.
  3. We     may place a tracking mechanism, such as a pixel or web beacon, on pages or     components of our site. This enables us to record in our server logs that     a specific user id has visited a particular page. This data allows us to     analyze and determine our audience’s behavioral characteristics, which     helps us to optimize our site, advertisement placement, and marketing     focus.

1.3 Information we receive from other sources:

  1. We may     place a tracking mechanism on pages or components of some of our partners’     sites so that when you use services from our partners, we can record that     a specific user ID visited that service. This helps us analyze our     audience in a manner similar to when you visit our own site.
  2. We     allow our advertisers and partners to collect certain information when you     visit our site by allowing them to place a tracking mechanism, such as     cookies, pixels, beacons, Google AMP Client IDs, or other technologies to     collect and use information about you during your visit to this and other     websites in order to provide advertisements they feel you would like.
  3. By     utilizing or permitting these tracking mechanisms , we prevent our     partners from fraudulently representing your internet activity, and we     ensure that we are trustworthy to our partners and advertisers about     accounting for the exchange of your personal information. To read about     your options for opting out of data sharing, please see our Opt     Out or Close Your Account section of this privacy statement.
  4. We     have also engaged third-party companies to gather and process information     about our users on our behalf, to help us improve our sites and find new     members. These companies will combine our data about how you visit our     websites with information that they have collected from outside our sites     and provide it to us so that we can optimize your experience across our     sites, across multiple devices, and based on your interests.

To learn more about this behavioral advertising, includinginformation on how to opt-out, please see our Opt Out or Close YourAccount section.

1.4 Business purposes and categories of personalinformation we collect:

Our business is constantly evolving to create and deliverthe most relevant products and services to you. We collect a variety ofdifferent personal data for numerous business reasons. For a full listing ofthose reason, please see Section 3.

1.5 Categories of third parties from which we collectpersonal information:

We collect information about you from third parties thathave information about you or about people that exhibit similarities to thedata we have collected about you. For more information, see the How WeUse Your Information section of this privacy statement.

We collect personal information about you from the followingcategories of third parties:

2. Our Legal Bases for Processing Your Information:

We can collect and process your data under one of thefollowing legal bases for our use.

2.1 Consent

We can collect and process your data with your consent.

2.2 Contractual Obligations

We need your personal data to comply with our contractualobligations.

2.3 Legal Compliance

If the law requires us to, we may need to collect andprocess your data.

2.4 Legitimate interest

We may use your data as required in the normal course ofoperating our businesses and services unless our legitimate interests areoverridden by your rights.

3. How We Use Your Information

3.1 Business Purposes for Which We Collect and UsePersonal Data:

When we have a legal basis for collecting your personalinformation , we do so from a variety of sources, including without limitationyour explicit input and interaction on our web sites, through ouradvertisements on other web sites, and through third parties that haveinformation about you or about people that exhibit similarities to the data wehave collected about you. We may combine your data with anonymized, aggregateddata to draw inferences about you or your interests. We use all this data to makeour site and our advertising relevant to you.

Business Purpose & Categories of Personal Data

Operations
To administer our site, site performance, and internal operations, such as toconduct troubleshooting, testing, and projecting usage volume and impact

Security

To keep our site safe and secure and to control access toyour account and services

Advertising

To deliver relevant advertising to you and to measure andoptimize the effectiveness of our advertising

Marketing

To keep you informed about products and services similar tothe ones you subscribe to – on our site and elsewhere on the internet

Optimization

To ensure our content, layout, and offerings are presentedin the most effective manner for you and devices

Fulfillment

To fulfill your transactions and to deliver informationabout goods and services you have requested, or that we think you would beinterested in

Personalization

To allow you to participate in interactive features of ourservices, when you choose to do so.

Research

To better understand our members, potential members, andvisitors so we can improve our products and services, and better target how wedeliver information about those products and services

3.2 Categories of Service Providers to Which PersonalData is Disclosed:

We utilize service providers to process personal informationfor a variety of purposes that would be difficult for our business to conducton our own. For example, to increase the likelihood of successfully processingyour credit card when you purchase access to one of our services, we may wishto submit a well-formatted address to the credit card company. We may send theaddress you give us to a service from the U.S. Postal Service to try to verifyyour address and provide its canonical version of your address with all thefields in the expected locations. In some states, these types of externalcompanies are called service providers. We disclose personal information aboutyou to the following categories of service providers in order to process datafor us:

In order to maintain relevant and accurate personalinformation about you, we may share your personal data, browsing habits, orother identifying information to service providers and third parties, and inreturn they may provide us with additional email addresses, names, physicaladdresses, other identifiers, browsing habits, and demographic information,which may include education level, income, investment portfolio, race, gender,personal interests you have told them about, and other personal details theyinfer about you. To read about your options for opting out of this datasharing, please see our Opt Out or Close Your Account sectionof this privacy statement.

3.3 Categories of Other Third Parties to Which PersonalInformation May Be Sold; and the Business Purposes for such “Sales”:

If you are a California resident, some of our disclosure ofpersonal information is considered a sale of data even if we don’t receivesomething of monetary value in exchange. We share personal information in thistype of “sale” with the following categories of third parties:

We share personal information with third parties in thistype of “sale” for the following business purposes:

4. Promotional Updates and Communications

Where permitted by one of the legal bases above, we will useyour personal information for marketing analysis and to provide you withpromotional update communications (e.g., by email) about our products/servicesand those of our affiliates and business partners.

To read about your options for opting out of marketing andpromotions, please see our Opt Out or Close Your Account sectionof this privacy statement.

5. How we store and retain your information

We store your data in databases and on storage servers inour own facilities, in colocation data centers, and in those of our contractedservice providers. Your data may not be stored in the country in which youreside. We typically store our data in the U.S. If you live in the EuropeanEconomic Area, please see our section for European Users.

We retain personal data for as long as necessary to fulfillany legal obligations we may have as well as for purposes of processing yourinformation for the delivery of our services (for example, if you continue tosubscribe to one of our email-based services, we will need your information toemail the service to you). We may also retain aggregate information beyond thistime for research purposes and to help us develop and improve our services. Youcannot be identified from aggregate information retained or used for thesepurposes.

6. Cookies and other technologies

Cookies contain bits of data that websites such as oursplace on your computer’s hard drive for record keeping purposes. Cookies canmake the web more useful by collecting and storing information about yourpreferences on a particular site and help websites operate more efficiently.Cookies and similar technologies enable you to be remembered when using thatcomputer or device to interact with websites and online services and can beused to manage a range of features and content as well as storing searches andpresenting personalized content.

We use our cookies:

(a) With the aim of optimizing our website and improvingmember experience. Cookies help us estimate our audience size, determine usagepatterns and help us better target content and ads based on our users’interests.

(b) We also use cookies so you can, for example, access anypremium content that you have subscribed to.

(c) You have the option of not accepting the cookies we set.However, if you reject our cookies, you will not be able to take advantage ofmost of the features on our site, including subscription-based services.

Below you’ll find the types of cookies that we set when youvisit Fool.com and their purpose. To help you better understand why we’resetting them, we’ve used the categories and definitions set by theInternational Chamber of Commerce (“ICC”):

(a) Strictly Necessary: cookies that enable the servicesthat you have specifically asked or paid for;

(b) Performance: cookies that collect information on howvisitors use our site including the pages visited and most frequented as wellas the sources of our traffic. They are used to help us improve how the siteworks;

(c) Functionality: cookies that help us remember the choicesyou have made so we can provide you with a more personalised experience; and

(d) Advertising: cookies used to deliver more relevant ads,and to make sure you don’t see the same adverts over and over again.

In addition to the cookies set directly by our partners,there are also cookies set by third parties to help deliver and monitor theirads. Please note we neither control nor have access to those cookies, and theseadvertisers’ uses of cookies are subject to their own privacy policies and notour policies.

If you follow links from our site to theirs, you should beaware that these other sites have their own privacy and data processingpractices. We have no responsibility or liability for these independentpolicies. For more information regarding a site and its privacy policiesincluding its use of cookies, check that site.

7. Cookie Removal and More Information

You can always modify your browser so as not to acceptcookies or to notify you when cookies are sent to it. For more informationabout cookies including removing any or all of your cookies, please visit http://www.allaboutcookies.org.

Also, if you would like to remove the Google Analytics andDoubleClick cookies, please go to http://tools.google.com/dlpage/gaoptout and http://www.google.com/ads/preferences/plugin/ respectively.You should be aware that this will affect your Google cookies on all sites, andnot just ours.

Some of our sites are affiliated with AdThrive, anadvertising partner. They, and others, use cookies collected from a variety ofsites to gather data about visitors. You can view, delete or add interestcategories associated with your browser by visiting: https://adssettings.google.com.

8. Update or Correct Your Information

If you want to change your email address for delivery ofyour paid-for newsletter email subscriptions (e.g. Stock Advisor,or ONE), or you would like to change your password, you should goto your accounts page.

9. Opt Out or Close Your Account

  1. Marketing     & Promotions. If you would rather not hear from us by email, you can     object to further marketing at any time by: (i) checking and updating your     contact details within your account page .;     (ii) selecting the "unsubscribe" link at the end of all our     marketing and promotional update communications to you.
       
        Please note: If you are paying for one of our services, please note that     clicking the “unsubscribe” link will not cancel your paid subscriptions,     but it is likely to affect deliverability of your newsletter messages,     announcements, or other product related communications. If you purchase     products or services from us, or if you register for an account with us,     we may contact you to confirm your purchase, subscription, or     registration, or to provide you with information about its terms or     features. You may wish to keep these transactional or relationship emails,     to help you use our products and services.
  2. Behavioral     Advertising. To learn more about this behavioral advertising, including     information on how to opt-out, please:

(a) visit the DAA opt-out program,the Evidon opt-out program, and the GoogleAnalytics opt-out program to learn how to opt out of having yourinformation collected in browsers for ad serving purposes;

(b) download the Evidon Ad Control application, availablefor iOS and Android, to learn how to opt out of having your informationcollected in mobile apps;

(c) see the interests associated with you by Google at https://adssettings.google.com;and

(d) visit the NetworkAdvertising Initiative’s opt out page.

Please remember that some or all of these opt-out mechanismsuse cookies to remember you have opted out, and if you delete cookies from yourbrowser your opt-out will also be deleted.

  1. Consent     Withdrawal. Where the processing of your personal information by us is     based on consent, you can withdraw consent at any time by: (i) checking     and updating your Data Preferences within your account page.
  2. Cancel     Your Subscription. If you want to cancel your subscription to one or more     of our services but do not wish to remove your account entirely at this     time, please contact us at.
  3. Close     Your Account Permanently. If you want to close your account - i.e., so     that it cannot be logged into - please go to this form: ‍

10. Security and Protection of Your Information

We are committed to protecting your personal information.All information that you provide to us is stored on our secure servers. Accessto paid-for areas of the site, such as our newsletter services ispassword-protected for your privacy and security. While we do our best toprotect your personal information, we cannot ensure or warrant the security ofany information you transmit to us, and you do so at your own risk. What doesall this mean? Just as in the investing world, you must protect yourself. You areresponsible for maintaining the secrecy of your passwords and/or any accountinformation. If you need to change your password, please follow the stepsoutlined below.

Unfortunately, the transmission of information via theinternet is not completely secure. Although we will do our best to protect yourpersonal data, we cannot guarantee the security of your data transmitted to oursite; any transmission is at your own risk. Once we have received yourinformation, we will use strict procedures and security features to try toprevent unauthorized access.

Our site may, from time to time, contain links to externalsites. We are not responsible for the privacy policies or the content of suchsites.

11. Users Aged 13 or Under

Protecting the safety of children when they use the internetis important to us.

The site is intended for use only by persons who are atleast 13 years of age. By using this site, you confirm to us that you meet thisrequirement. If you are aged 13 or under, please get your parent/guardian’spermission beforehand whenever you provide personal information to our website.Users without this consent are not allowed to provide us with personalinformation.

If you are under the age of 13 your parent or guardian mustconsent on your behalf where we ask for consent in relation to the use of yourinformation.

12. European Users

For the purposes of European Economic Area data protectionlaw, (the "Data Protection Law"), the data controller is: The EarlyInvestor, LLC

12.1 Use of Cookies

Our site places cookies on your device for a variety ofpurposes described in the Cookies and Other Technologies section of thisprivacy statement. Please refer to that section for more information aboutthose cookies and how to prevent the use of cookies.

If you have any questions about the cookies we set, pleasecontact our Data Protection Officer at [email protected].

12.2 Data Storage

The data that we collect from you is transferred to, and maybe stored at, a destination outside the European Economic Area("EEA") that is not subject to equivalent Data Protection Law. Forour purposes, the information we collect is processed and stored in the US.

We may transfer your personal information outside the EEA:

Where your information is transferred outside the EEA, wewill take all steps reasonably necessary to ensure that your data is subject toappropriate safeguards, such as relying on a recognised legal adequacymechanism, and that it is treated securely and in accordance with this privacypolicy.

12.3 European site users have certain rights undercertain circumstances:

12.4 Your right to withdraw consent:

Where the processing of your personal information by us isbased on consent, you have the right to withdraw that consent withoutdetriment. You can withdraw consent online or by contacting us. For moreinformation on this or other options to manage your privacy rights, please seethe Opt Out or Close Your Account section of this privacystatement.

You can also exercise the rights listed above at any time byfilling out 

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html).

13. Changes to this Policy

We may amend this Privacy and Cookie Statement from time totime. Please check back regularly to review your rights and to check theEffective date or Last Updated date listed below. If we make any substantivechanges to this policy, we’ll announce it on our site and notify you by email.

14. Contact Us

Questions, comments and requests regarding this privacy andcookie policy are welcomed and should be addressed to:

Data Protection Officer
The Early Investor, LLC
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Contact us for more
Early Investor respects your privacy and strives to be transparent about our data collection practices. We use your information to customize the site for you, to contact you about your membership, provide you with promotional information, and in aggregate to help us better understand how the service is used. Past performance is not a predictor of future results. Individual investment results may vary.

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