Purpose.

Smolin,  Lupin & Co., LLC (“Company”, “we”, “us”, or “our”) respects your privacy and is committed to protecting it. Toward that end, we have adopted this Privacy Policy to inform you what information about you we collect when you use our website www.smolin.com (the “Website”).

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit or use our website and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Privacy Policy applies to information we collect through our website, which may include information in e-mails, forms, or other electronic messages between you and our website when you voluntarily submit the information through our website. The Privacy Policy also applies to information we may collect through our website using certain automated technologies (described below). This Privacy Policy does not apply to any other website operated by us or any third party.

Acceptance of This Privacy Policy.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. YOUR USE OF OUR WEBSITE MEANS THAT YOU ACCEPT THE TERMS OF THIS PRIVACY POLICY. YOUR CONTINUED USE OF OUR WEBSITE AFTER WE MAKE CHANGES TO THIS PRIVACY POLICY SHALL BE DEEMED TO BE YOUR ACCEPTANCE OF THOSE CHANGES SO YOU SHOULD PERIODICALLY CHECK THIS PRIVACY POLICY FOR UPDATED VERSIONS. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY OR OUR TERMS OF USE, WHICH ARE INCORPORATED HEREIN BY REFERENCE, YOUR CHOICE IS TO NOT USE OR ACCESS OUR WEBSITE. BY USING OUR WEBSITE, YOU ALSO REPRESENT THAT YOU ARE AT LEAST THE AGE OF MAJORITY IN YOUR STATE OR COUNTRY.

Changes to This Privacy Policy.

We may make changes to this Privacy Policy. We reserve the right, at our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. We will post any revised Privacy Policy on the Website. Please check this page for updates periodically. Your use of the Website following any posted changes will indicate your acceptance of such changes.

Information We Collect About You and How We Collect It.

We collect several types of information from and about users of our website, including:

• information which identifies you personally, such as your first or last names, email address, postal address, telephone number, job title, and/or company name (“personal information”); and
• information that is about you but, by itself, does not identify you personally, such as the type of device you may be using (mobile, tablet, desktop) to visit or access our website, your operating system, your web browser type, the pages on our website you viewed, the frequency of your visits to our website, your connection speed, and the date(s) and time(s) you may have visited our website; and
• any other information you voluntarily provide to us in your communications with us (via e-mail, secure server, faxes, mail, etc.).

The categories of Personal Information we collect include identifiers (e.g., names, email address) and internet activity (e.g., IP address).

We collect both types of information described above either:

• Directly from you when you provide it through our website such as by registering for our Client Portal through our website, signing up for e-mail newsletters from our website, completing forms on our website, or sending us emails or messages through our website;
• Directly from you through other means that we make available at our discretion and that you elect to utilize; or
• Automatically as you navigate through our website. Information collected automatically may include your usage details, Internet protocol address (“IP address”), and information collected through cookies, web beacons, and other tracking technologies.

Information That You Provide to Us.

Any electronic communication sent to us through our website or via e-mail may not be secure and thus may be disclosed. However, as noted in the “Data Security” section below, transmissions over the Internet are not 100% secure at all times. Please also be aware that the sending of electronic mail to our professionals or through other contact/address provided on the website does not create a client relationship between you and the Company, and the contents of any such electronic mail are not privileged.

Information Collected Through Automatic Data Collection Technologies.

As you navigate through and interact with our website, we or certain of our third-party service providers may use automatic data collection technologies to collect certain information about you such as about your computer equipment, browsing actions, and patterns, including but not limited to:

• Details of your visits to our website, including traffic data and other communication data and the resources that you access and use on our website; and
• Information about your computer and Internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical data and is not intended to identify you personally. It helps us to improve our website 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, allowing us to customize our website according to your individual interests; and
• Recognize you when you return to our website.

For example, we use Google Analytics to provide us with statistics or metrics about the usage of our website, and Google Analytics may use cookies (described below) to compile and provide that information to us. You can learn more about how Google Analytics collects and processes data by visiting the following link: https://www.google.com/policies/privacy/partners/ which will take you to the site “How Google uses data when you use our partners’ sites or apps.” Google offers the ability to opt out from tracking through Google Analytics cookies; for more information, you may visit the following link: https://tools.google.com/dlpage/gaoptout.

The technologies we use for automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small text file placed on the hard drive of your computer or device (mobile, tablet, or desktop computer). Cookies placed on your computer by our website are called “first-party” cookies, and those placed by third parties are “third party” cookies. You may refuse to accept browser cookies by activating the appropriate setting on your browser such as a “Do Not Track” feature or delete or “flush” all cookies from your web browser. However, if you select such a setting or delete all cookies you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.
• By visiting or registering for our website, you consent to our use of first-party and third-party cookies and other automated technologies we or third parties may use to collect information about visitors to our website.
• Web Beacons. Pages of the website may also contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and/or for other related website statistics or metrics such as, for example, recording the popularity of certain website content and verifying system and server integrity.

How We Use Your Information.

We use information that we collect about you or that you provide to us, including any personal information:

• To present our website and its contents to you;
• To provide you with information, products, or services that you request from us;
• To market our products and services to visitors to our website;
• To analyze data or metrics about our website to send more targeted messages to visitors of our website;
• To conduct research to improve our products and services and website;
• To provide you with notices about your account;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
• To notify you about changes to our website or any products or services we offer or provide through it;
• To allow you to participate in interactive features on our website;
• To respond to your inquiries and to deliver email messages like special offers, updates, newsletters, and service announcements; and
• To fulfill any other purpose for which you provide your information or for any other purpose for which you provide your consent.

In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials based on a lawful disclosure request, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.

Disclosure of Your Information.

We may disclose aggregated information about our website users, and information that does not identify any individual, without restriction. We do not sell your information to third parties for marketing or advertising purposes. We may disclose personal information that we collect or you provide as described in this Privacy Policy:

• To our subsidiaries and affiliates;
• To our joint or sponsored partners or vendors for events or registration purposes;
• To fulfill the purpose for which you provide the Personal Information;
• To contractors, service providers, and other third parties we use to fulfill the purpose for which you provide the information, in accordance with applicable law;
• To a buyer or other successor of our business in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation or similar proceeding, in which Personal Information held by us about our Website users is among the assets transferred and which may result in the buyer or successor altering the terms of this Privacy Policy or our Terms of Use; and
• For any other purpose disclosed by us when you provide the information.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• To enforce or apply our Terms of Use, this Privacy Policy, and other agreements, including for billing and collection purposes;
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information.

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies. You can set your web browser to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts or features of our Website may then be inaccessible or not function properly.
• Promotional Offers from the Company. If you do not wish to have your email address or contact information used by us to promote our own or third parties’ products or services, you can use the “unsubscribe” feature found in any marketing emails we send to you, or you can send us an email stating your request to the email address listed in the Contact Information section below. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt-out does not apply to information provided to us as a result of a client engagement.

Rights of Website Visitors.

In certain jurisdictions, which may change from time to time, residents have certain rights relating to their Personal Information that we collect and maintain. If you are a resident of such a jurisdiction, for example, California, Texas or Nebraska, you have the right to request that we provide you with information, including Personal Information, that we collect, use or disclose, and you also have the right to request that we correct or delete such information to the extent it is collected or maintained by us.  Specifically, you may request (i) to know about Personal Information collected about you; (ii) to correct Personal Information collected about you; or (iii) to delete Personal Information collected about you.

To make a request such as those outlined above, to file a concern or complaint, or to opt-out of particular programs, please contact us by emailing us at marketing@smolin.com. You may also call our Compliance Line at +1-877-426-1040 or send a letter to the following address:

Smolin Lupin and Co., LLC
c/o Legal
10 Waterview Blvd.
Suite 300
Parsippany, NJ 07054

If you would like to delete, amend, or correct your Personal Information and are contacting us by email, please put “Deletion Request” or “Amendment/Correction Request” in the subject line of the email.

We will confirm receipt of a request within 10 days. Prior to providing a substantive response, we will review the information you provided along with information we have about you in our records, if any, to verify your identity. If and when your identity is verified, we will fulfill the request to the extent we are able and permitted to by law. Our substantive response will be within 45 days of the request, unless we notify you otherwise. We may reach out to you by e-mail, mail or by phone. If the request involves the deletion of Personal Information, we will, upon verifying your identity, ask you to confirm that you wish to proceed, and then, provided we are not barred from deleting the Personal Information for another reason, we will proceed to delete the Personal Information.

Note that if you request deletion of your Personal Information, we cannot do so without also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause such information to be incorrect. Further, even after you have changed your information, deleted it, or requested its deletion, we may need to keep archival copies of such information for legal or compliance purposes.

Data Retention.

We may retain your Personal Information for purposes of providing services to you, for ongoing improvement of our website, and for better aligning our products and services with your needs.  Where required by law, retention of your Personal Information may be limited to a duration that is reasonable in order to provide the services requested by you. To the extent required by applicable law, we will retain your Personal Information for the duration of our relationship, plus a reasonable period to comply with the applicable statute of limitations or if otherwise required under applicable law.

Children.

Our website is not directed to children under the age of 18 (we define “children” as minors younger than 18).  We do not knowingly collect or use any Personal Information directly from children on our Website. We do not knowingly allow children to order our services, to communicate with us, or to use any of our online services. If you are a parent and become aware that your child has provided us with information, please contact us using one of the methods specified below, and we will work with you to address this issue.

Data Security.

We have implemented administrative, technical and physical safeguards designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

Unfortunately, the transmission of information over the Internet is not completely secure at all times. Consequently, although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is therefore at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our website.

Similarly, for Personal Information collected through means other than our website, we maintain reasonable technical, administrative and physical controls.

Third-Party Websites and Services.

Our website may contain links to other websites and services not maintained by us. This Privacy Policy does not apply to websites that are not owned by or managed by us nor does it apply to third-party websites to which our website may link. We make no representations or warranties as to the accuracy or any other aspect of the information on those linked websites. No link to another website should be construed as an endorsement or recommendation of any information, goods or services on such website. In this way, it is your responsibility to understand the terms of any applicable third party privacy policies and address any concerns with such policies to the applicable provider.

As an example, if you join our mailing list, you may be required to visit a third party website to join the mailing list when a third party manages communications for the mailing list. In such cases, the information you submit to the third party service will be subject to their Privacy Policy and Retention Policy.

Similarly, we may use third-party vendors for payment processing, secure file transfers or for purposes of fulfilling your other requests.  In such instances, you may be required to visit the website of such third parties in order to use the applicable services. Any information you submit through these third-party vendors’ websites will be subject to their privacy policies and terms of use. These other websites or services described above are not subject to our Privacy Policy and we are not responsible for their content or for the policies or practices they apply to the treatment of your information. To the extent we use third-party vendors to fulfill your requests and you are not directed to such third-party vendors website(s), or you are sharing personal information with a vendor in order for us to use that information to perform services for you, we require that such vendors only use your personal information for the purposes for which it was provided.  To avoid ambiguity, the handling of personal information by third-party vendors outlined above is not meant to include information derived from browsing of our website, which is addressed separately above.

In addition, other websites and services may also reference or link to our website. These other websites or services described above are not subject to our Privacy Policy and we are not responsible for their content or for the policies or practices they apply to the treatment of your information. We encourage you to be aware when you enter or leave our website, or surf the Internet, and to read the privacy policies of each website and service that you visit. We do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of, other websites or services.

Social Media Features.

Our website also includes certain social media features, enabled through plug-ins and widgets, for example, that run on our Website, including from social media websites such as Instagram, Facebook, X, LinkedIn, and YouTube.com. These social media features may collect your IP address, the page you are visiting on our website, and may set cookies to enable such feature(s) to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the third party social media website providing such features.

Governing Law and Jurisdiction.

All matters relating to our Website and this Privacy Policy and any dispute or claim arising therefrom or related thereto (in each case, including non-contractual disputes or claims), shall be governed by and construed in accordance with the laws of the State of New Jersey without giving effect to any choice or conflict of law provision or rule (whether of the State of New Jersey or any other jurisdiction).

Any legal suit, action or proceeding arising out of, or related to, our Website or this Privacy Policy shall be instituted exclusively in the federal courts of the United States or the courts of the State of New Jersey. You waive any and all objections to the exercise of jurisdiction over you by such courts and to a venue in such courts. Notwithstanding the foregoing, we retain the right to bring any suit, action or proceeding against you concerning this Privacy Policy in your state or country of residence or any other relevant state or country. YOU HEREBY WAIVE YOUR RIGHT TO A TRIAL BY JURY WITH RESPECT TO ANY CLAIM, ACTION OR PROCEEDING, DIRECTLY OR INDIRECTLY, ARISING OUT OF, OR RELATING TO, THIS PRIVACY POLICY TO THE FULLEST EXTENT PERMITTED BY LAW.

Contact Information.

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your information, your choices and rights regarding such use, or you wish to exercise your rights to the extent permitted under applicable law, please do not hesitate to contact us at:

Website: https://smolin.com/
Email: marketing@smolin.com
Postal Address:
Smolin, Lupin & Co., LLC
10 Waterview Blvd, Ste 300
Parsippany, NJ 07054