Privacy Policy

1. Welcome

At UMB Advisors (“UMB”, “we”, “us”, “our”), we are committed to protecting your privacy and ensuring that your Personal Information (defined below) is handled in a safe and responsible manner. This Privacy Policy (“Policy”) is here to help you understand how we collect, process, and share your Personal Information. We also describe our security practices with respect to your Personal Information, as well as your rights & choices with respect to how we process that Personal Information. Please read this Policy carefully.

2. Scope & Acknowledgment

This Policy applies to our website, located at https://umbadvisors.com and any other website, application, or services where we post or link to this Policy (the “Site”) as well as other online services where we collect Personal Information from you (collectively, our “Services”).

This Policy does not apply to information processed by third parties, for example, when you visit a third-party website or interact with third-party sites, except to the extent those parties collect or process information on our behalf. Please review any relevant third party’s privacy policy for information regarding their privacy practices.

Your use of our Services indicates your acknowledgement of the notices provided in this Policy.

3. Contact Us

The controller of your Personal Information under this Policy is UMB Advisors. You may contact us as follows:

General Inquiries and Data Updates: hello@umbadvisors.com

4. Categories & Sources of Personal Information

In order to provide our Services, we may collect and process information that relates to identified or identifiable individuals (“Personal Information”). We collect and process the following categories of Personal Information (note, specific Personal Information elements are examples and may change):

• Audio Data — Audio files and records, such as voicemails, call recordings, and the like.
• Contact Data — Identity Data used to contact an individual, e.g. email address, physical address, or phone number.
• Device/Network Data — Personal Information relating to your device, browser, or application e.g. device identifiers, identifiers from cookies, session history and Site navigation metadata, and other data generated through applications and browsers, including via cookies and similar technologies.
• General Location Data — Non-precise location data, e.g. location information derived from IP addresses.
• Identity Data — Personal Information about you and your identity, such as your name or IP address.
• Inference Data — Personal Information we create or use as part of a profile reflecting your preferences, characteristics, aptitudes, market segments, likes, favorites or your interests.
• User Content — Personal Information included in content provided by users of the Site in any free-form or unstructured format, such as in a “contact us” box, free text field, in a file or document, or messages to us.

Sources of Personal Information

We collect Personal Information from various sources based on the context in which the Personal Information will be processed:

• You — We collect Personal Information from you directly, for example, when you input information into an online form, or contact us directly.
• From your devices — We may collect certain Personal Information automatically from devices you use when you interact with our Services. For example, we collect Device/Network Data automatically using cookies and similar technologies when you use our Site or when you open our marketing communications.
• Service Providers — We receive Personal Information from service providers performing services on our behalf.
• Data we create or infer — We, or certain third parties operating on our behalf, may create and infer Personal Information such as Inference Data based on our observations or analysis of other Personal Information processed under this Privacy Policy, and we may correlate this data with other data we process about you.
• Social Media Companies — We receive Personal Information from social media companies, such as LinkedIn, when you interact with us on that social media company’s platform on or in connection with our Services.

5. Data Processing Contexts / Notice at Collection

Website / Generally

When you use our Site, we automatically collect and process Identity Data, Inference Data, General Location Data, and Device/Network Data. We use this data as necessary to initiate or fulfill your requests for certain features or functions through our Site, such as operating our Site, delivering webpages, or logging activities for security purposes. We may also process this Personal Information for our Business Purposes (as defined below).

Cookies and Similar Tracking Technologies

We process Identity Data, Device/Network Data, Contact Data, Inference Data, and General Location Data in connection with our use of cookies and similar technologies on our Site. We may collect this data automatically.

We and authorized third parties may use cookies and similar technologies to process such data for the following purposes:

• For “essential” purposes necessary for our Site to operate (such as maintaining user sessions, content delivery, and the like); and
• For “functional” purposes, such as to enable certain features of our Site (for example, to save user preferences or language settings).

We may also process this Personal Information for our Business Purposes. See the “Rights and Choices” section below for information regarding opt-out rights for cookies and similar technologies.

Please note, in some cases, third parties may view, edit, or set their own cookies or place web beacons on our Site. We, or these third-party providers, may be able to use these technologies to identify you across websites, devices, sites, and services. Third parties have their own privacy policies and their processing is not subject to this Policy.

Contact Us

When you contact us using a contact phone number or via email, request information from us, inquire about our advisory services, or ask for support, we process Personal Information such as Identity Data, Device/Network Data, and any Personal Information contained within any User Content you provide. We may also collect Audio Data if you contact us via phone and/or leave a voicemail. We use Identity Data, Contact Data, User Content, and Audio Data as necessary to communicate with you about the subject matter of your request and related matters. We may also process this Personal Information for our Business Purposes, and we may send you Marketing Communications if related to your request.

Social Media Posts

We process Identity Data, Contact Data, and User Content if you interact with or identify us on social media or communication platforms (e.g. if you post User Content that engages with or tags our official accounts). We process this Personal Information for our Business Purposes.

Posts may be public, or reposted on our Service. Content you provide may be publicly available when you post it on our Service, or in some cases, if you reference, engage, or tag our official social media accounts or communications platforms.

Informational or Promotional Communications

We process Device/Network Data, Contact Data, Identity Data, and Inference Data in connection with our newsletter, marketing emails, or similar communications, and when you open or interact with those communications (“Marketing Communications”).

You may receive Marketing Communications if you consent and, in some jurisdictions, where permitted by law. Marketing communications will include information about our Services, advisory engagements, and other promotional material we believe will interest you.

We process this Personal Information to contact you about relevant services and for our Business Purposes. You can withdraw your consent to receive Marketing Communications by clicking on the unsubscribe link in an email, or by contacting us. See the “Rights and Choices” section below for information regarding opt-out rights for Marketing Communications.

Events / Conferences

We may process Identity Data, Contact Data, and User Content if you attend and interact with us at an event, conference, or trade show (“Event”). We process this Personal Information to continue our conversation with you in the future, to provide any services you request, and for our Business Purposes. We may also send you promotional communications if you provide us with your contact information at an Event.

6. Purposes of Processing

Business Purposes

In addition to the processing described above, we generally process Personal Information for several common purposes in connection with our business:

• Operate our Site and Fulfill Obligations — We process any Personal Information as is necessary to operate our Services, and as otherwise necessary to fulfill our obligations to you, e.g. to provide you with the information, features, and services you request.
• Internal Processes and Service Improvement — We may use any Personal Information we process through our Services in connection with our improvement of the design of our Services, for customer service purposes, in connection with the creation and analysis of logs and metadata relating to the use of our Services, and for ensuring the security and stability of the Services.
• Security and Incident Detection — We may process Personal Information in connection with our legitimate interest in ensuring that our Service is secure, identify and prevent crime, prevent fraud, and verify or authenticate users/individuals.
• Aggregate Analytics — We process Personal Information as necessary in connection with our creation of aggregate analytics relating to how our Services are used. The resulting aggregate data will not contain information from which an individual may be readily identified.
• Compliance, Safety & Public Interest — We may, without your consent or further notice to you, and to the extent required or permitted by law, process any Personal Information subject to this Policy for purposes determined to be in the public interest or otherwise required by law.

7. Data Sharing

Personal Information we collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided:

• Service Providers — In connection with our general business operations, product improvements, to enable certain features, and in connection with our other lawful business interests, we may share Personal Information with service providers or subprocessors who provide certain services to us, or process data on our behalf.
• Social Media Companies — We may share certain Personal Information with social media companies when you interact with us on social media. We do not share Contact Data collected in connection with our Marketing Communications with these parties.
• Corporate Events — Your Personal Information may be disclosed to a third party in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets.
• Affiliates — In order to streamline certain business operations and develop products and services that better meet the interests and needs of our clients, partners, and users, we may share your Personal Information with any of our current or future affiliated entities, subsidiaries, and parent companies.
• Legal Disclosures — In limited circumstances, we may, without notice or your consent, access and disclose your Personal Information, our correspondence with you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, or in the vital interests of us or any person.

8. Your Rights & Choices

Applicable law may grant you rights in your Personal Information. These rights vary based on your location, state/country of residence, and may be limited by or subject to our own rights in your Personal Information. You may submit requests to exercise rights you may have by contacting us.

We verify all rights requests to ensure that the individual making the request is authorized to make that request, to reduce fraud, and to ensure the security of your Personal Information.

Your Choices

• Consent — If we rely on your consent to our processing of Personal Information, you may withdraw your consent at any time. You can withdraw your consent to receive marketing communications by clicking on the unsubscribe link in an email, or by contacting us.
• Email Marketing — You have the choice to opt-out of or withdraw your consent to email marketing communications. You may exercise your choice via the links in our communications.
• Cookies & Similar Tech — If you do not want information collected through the use of cookies and similar technologies, you can manage/deny cookies using your browser’s settings menu. If you do not allow functional cookies, then our Site or certain features may not function properly.
• Do Not Track — Our Site does not respond to your browser’s do not track signal.

9. Security

We implement and maintain reasonable security measures to safeguard the Personal Information you provide us. However, we sometimes share Personal Information with third parties as noted above, and though we may take certain measures to help ensure the security of your Personal Information, we do not control third parties’ security processes. We do not warrant perfect security and we do not provide any guarantee that your Personal Information or any other information you provide us will remain secure.

10. Data Retention

We retain information for so long as it, in our discretion, remains relevant to its purpose, and in any event, for so long as is required by law. We will review retention periods periodically, and may sometimes pseudonymize or anonymize data held for longer periods, if appropriate.

11. International Transfers

We operate in and use service providers located in the United States. If you are located outside the U.S., your Personal Information may be processed in the U.S. The U.S. may not provide the same legal protections guaranteed to Personal Information in foreign countries. Contact us for more information regarding transfers of data to the U.S.

12. Children

Our Services are neither directed at nor intended for use by persons under the age of 13 in the US. We do not knowingly collect information from such individuals. If we learn that we have inadvertently done so, we will promptly delete such Personal Information if required by law. Do not access or use our Services if you are not of the age of majority in your jurisdiction unless you have the consent of your parent or guardian.

13. Changes to Our Policy

We may change this Policy from time to time. Please visit this page regularly so that you are aware of our latest updates. Your use of the Site following notice of any changes indicates acceptance of any changes.