Privacy Policy

Effective Date: November 6th, 2020

Thank you for visiting the Web site (the “Site”).  Throughout this Privacy Policy (“Privacy Policy”) the words “Gresham Partners,” “we,” or “us” refer to Gresham Partners LLC and our affiliates, and the words “you” and “your” refer to the user visiting the Site and your institution or organization. This Privacy Policy applies to information that we collect at the Site (including any mobile version) and our handling of such information. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of the Site (unless otherwise stated below). Please review the Site’s Terms of Use, which governs your use of the Site.

By accessing this Site, you acknowledge and agree to accept this Privacy Policy, the Terms of Use, any other legal notices, conditions or guidelines located within the Site. If you do not agree to our Privacy Policy or Terms of Use, please do not use the Site and exit now.  

1. What Information Does the Site Collect? 

(a) Information You Provide to Us

Personal Information. We may ask you to provide us with your personally identifiable information such as your first and last name, telephone number and e-mail address (“Personal Information”). We may collect this Personal Information through various forms and in various places on the Site or when you otherwise interact with the Site. If you access and use our Client Portal, you will also provide certain additional Personal Information or financial information. See below for more information about our Client Portal.

Client Portal.  When you log-in to our Client Portal we will require login ‎information in connection with your account, including a user ID and ‎password. We will provide you a user ID generated by us and when you log in for the first time you will be asked to create a password.  You are responsible for keeping your password secure and you should not share your user ID or password with any other person. ‎If you choose to use the Client Portal, you will be redirected to our current third-party processor, Summitas. Gresham Partners strives to ensure that all of its partners and affiliates maintain ‎industry-standard privacy policies and security. You may read a current, effective description of security features of the Summitas Site here: Please be aware, however, that Gresham does not directly collect ‎or store any of your Personal Information when you use the Client Portal and we do not control the privacy policies and practices ‎of third parties. To understand how Summitas collects, processes and stores your Personal Information when using our Client Portal, please review the ‎Summitas privacy policy (

(b) Information Collected or Stored As You Access and Use the Site 

In addition to any Personal Information or other information that you choose to submit to us via the Site, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Site (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with the Site. To the extent we associate Usage Information with your Personal Information that we collect directly from you on the Site, we will treat it as Personal Information. 

This Usage Information may include:

  • your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Site, and our computers identify your Device by its Device Identifier;
  • your Device functionality (including browser, operating system, hardware, mobile network information);
  • the URL that referred you to the Site;
  • the areas within the Site that you visit and your activities there, including remembering you and your preferences, if any;
  • your Device location;
  • your Device characteristics; and
  • certain other data from your Device, including the time of day you accessed the Site, among other information. 

Tracking Technologies. We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):

Cookies. A cookie is a data file placed on a Device when it is used to visit a Web site. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in the Site’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed. 

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with a Web site, such as the links you click on. The code is temporarily downloaded onto your Device from a web server or a third-party service provider, is active only while you are connected to the relevent site, and is deactivated or deleted thereafter. 

Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification, is known as browser fingerprinting. 

ETag, or Entity Tag. An ETag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies. 

Recognition Technologies. Recognition technologies are technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices in the same user).

Tracking Technologies Usage. We may use Tracking Technologies for a variety of purposes, including:

Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access the Site, including cookies required to prevent fraudulent activity and improve security. 

PerformanceRelated. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site. 

FunctionalityRelated. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Site, including identifying you when you visit the Site or keeping track of your specified preferences, including in terms of the presentation of content on the Site. 

TargetingRelated. We may use Tracking Technologies to deliver content relevant to your interests on the Site and third-party sites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you. 

Tracking Technologies Choices and Consent.

We obtain your consent to our information storage or collection Tracking Technologies by providing you with transparent information in our Privacy Policy and providing you with the opportunity to make a choice to disable cookies as set forth above. Please note that we are not required to obtain your consent to the information collection Tracking Technologies identified above that are strictly necessary.

We are giving you detailed notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed.

‎Analytics Services‎

We may use third-party analytics services (such as Google Analytics) that track details about your online activities over time ‎and across different sites. This information is only processed in a way that does not identify anyone. These services help us to improve our Site. To opt out of being tracked by Google Analytics across all Web sites, visit:

Third Party Tracking and “Do Not Track.”

There may be other Tracking Technologies now and later devised and used by us in connection with the Site. Further, third parties may use Tracking Technologies in connection with the Site, which may include the collection of information about your online activities over time and across third-party Web sites or online services. We do not control those Tracking Technologies and we are not responsible for them. You consent, however, to potentially encountering third-party Tracking Technologies in connection with use of the Site and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties. Also, 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 Web sites or online services (e.g., browser :do not track: signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms. 

 (c) Information Third Parties Provide About You

We may, from time to time, supplement the information we collect directly from you on the Site with outside records you provide to us or we obtain from third parties for various purposes, including enhancing our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. To the extent we combine information we receive from those sources with Personal Information we collect on the Site, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you outside the Site or from third parties. 

(d) Interactions with Third-Party Sites 

The Site may include functionality that allows certain kinds of interactions between the Site and a third-party Web site or application. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. If we offer and you choose to use this functionality to access or use the Site, the third-party site or application may send Personal Information about you to us. If so, we will then treat it as Personal Information under this Privacy Policy, since we are collecting it as a result of your accessing and interacting with the Site. In addition, we may provide third-party sites’ interfaces or links on the Site to facilitate you sending a communication from the Site. These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. We may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on the Site. 

2. How Do We Use the Information Collected?

We may use your Personal Information or Usage Information that we collect about you: (1) to provide you with information or services or process transactions that you have requested or agreed to receive or to provide you with materials on behalf of us or third parties; (2) to enable you to participate in a variety of the Site’s features; (3) to process any inquiry, including verifying your information is active and valid; (4) to improve the Site or create new service offerings, to customize your experience on the Site, or to serve you specific content that is most relevant to you; (5) to contact you with regard to your use of any portion of the Site and, in our discretion, changes to the Site and/or any of the Site’s policies; (6) for internal business purposes; and (7) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

3. How and When Do We Share Information with Third Parties?

We may share non-Personal Information, such as aggregated user statistics, with third parties. We may share your Device Identifiers with third parties along with data related to you and your activities. We do not share your Personal Information with third parties for our or those third parties’ direct marketing purposes. If we de-identify data about you, it is not treated as Personal Information by us, and we may share it with others freely. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. Gresham Partners may also disclose your information as follows:

(a) When You Request Information From or Provide Information to Third Parties. You may be presented with an option on the Site to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. 

(b) Third Parties Providing Web Sites on Our Behalf. We may use third-party vendors to perform certain services on behalf of us or the Site, such as hosting the Site, designing and/or operating the Site’s features, tracking the Site’s activities and analytics, and enabling us to perform other administrative services. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third-party technologies or activities arising out of them, nor are we responsible for the effectiveness of or compliance with any third parties’ opt-out options. 

(c) To Protect Our Rights and the Rights Others. To the fullest extent permitted by applicable law, we may also disclose your information (including Personal Information) if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Gresham Partners or third parties (including through the enforcement of this Privacy Policy, our Terms of Use, and other applicable agreements and policies and for fraud protection); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders). To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.

(d) Affiliates and Business Transfer. We may share your Personal Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process. 

4. Updating Your Information ‎

Our Site may allow you to update the information that we collect from you, such as your contact ‎information, name, password, or user ID. You may also request that we ‎update your information by sending an e-mail to us at Our Site may also allow you to update ‎your e-mail preferences. If you would prefer not to receive e-mail newsletters or other messages ‎from us, you may use the “unsubscribe” features that are included in such messages or contact us ‎at

5. What About Transfer of Information to the United States?

This Site is operated in the United States and is intended for users ‎located in the United States. If you are not located in the United States, please note that the data ‎protection laws in the United States may differ from those of the country in which you are ‎‎located, and your Personal Information may be subject to access requests from governments, ‎courts, ‎or law enforcement in the United States according to laws of the United States. By using ‎the Site ‎or providing us with any information, you consent to the transfer to, and processing, ‎usage, sharing ‎and storage of your information, including Personal Information, in the United ‎States as set forth in ‎this Privacy Policy. ‎

6. What Should Parents Know About Children?

Our Site is intended for adults, and we do not knowingly seek or collect Personal Information from children under the age of majority in your jurisdiction. In accordance with the Child Online Privacy Protection Act, in the event that we learn that we have collected Personal Information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any Personal Information from or about a child, please contact us by e-mail using the subject heading “COPPA Inquiry” at or by phone at 312.327.5020.

7. What About Security?

We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. No data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information, however, can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Site and provide us with your information at your own risk. 

8. What About Changes to the Privacy Policy?

We reserve the right to change this Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of the Site indicates your consent to the Privacy Policy posted at the time of use. We will not, however, use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

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