YOUR PRIVACY IS IMPORTANT TO US
LAST UPDATE: May 1, 2022
1. COLLECTION AND USE OF PERSONAL INFORMATION
Personal Information You Provide
The privacy and security of the personal information that Cohen & Company collects from you is a priority for us. When you visit this Site you may be asked for, or choose to provide, personal information that could reasonably be used to contact you or to identify you personally including, but not limited to, your first and last name, address, company name, email address, phone number, and inquiry information. You will be informed what personal information is required and what information is optional when asked to submit personal information to us. By submitting personal information to Cohen & Company at this Site, you hereby consent to Cohen & Company’s collection, use and disclosure of such personal information in accordance herewith.
We may combine the personal information you submit directly through this Site with other personal information we have collected from you, whether on- or offline. We may also combine it with information we receive about you from other sources, such as other companies, publicly available information sources (including information from your publicly available social media profiles), and other third parties.
Passive Information Collection and Use
As you navigate around this Site, certain information can be passively collected (that is, gathered without you actively providing the information), using various technologies. We and our third-party service providers passively collect and use information in a variety of ways, including:
- Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, Device type (Windows or Macintosh), screen resolution, operating system version, and Internet browser type and version. We may collect similar information, such as your device type and identifier, if you access this Site through a mobile Device.
- You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) to disable existing cookies; or (iii) to set your browser to automatically reject any cookies.
- Pixel tags, Google analytics, web beacons, clear GIFs, or other similar technologies: These may be used in connection with some Site pages to, among other things, track the actions of Site users and compile statistics about Site usage and response rates.
- IP Address: Your IP Address is a number that is automatically assigned to the Device that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits this Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering this Site.
- Device Information: We may collect information about your Device, such as a unique device identifier
- Do Not Track Requests: At this time Cohen & Company does not respond to Do Not Track signal requests.
Integrated Accounts and Social Media Information
We may implement applications or "widgets" from third party providers (e.g., Facebook, Twitter, Instagram, LinkedIn, etc.) that allow interaction, integration or content sharing with third party services. These widgets or applications may be visible on a page you visit on our Site or may require log-in through the third-party provider’s service. The third party providing the widget or integration may offer controls for you to manage your interactions. Any interaction with a third-party widget or application typically allows the third party to collect some information about you (whether through cookies, registration information or otherwise). These third parties may even track you when you do not interact with the widget. If you have engaged any of these third-party service providers, their respective privacy policies will govern their tracking and collection of information. You should review these third-party policies to understand these practices.
How We Use and Disclose Information
We use and disclose personal information you provide to us as described to you at the point of collection, such as when you (1) register for a user account, (2) submit your name and e-mail address to receive updates and marketing information, and (3) send e-mail messages or feedback, or transmit other information by e-mail. When you elect to engage in such activities, we may ask that you provide us personal information, such as your first and last name, employer, mailing address (including zip code), e-mail address, mobile telephone numbers, and payment information.
We also use and transfer personal information from or about you:
- To respond to your inquiries and fulfill your requests, such as to send you documents you request or e-mail;
- To send you important information regarding our relationship with you or regarding this Site, changes to our terms, conditions, and policies and/or other administrative information;
- For our business purposes, such as marketing new services, data analysis, developing new services, enhancing our Site, improving our services, identifying Site usage trends, and determining the effectiveness of our Site;
- To our third-party service providers who provide services such as website hosting and moderating, mobile application hosting, data analysis, infrastructure provision, credit card processing, data portals, IT services, e-mail services, marketing services, and other services, in order to enable them to provide services; and
- To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
We also use and disclose information we collect passively as described above, under "Passive Information Collection and Use," and for any other purpose, except where we are required to do otherwise under applicable law (for example, if we are required to treat such information as personal information). In addition, we may use and disclose information that is not in personally identifiable form (such as anonymized, masked or de-identified information) for any purpose. If we combine information that is not in personally identifiable form with information that is (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined.
Opting Out from Marketing Emails
If you would like to opt out of receiving promotional or marketing e-mails from us, use the “update subscription preferences” link included in each marketing message. You may also let us know by sending an email at the address in the CONTACTING US section below with “REMOVE” in the subject line, and stating the e-mail address that you wish to be removed from our mailing list. However, your option not to receive promotional and marketing e-mail shall not preclude us from corresponding with you by e‑mail or otherwise regarding your existing relationship with us. Opt-out requests will also not apply to correspondence that has already been initiated.
2. GENERAL PRINCIPLES FOR THE PROCESSING OF PERSONAL INFORMATION
Personal information will be collected, stored, processed and transmitted in accordance with Cohen & Company’s established policies and applicable federal, state, local and foreign laws, rules and regulations.
The principles of Cohen & Company with respect to the processing of personal information are as follows: (1) personal information will be processed fairly and lawfully, (2) personal information will be collected for specified, explicit, and legitimate purposes and not further processed for incompatible purposes, (3) personal information collected by Cohen & Company will be adequate, relevant, and not excessive in relation to the purposes for which it is collected, (4) personal information collected by Cohen & Company will be accurate and, where necessary, kept up to date to the best of our ability, and (5) personal information collected by Cohen & Company will be retained as identifiable data for no longer than necessary to serve the purposes for which the personal information was collected.
If Cohen & Company engages in the processing of personal information for purposes other than those specified in this Policy, Cohen & Company will provide notice of these changes, the purposes for which the personal information will be used, and the recipients of personal information.
3. THIRD-PARTY SITES AND SERVICES
This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any application) that is available through this Site or to which this Site contains a link. The availability of, or inclusion of a link to, any such site or property on this Site does not imply endorsement of it by us or by our affiliates.
4. CHOICES AND ACCESS
We give you choices regarding our use and disclosure of your personal information. You may opt-out of our collection of your personal information at any time by contacting us as specified below in the CONTACTING US section below. We will seek to comply with your request(s) as soon as reasonably practicable.
If applicable and you would like to review, correct, update, or delete the personal information that you have provided via this Site, please contact us as specified below in the CONTACTING US section below. We will try to comply with your request as soon as reasonably practicable.
It is your responsibility to provide Cohen & Company with accurate personal information. Except as otherwise set forth in this Policy, Cohen & Company shall only use personal information in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. To the extent necessary for these purposes, Cohen & Company shall take reasonable steps to ensure that personal information is accurate, complete, current and relevant to its intended use.
6. RETENTION PERIOD
We retain your personal information for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or allowed by law or to otherwise fulfill a legal obligation.
We use reasonable organizational, technical, and administrative measures to protect personal information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the CONTACTING US section below.
8. USE OF SITE BY MINORS
The Site is not directed to individuals under the age of 16 and we request that these individuals not provide personal information through this Site.
9. COMPLIANCE WITH LOCAL LAWS
This Policy is meant to guide Cohen & Company with respect to personal information collected from or about you at this Site. While this Policy applies to personal information generally, the local laws, rules and regulations of jurisdictions that are applicable to Cohen & Company (“Local Laws”) may require standards which are stricter than this Policy and, in such event, Cohen & Company will comply with applicable Local Laws. Specific privacy policies may be adopted to address the specific privacy requirements of particular jurisdictions.
Privacy Notice for California Residents
This section is our Privacy Notice for California Residents (“Notice”) and applies to visitors, users, and others who reside in the State of California (“consumers,” or “you/your”) and use our Services, as contemplated under the California Consumer Privacy Act of 2018 (“CCPA”).
If you wish to exercise your rights under the CCPA, please contact us using any of the methods provided in the CONTACTING US section below. We will consider and process your request within a reasonable period of time. Please be aware that under certain circumstances, the CCPA may limit your exercise of these rights.
We collect different types of information from users, and we use and/or disclose this information for different business purposes. The chart below identifies the Personal Information we may collect and lists the parties with whom we may share this information and for what business purpose:
|Category of Personal Information
|Specific Personal Information that may be collected
|Purpose of collecting the Personal Information
|Categories of sources from which the personal information is collected
|Is this category of Personal Information shared with third parties?
|Categories of third parties with which the Personal Information may be shared
|Purpose of disclosing or sharing Personal Information
|Name, mailing address, email address, and telephone number; IP address; account information
|To uniquely identify an individual in support of business activities
|Contact information, transaction/order history
|To support business transactions
|Your transactions with us
|Service Providers (payment processor, shipping companies)
|Internet or other similar network activity.
|IP address; browser type and version; Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
|To allow access to and optimize our website or mobile application
|From you and third-party technologies
|No (but we may share aggregated statistical or demographic data with our service providers)
|Improve Site or Device
|Unique identifiers and your location
|From you and your devices
|Service Providers to help us locate your products
The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
- The right to know. You have the right to request to know (i) the specific pieces of personal information* we have about you; (ii) the categories of personal information we have collected about you in the last 12 months; (iii) the categories of sources from which that personal information was collected; (iv) the categories of your personal information that we sold or disclosed in the last 12 months; (v) the categories of third parties to whom your personal information was sold or disclosed in the last 12 months; and (vi) the purpose for collecting and selling your personal information. Generally, please note that:
- Within the preceding 12 months, Cohen & Company collected the categories of personal information detailed in the “Personal Information You Provide” section above.
- Cohen & Company may have disclosed your personal information in the “How we Use and Disclose Information” section above.
- We do not sell (i.e., exchange anything of value with a 3rd party) any personal information received from our clients, and we do not sell any personal information obtained in the course of providing our professional services.
- We neither collect nor sell the personal information of minors under 16.
* “Personal information” means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information; but does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.
The right to deletion. You have the right to request that we delete the personal information that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your personal information was collected. If we deny your request for deletion, we will let you know the reason why.
- The right to opt out of the sale of your personal information. You have the right to opt out of the sale of your personal information. If you are a California resident and you wish to opt out, you can submit your request to opt out of the sale of your personal information by emailing us at the address in the CONTACTING US section below to request an opt out form.
- The right to non-discrimination. If you choose to exercise any of these rights, we will not discriminate against you in anyway. If you exercise certain rights, understand that you may be unable to use or access certain features of our web sites or our services.
- Service Provider. If we are a service provider of the business to which you submitted your personal information, we may deny your request as you must submit your request to the business itself and we may not be able to disclose the identity of that business to you.
You may exercise your right to know and your right to deletion twice a year free of charge. To exercise your right to know or your right to deletion, contact us at the CONTACTING US information set forth below. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. If you are a client of ours, we will use our existing authentication practices to verify your identity. If you are not a client of ours, we may request additional information about you to verify your identity. We will only use the personal information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose. Making a request does not require you to create an account with us. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request. We will respond to your request within a reasonable timeframe in accordance with applicable law.
You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your personal information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to the address in the CONTACTING US section below.
10. CROSS-BORDER TRANSFER
Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our Site or by providing consent to us (where required by law), you specifically acknowledge and agree to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules, and a lower standard of required protection, than in your country.
We may change this Policy. Please take a look at the LAST UPDATE legend at the top of this page to see when this Policy was last revised. Any changes to this Policy will become effective when we post the revised Policy on this Site. Your use of this Site following these changes means that you accept the revised Policy.
If you believe that your personal information has been processed or disclosed in violation of this Policy, Cohen & Company encourages you to raise any concerns using the contact information provided in this Policy. Cohen & Company will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information.
13. CREDIT CARD PROCESSING
Credit card and payment information is processed by a secure third party, and Cohen & Company will never store, access, or manage your credit card and payment information. The privacy policies of such third party processors shall apply to the receipt, storage and/or transmission of your information.
14. CONTACTING US
If you have any questions about this Policy, please contact us via one of these methods:
Or please write to the following address:
Cohen & Company
1350 Euclid Ave., Suite 800
Cleveland, OH 44115