Introduction and Scope of this Privacy Statement

Last updated:  December 20, 2019

Effective:  January 1, 2020

KippsDeSanto & Co. is committed to protecting the privacy of your personal information. This Privacy Statement describes how KippsDeSanto & Co. (“KDC” or “we” or “our”) collects, stores, uses and protects your personal information when you access or use our website: www.kippsdesanto.com (the “Site”).

How to Contact Us

If you have any questions or issues about this Privacy Statement or how KDC handles personal information, please send us an email to kippsdesanto@kippsdesanto.com or a letter to: ATTN: Chief Compliance Officer, 8000 Towers Crescent Drive, Suite 1200, Tysons Corner, VA 22182

Acceptance

Please carefully review this Privacy Statement. By visiting and using our Site, you acknowledge that you understand the data collection practices and other information in this Privacy Statement.

If you do not agree with or you are not comfortable with any aspect of this Privacy Statement you should immediately discontinue use of our Site.

Changes to this Privacy Statement

KDC reserves the right to change or update this Privacy Statement at any time.

If we make a material change to this Privacy Statement, we will provide you with notice on the Site. By continuing to visit the Site after those changes become effective, you agree to be bound by the revised Privacy Statement. To find out when we last updated this policy, please refer to the date listed after “Last Modified” at the top of this Privacy Statement. In addition, we may provide you with “just-in-time” disclosures or additional information about the data collection, use and sharing practices of specific parts of our Site. These notices may provide more information about our privacy practices, or provide you with additional choices about how we process your personal data.

What if I am Visiting the Site from Outside the United States?

At this time, the Site is only intended to be available to residents of the United States and it is not intended to be directed to anyone residing outside of the United States.

If this current limitation changes, we expect that the Privacy Statement available to non-U.S. residents will reflect the laws and regulations of the territories where the Site is intentionally made available.

What is Personal Information?

For purposes of this Privacy Statement, we define “personal information” as personally identifiable information you provide to us such as your name, mailing address, email address, telephone or wireless phone number, social security number (used for identification purposes), or other information that identifies you.

Personal Information We May Collect

The personal information and other data we may collect when you visit the Site depends on how you use the site. The following are examples of the personal data and other information we may collect when you visit the site:

Information You Voluntarily Provide:

• Contact Us. If you provide personal information via the Contact Us feature on the Site, we will collect your name, email and any personal information you disclose in your message to us.
• Career. If you provide personal information to us by submitting information via the Careers page on our Site, we will collect the personal information requested and maintain it for as long as required to fill the position or comply with our legal obligations.
• Log Data. We automatically receive and store in log files certain information from your browser when you visit the
• Site. This information includes your Internet Protocol (“IP”) address, browser type, Internet services provider, referring/exit pages, your operating system, and the date/time stamp of your Site visit. We use this information, which doesn’t identify individual Site visitors, to analyze and understand how the Site works for you so we can improve it, to administer the Site, and to gather demographic information about Site visitors for targeted online marketing purposes.
• Cookies. We may use “cookies” and similar tracking technologies (e.g., web beacons and pixels) to collect and store information about your use of our Site. Please refer to the “Cookies” section below for more information about the cookies and tracking technologies we use and how to control them.

How We Use Your Personal Information

We may use your personal information for various purposes, including:

• providing, analyzing, and improving our Site;
• communicating with you regarding our Site if you request information from us;
• direct and re-targeted advertising unless you decline to share this information via the Cookie settings addressed in the Cookies section below;
• ensuring network and information security.

How We Share Your Personal Information

If you permit Cookies and other tracking technologies to be utilized when you visit the Site, we may share your IP address and other information collected for the purpose of delivering targeted marketing to you (please see our Cookie section below).

Cookies & Similar Tracking Technologies We Use & How to Manage Cookies

As mentioned above, the Site may use cookies and similar tracking technologies.

Cookies & How We Use Them.

Cookies are bits of data that a website sends to a web browser on a visitor’s computer. Cookies help us to collect information about visitors to the Site, including date and time of visit, pages viewed, amount of time spent on our sites, or general information about the device used to access the site. Cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout. We may also collect additional information to Site visitors including, but not limited to, duration of visit and IP address for the purposes of targeted marketing that may be of interest to you.

KDC may use third-party companies to provide you with KDC advertisements and other targeted advertising that may be relevant to your interests, as determined by your activity on the Site and other websites on the Internet. This type of ad customization is known as “online behavioral” or “interest-based” advertising. These advertising companies may use cookies to understand your interests based on, for example, pages visited and browsing patterns on the Site and other websites on the Internet.

We use and collect social media data on our social media profiles. Raw social media data is the collected information from social networks that show how users share, view or engage with our content or profiles (such as “likes” or comments/mentions made via social media).

If you change your activity when using our social media sites, or if you unsubscribe to us using your social media account, you may lose functionality to our information.

Types of Cookies on Our Site.

We use the following types of cookies on our Site:

Strictly Necessary Cookies. These cookies are essential because they enable you to move around and use our Site. For example, strictly necessary cookies allow you to access secure areas on our Site. Without these cookies, some services on the Site cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Site to work and they cannot be disabled.

Functional Cookies. We use functional cookies to remember your choices so we can tailor our Site to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Site. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Site.

Performance or Analytic Cookies. These cookies collect anonymous passive information about how you use our Services, including web pages you visit and links you click. We use the information collected by such cookies to improve and optimize our Site. We do not use these cookies to target you with online marketing. You can disable these cookies.

Third-Party Cookies. These are cookies that are provided by third-party service providers and belong in one of the cookie categories described above. These third-party providers process your personal information on our behalf pursuant to our instructions and obligations consistent with this Privacy Policy.

How long will cookies stay on my browsing device?

The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device until they expire or are deleted (i.e. after you have finished browsing). The expiration time or retention period applicable to persistent cookies depends on the purpose of the cookie collection and tool used. You may be able to delete cookie data as described below.

How to Manage Cookies:

Depending on whether you would like to manage a first-party or third-party cookie, you will need to take the following steps:

First-Party Cookies. You can enable, disable or delete our cookies through the browser you are using to access our Site. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of our Site, and/or parts of the Site may not work properly for you. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.

In addition, many browser manufacturers provide helpful information about cookie management, including, but not limited to:

Google Chrome
Internet Explorer
Mozilla Firefox
Safari (Desktop)
Safari (Mobile)
Android Browser
Opera
Opera Mobile

Third-Party Cookies. Cookies that are placed on your browsing device by a third party can be managed through your browser (as described above) or by checking the third party’s website for more information about cookie management and how to “opt-out” of receiving cookies from them.

Some of the third parties that serve analytics and marketing cookies via our Site allow you to opt-out of their processing directly, as further described on their websites below:

• Google Analytics: https://tools.google.com/dlpage/gaoptout (requires you to install a browser add-on)
• Hotjar: https://www.hotjar.com/legal/compliance/opt-out
• LinkedIn Ads: https://www.linkedin.com/help/linkedin/answer/62931/manage-advertising-preferences?lang=en
• Facebook Ads: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen

How to Opt-Out of Interest-Based Advertising.

If you would like more information about cookies and targeted advertisements or to opt out of having this information used by companies that are part of the Network Advertising Initiative, please visit www.networkadvertising.org/choices.

Do Not Track

Your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online service you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we do not respond to “Do Not Track” signals or other mechanisms from a visitor’s browser. If, in the future, we create a program or protocol to respond to such web browser “Do Not Track” signals, we will inform you of the details of that protocol in this Privacy Policy. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.

How Does KippsDeSanto & Co. Protect My Personal Information?

KDC employs physical, electronic and managerial procedures to safeguard the security and integrity of your personal information. Billing and payment data is encrypted whenever transmitted or received online. Personal information is accessible only by staff designated to handle online requests or complaints. All KDC employees, agents, personnel and contractors with access to personal information on our Site are bound to adhere to appropriate physical and technical measures to ensure the protection of personal information. But please remember that, while we use industry standard precautions to safeguard your personal information, this is not a guarantee that your information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. We cannot guarantee or warrant the security of any information you transmit to us and you do so at your own risk.

To learn more about security at KippsDeSanto & Co., please contact us at kippsdesanto@kippsdesanto.com.

California Residents

KDC is part of the Capital One family of companies. The Capital One California Consumer Privacy Act Disclosure also applies to certain information that we and other Capital One affiliates collect about California residents.

In addition, any users of the Site who are California residents are entitled to request and receive once a year, free of charge, a notice from us describing what categories of personal customer information (if any) we shared with third parties, including our corporate affiliates, for their direct marketing purposes during the preceding calendar year. If applicable, the notice will identify the categories of information that we shared, and the names and addresses of the third parties and affiliates with which we shared your information. If you are a California resident and would like to request a copy of this notice, please submit a written request to the following address: ATTN: Chief Compliance Officer, 8000 Towers Crescent Drive, Suite 1200, Tysons Corner, VA 22182 or by email at kippsdesanto@kippsdesanto.com. In your request, please specify that you want a “California Privacy Rights Notice.” Please allow at least thirty (30) days for a response.

Children

KDC is committed to protecting the privacy of children as well as adults. Neither KDC nor its Site are designed for, intended to attract, or directed toward children under the age of 18. We adhere to the Children’s Online Privacy Protection Act (“COPPA”) and will not knowingly collect personal information from any child under the age of 18, unless a parent or guardian consents to our collection and processing of such information. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, he or she should contact us at kippsdesanto@kippsdesanto.com. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information from our files.

Retention

KDC will retain your personal information for the length of time needed to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.