1. INTRODUCTION

Brydon Group LLC (“Brydon”, “we”, “us”) has created this privacy policy (“Privacy Policy”) in order to set out how we collect, use, and disclose information through our website located at www.brydonhealth.com (the “Website”) as well as our related, affiliated and/or subsidiary companies (collectively the “Services”), unless another applicable privacy policy applies to such Service.

Your privacy is very important to us. By visiting our Website and/or using the Services in any manner, you acknowledge that you have read the practices and policies outlined in this Privacy Policy and you understand that your information will be collected, used and disclosed in accordance with this Privacy Policy. If you do not agree with our policies and practices, you should not use the Website or the Services.

2. WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy describes our collection, use and disclosure of information, including information which can be used to identify an individual (“Personal Information”). Personal Information does not include any anonymized information which we may create or derive from information (including Personal Information) you provide to us.

Personal Information may be collected about employees, prospective customers, and visitors to the Website. You can choose not to provide us with certain Personal Information, but by doing so, you may not be able to use certain features and functionality of our Services.

This Privacy Policy does not apply to the practices of companies that we do not own or control. Such companies are responsible for maintaining their own privacy policies governing the collection, use and disclosure of Personal Information and for ensuring that they have obtained the necessary authorizations and consents for any Personal Information made available to us for use in accordance with this Privacy Policy.

3. COLLECTION AND USE OF PERSONAL INFORMATION AND OTHER DATA

Types of information we collect
The categories of Personal Information we may collect include:

• Contact Data, such as first name, last name, email address and phone number.
• Marketing Data, such as your preferences in receiving marketing materials from us, the content of your communications, and the date and time of any such communications.
• Location data, such as geolocation information.
• Account Data, such as your email address and password.
• Any other information you voluntarily provide to us.

We may also collect certain other types of information that may not specifically identify you, but may be unique to your device, such as:

• Technical Data, which includes information collected via cookies and similar technologies (and identifiers associated with those cookies and technologies), internet protocol (IP) address, cookie data, your mobile or internet service provider, mobile device identifier, browser type, and operating system.
• Usage Data, which includes information about how you use our Services, your access times, pages viewed, and the routes by which you access or exit our Services.

We collect and use your information for the following purposes:

• To create your account
  To use certain Services (such as to manage funds, investments and access documents), users may be required to create a valid account. When you register for the Services, Brydon may collect your name, email address, birth date, zip or postal code, and your phone number.

Brydon uses account data to authenticate access to your account and provide access to the Services. We may also use this information to better understand, improve and personalize the delivery of our Services and related products, to conduct our business, to develop analytics and aggregated data that allow us to improve our Services and related products, or to correspond with you including to send alerts, updates and administrative messages.

We may also use information to investigate and prevent fraudulent transactions, unauthorized access to the Services, and other unlawful activities.

• To contact prospective partners
  We collect names, email addresses and other business contact information about individuals who we consider to be prospective business partners (“Prospects”). We may use third-party service providers to collect, store and process Personal Information about Prospects and to identify Prospects and locate contact information to contact Prospects about our products and services.
• To send marketing communications
  With your consent, we use your email address as well as other information on an optional basis to help us tailor our communications to you. You will receive email message communications from us or our partners regarding our or our partners’ products, services and initiatives (including collaborations and partnerships).
• To improve our products and services
  Brydon may use demographic information that we collect about our users for our own business purposes, including forecasting demand for our products and services, improving our products and services and creating a personalized experience. Personal Information is not shared with third parties for these purposes.
• To assist you when you contact us
  When you contact us with a comment, question or complaint through email, telephone, or message features available on the Services, you may be asked for information that identifies you, such as your name, address and a telephone number, along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future and to improve our customer service and service offerings.
• To assess your application for employment
  If you apply for a job with us, we may collect certain personal information about you (such as information that would be contained in a resume, cover letter, or other employment-related materials). We use this information for the purpose of processing and responding to your application.
• Aggregate or De-identified Data
  We may aggregate or de-identify Personal Information, including information that we may receive from Practices, so that it does not personally identify you (“De-identified Data”). We may collect, use and disclose De-identified Data for our business purposes and any purpose permitted by law. In some instances, we may combine De-identified Data with Personal Information. If we combine any De-identified Data with Personal Information, the combined information will be treated by us as Personal Information.

4. MINORS

Brydon does not knowingly solicit or collect data from children nor knowingly market to anyone under the age of 16. If you are under the age of 16, you are explicitly not authorized to use these Services.

5. WEBSITE INFORMATION

In general, you can visit our Website without telling us who you are or creating an account. However, like many internet and mobile services, we may automatically gather certain information about our Services traffic and store it in log files. This information may include mobile device identifiers, browser type, IP address, mobile or internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, to administer the Services, to understand users’ movements around the Services. We may link this automatically collected data to Personal Information. Device identifiers may be tied to Personal Information to troubleshoot access issues.

Log Files
We may automatically gather certain information about our Service’s traffic and store it in log files. This information includes mobile device identifiers, browser type, IP address, mobile or internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data.

Cookies and other tracking technologies
Cookies are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings. We may also use:

• Local storage technologies like HTML5
• Web beacons (pixel tags or clear GIFs)

Categories of cookies:

• Essential – Required for basic site functionality
• Functionality / performance – Improves features and performance
• Analytics – Understands site usage (e.g., via Google Analytics)

Opt out of Google Analytics: https://tools.google.com/dlpage/gaoptout

Clickstream
We may collect clickstream data to understand how users move through our Website. This information is anonymous and used to improve functionality and experience.

Third Party Links and Social Networking Services
Our Website may link to external sites, each governed by their own privacy policy. Information you post publicly (blogs, forums, etc.) may be viewed or used by others.

6. DISCLOSURE OF INFORMATION

Service Providers
We share Personal Information with service providers for tasks such as web hosting, analytics, marketing, and technical support.

Marketing
We may share de-identified data for analytics, improvement, or business operations.

Business Transfers
Personal Information may be transferred during mergers, acquisitions, or other changes of control.

With Your Consent
We’ll request your consent for new or unexpected uses of your information.

Legal Compliance
We may disclose information to comply with legal obligations, detect or prevent fraud, or exercise legal rights.

7. RETENTION

We retain your Personal Information only as long as needed for legal or business purposes, including fraud prevention, account recovery, and auditing.

8. OPT-OUT CHOICES

• Email us at info@brydon.com to opt-out of third-party sharing or revoke consent.
• Unsubscribe from promotional emails via the unsubscribe link.
• Adjust cookie preferences in your browser settings.
• Note: You may still receive essential transactional emails.

9. SECURITY

We use commercially reasonable measures to protect Personal Information. However, no method of transmission is 100% secure. If you believe your data may be at risk, contact us immediately.

10. CALIFORNIA CONSUMER NOTICE

California residents have the right to:

• Request access to collected data
• Request deletion or correction
• Request a portable copy of your data
• Opt out of sale or targeted advertising (we don’t sell data)

Email privacy-related requests to info@brydon.com. We may verify your identity before responding. You may also appoint an authorized agent.

11. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically. Any changes will be posted on this page with the updated date. Major changes may also be communicated via email or on the Website.

12. CONTACT US

Questions? Please reach out:

Email: info@brydon.com
Phone: (202) 972-4620
Address:
2000 Pennsylvania Avenue, Suite 4006
Washington, D.C. 20006

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