What personal information do we collect from the people that visit our website?
When submitting a form on our site, as appropriate, you may be asked to enter your name, email address, phone number or other details to help you with your experience.

When do we collect information?
We collect information from you when you fill out a form or enter information on our site.

How do we USE your information?
We may use the information we collect from you in the following ways:    

To send periodic emails regarding our services.      
To follow up with you after correspondence

How do we PROTECT your information?
We only provide articles and information. We never ask for credit card numbers.

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive information you supply is encrypted via Secure Socket Layer (SSL) technology.

For your convenience, we may store your information for more than 60 days.

Cookies and Web Beacons
We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) to compile data regarding user interactions and impressions. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, and number of clicks to analyze trends, administer the site, track user’s movement around the site, and gather demographic information. IP addresses, and other such information are not linked to any information that is personally identifiable, and is not shared with any third-parties.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since each browser is a little different, look at your browser's Help Menu to learn the correct way to modify your cookies. Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

Opting Out
You can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

California Online Privacy Protection Act
CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. - See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

ACCORDING TO CalOPPA, WE AGREE TO THE FOLLOWING:
Users can visit our site anonymously.

Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website.

Our privacy policy link includes the word 'Privacy' and can easily be found on the page specified above.

You will be notified of any privacy policy changes in our privacy policy page.

You can change your personal information at any time by emailing us at info@snowcm.com.

How does our site handle Do Not Track signals?
We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third-party behavioral tracking?
It's also important to note that we do not allow third-party behavioral tracking.

COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under the age of 13 years old, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States' consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.

We do not specifically market to children under the age of 13 years old.

Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify you via email within 7 business days.

We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:
Send information, respond to inquiries, and/or other requests or questions.

To be in accordance with CANSPAM, we agree to the following:
Not use false or misleading subjects or email addresses.      
Identify the message as an advertisement in some reasonable way.      
Include the physical address of our business or site headquarters.      
Monitor third-party email marketing services for compliance, if one is used.      
Honor opt-out/unsubscribe requests quickly.      
Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us at
info@snowcm.com and we will promptly remove you from future correspondence.

Contacting Us
If there are any questions regarding this privacy policy, you may contact us using the information below.

Snow Capital Management L.P.
Attn: Compliance
2000 Georgetowne Drive, Suite 200
Sewickley, PA 15143

(724) 934-5800
www.snowcm.com

Last Revised: January 30, 2019