Important Disclosures

Crawford Investment Counsel, Inc. (“Crawford”) is an independent investment adviser registered under the Investment Advisers Act of 1940, as amended. Registration does not imply a certain level of skill or training. More information about Crawford Investment Counsel, including our investment strategies, fees and objectives, can be found in our Form ADV Part 2A.

View our Form CRS

View our Form ADV Part 2A

 

A complete list of composite descriptions is available upon request. Past performance is not a guarantee or indicator of future results. These materials are for informational use only and should not be considered investment advice or an offer to sell any product. The information discussed and shown here is not a recommendation to buy or sell a particular security or to invest in any particular sector. Forward-looking statements are not guaranteed. You should not assume that any of the securities transactions, sectors or holdings discussed in these reports are or will be profitable, or that recommendations Crawford make in the future will be profitable or equal the performance of the securities discussed. There is no assurance that any securities, sectors or industries discussed herein will be included or excluded from a client’s portfolio. Crawford reserves the right to modify its current investment strategies and techniques based on changing market dynamics or client needs. The discussions, outlooks and viewpoints featured are not intended to be investment advice and do not take into account specific client investment objectives.

Crawford Investment Counsel, Inc. Privacy Policy

Last modified: January 28, 2021

Introduction

The following privacy policy (this “Policy”) governs the website (the “Website”) of Crawford Investment Counsel, Inc. (“Company” or “We”). This Policy describes:

  • The types of information we may collect or that you may provide when you register with, access, or use the Website.
  • Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies only to information we collect on or through the Website. This Policy DOES NOT apply to information that we collect offline, or that you provide to or is collected by any third party, which may have their own privacy policies that we encourage you to read before providing your information to or through them (see Third-Party Information Collection).

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. In using the Website, you agree to be bound by this Policy. If you do not accept the terms of this Policy, then you should discontinue your use of the Website.

If you are a customer, information that we receive from you through your use of our services is covered by the Privacy Notice available here and not this Policy. For our customers, if this Policy and the Privacy Notice conflict or are inconsistent, then the Privacy Notice applies to the extent of the conflict or inconsistency.

This Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Website after we revise this Policy means you accept those changes, so please check this Policy periodically for updates.

Additional Protections for Minors

The Website is not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 16. If we learn that we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us by email at info@crawfordinvestment.com, or by regular mail at 600 Galleria Parkway, Suite 1650, Atlanta, Georgia, USA 30339.

California residents under 18 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

How We Collect Information

We collect information from and about users of the Website:

  • Directly from you when you provide it to us.
  • Automatically when you use the Website.

Information You Provide Directly to Us 

When you register with, access, or use any aspect of the Website, we may ask you to provide the following types of information:

  • Information by which you may be personally identified, including but not limited to, your name, postal address, email address, and telephone number (“personal information”).

This information may be provided by you in the following ways:

  • Filling in forms on the Website. This includes information that you may provide when registering with, accessing, or using any aspect of the Website, when requesting further services, and when reporting problems with the Website.
  • Contacting us; Receiving our services. This includes information, including, but not limited to, email addresses, phone numbers, and certain financial information, that you may provide when you correspond with us, or if you are a client, information you may provide when we provide you with our services.
  • Participating in surveys. This includes information you may provide when you respond to surveys that we might ask you to complete for research purposes.
  • Searching within the Website. This includes information you may provide when you perform search queries on the Website.

If you provide information for publication or display (“Posted”) on public areas of the Website or other websites you access through the Website (collectively, “User Contributions”), then your User Contributions are Posted and transmitted to others at your own risk. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Automatic Information Collection and Tracking  

When you register with, access, or use any aspect of the Website, the Website may use technology to automatically collect:

  • Usage Details. When you access and use the Website, we may automatically collect certain details of your access to and use of the Website, including traffic data, location data, logs, and other communication data, and data regarding the resources that you access and use on or through the Website.
  • Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
  • Stored Information and Files. The Website may also access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.

If you do not want us to collect any of the above information, then you may decide not to use the Website. For more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information.

Information Collection and Tracking Technologies

The technologies we use for automatic information collection may include:

  • Cookies (or mobile cookies). A cookie is a small file placed on your computer or smartphone. It may be possible to refuse to accept cookies by activating the appropriate setting on your web browser or smartphone. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Web Beacons. The Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

Third-Party Information Collection

When you use the Website or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

  • Advertisers, ad networks, and ad servers.
  • Analytics companies. Please see additional information below, “Our Use of Google Analytics”.
  • Your mobile device manufacturer.
  • Your mobile service provider.

These third parties may use tracking technologies to collect information about you when you use the Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Our Use of Google Analytics

We use a tool called “Google Analytics” to collect information about use of this site. Google Analytics collects information such as how often users visit or use the Website, what pages users visit when they do so, and what other sites user used prior to coming to the Website. For more information regarding how Google uses such information, please visit the following website: https://www.google.com/policies/privacy/partners/.

We use the information we get from Google Analytics to improve the Website. Google’s ability to use and share information collected by Google Analytics about your visits to this the Website is restricted by the Google Analytics Terms of Use (https://marketingWebsite.google.com/about/analytics/terms/us/) and the Google Privacy Policy (https://policies.google.com/privacy). You can prevent Google Analytics from recognizing you on return visits to the Website by disabling cookies on your browser. For more information on disabling cookies on your browser, see Your Choices About Our Collection, Use, and Disclosure of Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, to:

  • Provide you with the Website and its contents, and any other information, products, or services that you request from us.
  • Fulfill any other purpose for which you provide it.
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • Notify you when updates for the Website are available, and of changes to any products or services we offer or provide.

The usage information we collect helps us to improve the Website and to deliver a better and more personalized experience by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize the Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you use the Website.

We may also use your information to contact you about goods and services that may be of interest to you. For more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information.

We may use the information we collect to display advertisements. Even though we do not disclose your personal information for these purposes, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual without restriction.

In addition, we may disclose personal information that we collect or you provide:

  • To contractors, service providers, and other third parties we use to support our business.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about the Website’s users is among the assets transferred.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce our rights arising from any contracts entered into between you and us and for billing and collection.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

Your Choices About Our Collection, Use, and Disclosure of Your Information

This section describes mechanisms that you may use to control certain uses and disclosures of your information.

  • Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you disable or refuse cookies or block the use of other tracking technologies, some parts of the Website may then be inaccessible or not function properly.
  • Promotion by the Company. You can opt-out of receiving promotional materials by selecting “unsubscribe” in emails we send to you.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Consent to Electronic Delivery. If you are our client, under your agreement with us you have consented to our delivery of any and all documents and information (including regulatory forms such as Form ADVs and privacy notices) by electronic means, including, without limitation, by email, weblink or other form of electronic delivery to the fullest extent permitted by applicable law (such electronic delivery methods individually and collectively “Electronic Delivery”). Your consent to Electronic Delivery became effective immediately upon your execution of your advisory agreement with us and remains effective until withdrawn in writing by you.

Accessing and Correcting Your Personal Information

You may send us an email at info@crawfordinvestment.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Your California Privacy Rights

The following additional privacy notices for California residents (the “California Notice”) supplement the information contained in the other portions of this Policy and apply solely to individuals who reside in the State of California (“California consumer” or “you”). The Company adopts this California Notice to comply with the California Consumer Privacy Act and its related regulations (the “CCPA”) and other applicable California laws.

Overview of Consumer Rights Under the CCPA

Under the CCPA, California consumers have certain rights regarding their personal information, including:

  • The right to know the categories of personal information that the Company has collected and the categories of sources from which we obtained such information.
  • The right to know the Company’s business purposes for sharing personal information.
  • The right to know the categories of third parties with whom the Company shared personal information.
  • The right to access the specific pieces of personal information that the Company has collected and the right to delete your personal information.
  • The right to not be discriminated against if a California consumer exercise their rights under the CCPA.

The provisions below of this California Notice provide further details about these rights and how you may exercise them.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer, household or device (collectively, “personal information”). Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated California consumer information.
  • Information excluded from the CCPA’s scope, including:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
  • Personal information covered by certain other laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We have collected the following categories of personal information from California consumers within the last twelve (12) months:

 

Category Examples
A.  Identifiers An individual’s name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number or other similar identifiers
B.  Personal information categories described in Cal. Civ. Code § 1798.80(e) A 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
C.  Protected classification characteristics under California or federal law Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D.   Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
E.   Internet or other similar network activity Browsing history, search history, information on a California consumer’s interaction with a website, application, or advertisement
F.  Geolocation data Physical location or movements
G.  Professional or employment-related information Current or past job history or performance evaluations
H. Inferences drawn from other personal information Examples include a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes

 

Sources of Personal Information

In addition to sources of personal information addressed elsewhere in this Policy, we obtain the categories of personal information listed above from the following categories of sources:

  • Directly From You. For example, from forms you complete or products and services you purchase or from communications with you such as when you contact the Company (whether in person, by mail, by phone, online, via electronic communication or by other means) including our customer support service.
  • Indirectly From You. For example, from observing your actions on our Website or from products or services that you have purchased from the Company, if you have enabled such functionality, such as telemetry services.
  • From Others. From third party service providers. For example, if you choose to make an electronic payment directly to the Company, or through a linked website or mobile application, or through an affiliate of ours, the Company may receive personal information about you from third parties such as payment services providers, for the purposes of that payment.
  • From Public Sources. For example, we may collect information from public records.

Uses of Personal Information

In addition to uses of personal information addressed elsewhere in this Policy, we may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill the reason that you provided the information. For example, if you share your name and contact information to request a fee information, request to be contacted by an affiliate, or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we may use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product or service orders or to process returns.
  • To perform services such as customer service, order fulfillment, payment processing, financing and advertising, marketing or analytic services.
  • To advance our commercial or economic interests, such as by helping you to buy, rent, lease, join, subscribe to, provide, or exchange products, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.
  • To verify or maintain quality or safety standards or improve or upgrade a product or service provided or controlled by or for us.
  • To provide, support, personalize and develop our Website, products and services such as to perform warranty related services or other post-sale activities such as product or service monitoring or repairs.
  • To create, maintain, customize and secure your account with us.
  • To process your requests, purchases, transactions and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites and via mail, email or text message (with your consent, where required by law).
  • To help maintain the safety, security and integrity of our Website, products and services, databases and other assets and business.
  • For testing, research and analysis purposes, including to develop and improve our Website, products and services.
  • To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA or applicable law.
  • To send you information relevant to your past purchases and interests, subject to compliance with applicable laws regarding direct marketing.
  • To otherwise use as reasonably necessary and proportionate to achieve our operational or notified purpose for collecting personal information and as compatible with the context in which we collected the information.
  • To perform services on behalf of a CCPA-covered business or its service provider, such as customer service, order fulfillment, payment processing, financing and advertising, marketing, or analytic services.
  • To review and audit our business interactions with you.
  • To detect or prevent security incidents or other illegal activity.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users, including California consumers, is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you notice.

Sharing Personal Information

All financial companies need to share client personal information to run their everyday business.  We use information about you to provide our asset management services to you.  We may disclose the information to third parties as permitted by law, including the broker/dealers, custodians or other companies used to provide services to you.  From time to time, we may be required to give information about our business to regulatory authorities.  This may include personal information about you. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, the Company has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers

Category B: Personal information categories described in Cal. Civ. Code § 1798.80(e)

Category C: Protected classification characteristics under California or federal law

Category D: Commercial information

Category E: Internet or other similar network activity

Category F: Geolocation data

Category G: Professional or employment-related information

Category H: Inferences drawn from other personal information

The categories of third parties to which we may disclose personal information collected by us include service providers and recipients of data from cookies.

Sales of Personal Information

The Company does not sell personal information to third parties.

Exercising Your CCPA Rights and Choices

The sections below describe how you may exercise your rights under the CCPA.

Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability and Deletion Rights below), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we disclosed your personal information for a business purpose, a list disclosing:
  • the personal information categories that each category of recipient obtained.

As allowed by the CCPA, we do not provide these access and data portability rights (i) for business-to-business personal information or (ii) as to personal information collected from the Company’s California-based employees, job applicants or contractors when provided or collected in such employee, job applicant or contractor capacities.

Deletion Request Rights. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability and Deletion Rights”, below), we will delete (and direct our service providers to delete) your personal information from our (and service provider) records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products or services to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another California consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with California consumer expectations based on your relationship with us, such as future field campaigns or product safety issues.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

As allowed by the CCPA, we do not provide these deletion rights (i) for business-to-business personal information or (ii) as to personal information collected from the Company’s California-based employees, job applicants or contractors when provided or collected in such employee, job applicant or contractor capacities.

Exercising Access, Data Portability and Deletion Rights. To exercise the access, data portability and deletion rights described above, you should submit a verifiable consumer request to us by one of the following methods:

  • Emailing us at: info@crawfordinvestment.com
  • By postal mail at: ATTN: Compliance Dept. 600 Galleria Parkway, Suite 1650, Atlanta, Georgia, USA 30339
  • Accessing your online account that you maintain with us.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of a minor child for whom you are a parent or legal guardian.

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative, which may include:

  • Your name
  • Your address
  • Additional information depending upon the type of request and the sensitivity of the information involved with such request
  • Describe your request with sufficient detail to enable us to properly understand, evaluate and respond to such request.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or your authority to make the request and confirm that the personal information involved with the request relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we will consider requests made through a password-protected online account that you maintain with us to be sufficiently verified when the request relates to personal information associated with that online account, provided such online account functionality is then made available by us on the Website.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

If you have an online account with us, we may deliver our written response to that online account, provided that such online account functionality is then made available by us on the Website. If you do not have an online account with us, or such functionality is not available for your online account we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the twelve (12) month period immediately preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA or other applicable law, we will not as a result of you exercising any of your rights under the CCPA:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services; or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California Privacy-Related Disclosures

Sharing Personal Information for Direct Marketing Purposes. Before sharing personal information of California consumers with third parties for direct marketing purposes we will obtain opt-in consent from the applicable California consumers or provide such California consumers with a cost-free method to opt out.

California Do-Not-Track Disclosure. At this time, the Website is not set up to honor web browser do-not-track settings.  Do-not-track is a privacy preference that users can set in their web browsers. When a user activates the do-not-track settings in browsers that offer this setting, the browser sends a message to websites or applications requesting them not to track the user. For more information about do-not-track matters, please visit www.allaboutdnt.org.

Information on Marketing Disclosures. California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at: info@crawfordinvestment.com or ATTN: Compliance Dept. 600 Galleria Parkway, Suite 1650, Atlanta, Georgia, USA 30339.

Content Removal Requests for Website Users Under 18 Years Old. If you are a Website user under 18 years of age and reside in California, you may request and obtain removal of, content or information that you have posted on the Website. You may send us any such requests by one of the following methods: (i) by email (writing “Privacy Policy – Removal Request” in the subject line) at info@crawfordinvestment.com; or (ii) by writing to us at ATTN: Compliance Dept. 600 Galleria Parkway, Suite 1650, Atlanta, Georgia, USA 30339.  We will review the request and respond promptly.  You should be aware that a request to remove content or information posted by you on the Website does not ensure or require complete or comprehensive removal of such content or information from our databases.

Complaints

If you have any complaint about use of the Website, you may contact us by email at info@crawfordinvestment.com, or by postal mail at ATTN: Compliance Dept. 600 Galleria Parkway, Suite 1650, Atlanta, Georgia, USA 30339. In accordance with California Civil Code Section 1789.3, California residents may also file complaints with the Complaint Assistance Unit, Division of Consumer Services, California Department of Consumer Affairs by postal mail at 1625 North Market Road, Suite N112, Sacramento, CA 95834 or by telephone at 800-952-5210.

Changes to Our California Notice

We reserve the right to amend this California Notice at our discretion and at any time. When we make changes to this California Notice, we will post the updated California Notice on the Website and update the California Notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Your EU Privacy Rights

Persons who are residents of the member countries of the European Union (“EU”) or other data subjects covered by the EU’s General Data Protection Regulation, (EU) 2016/679 (the “GDPR”), have certain additional privacy rights under applicable law. The following provisions of this Section 12 provide an overview of these additional rights.

Legal Bases for Processing Personal Information of European Union Citizens

When processing your personal information, the Company may rely on one or more of the following legal bases (or other available legal grounds), depending on the circumstances:

  • Legitimate Interests. The Company may process your personal information where the Company has a legitimate interest in such processing for managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights or freedoms.
  • The Company may process your personal information where the Company has obtained your consent to the processing.
  • Contractual Necessity. The Company may process your personal information where such processing is necessary in connection with any contract that the Company has with you.
  • Legal Requirements. The Company may process your personal information where such processing is required by applicable law.

Disclosures to Third Parties

Your personal information will not be disclosed to third parties except for where it is necessary for fulfillment of the Company’s obligations to you or where the Company is obliged or permitted to do so by law (including, without limitation, through the terms of any agreement the Company may have with you), or where the Company makes disclosures that are otherwise consistent with the uses described in this Policy.

The Company may also disclose any information (including personal information) relating to you to law enforcement authorities or any regulatory or government authority in response to any request including requests in connection with the investigation of any suspected illegal activities.

The Company reserves the right to transfer any personal information the Company has about you in the event the Company sells or transfers all or a portion of our business or assets, or merges with another organization. Should such a sale, transfer or merger occur, the Company will use reasonable efforts seeking to require that the transferee uses personal information you have provided to the Company in a manner that is consistent with this Policy.

The Company will not sell, resell or lease your personal information to any third parties but the Company may, if required for the purpose(s) for which your personal information was collected and processed, share it with the Company partners and/or service providers to enable them to provide their services to the Company or to you, as applicable. The foregoing are in addition to the other uses described elsewhere in this Policy.

Security of Personal Information of European Citizens

The Company has policies and technical and organizational measures in place which are intended to safeguard and protect your personal information against unauthorized access, accidental loss, improper use and disclosure. However, you should be aware that information transmitted over the internet is not completely secure because of the nature of the internet and that systems and measures used to secure information are not flawless. For these reasons, although the Company will use reasonable efforts to protect your personal information, the Company does not warrant the security of personal information transmitted to the Company or stored by the Company, and personal information that is transmitted to the Company by you electronically is done at your own risk.

Retention of Personal Information of European Citizens

The Company’s policy is to retain your personal information only for as long as is necessary to fulfill the purposes for which the Company collected such personal information, including for the purposes of satisfying any professional, legal, accounting or reporting requirements to which the Company is subject. To determine the appropriate retention period for personal information, the Company considers the scope, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which the Company collected and processed your personal information and whether the Company can achieve those purposes through other means, and any applicable legal and professional requirements.

Your Rights as a European Citizen

You have a number of rights concerning your personal information that the Company holds and uses, including the following:

 

  • Right of Access. You have the right to be informed about what personal information the Company holds about you and to a copy of this personal information.
  • Right to Rectification. You have the right to have any inaccurate personal information which the Company holds about you updated or corrected.
  • Right to Erasure. In certain circumstances you may request that the Company delete the personal information that the Company holds about you.
  • Right to Complain. You have the right to lodge a complaint regarding the processing of your personal information to an applicable governmental or supervisory authority in your country.
  • Right to Withdraw Consent. Where processing of personal information is based on your consent, you have the right to withdraw such consent at any time.
  • Right to Object. Where the Company relies on our legitimate interests to process your personal information, you have the right to object to such use and the Company is required to discontinue such processing unless the Company can demonstrate an overriding legitimate interest in such processing.
  • Right to Restriction. You have the right to request that the Company stop using your personal information in certain circumstances including if you believe that the personal information the Company holds about you is inaccurate or that the Company’s use of your personal information is unlawful. If you validly exercise this right, the Company will store your personal information and will not carry out any other processing until the issue is resolved.

You may exercise any of the above requests in writing to the Company via email at info@crawfordinvestment.com, or via regular mail at ATTN: Compliance Dept. 600 Galleria Parkway, Suite 1650, Atlanta, Georgia, USA 30339. You are also free at any time to request that the Company stop using your personal information for marketing purposes by writing to the Company via email at info@crawfordinvestment.com, or via regular mail at ATTN: Compliance Dept. 600 Galleria Parkway, Suite 1650, Atlanta, Georgia, USA 30339.

Changes to Our Privacy Policy

We may update this Policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the most recent privacy policy on this page.

The date that this Policy was last revised is identified at the top of the page. You are responsible for periodically visiting this Policy to check for any changes.

Contact Information

To ask questions or comment about this Policy and our privacy practices, contact us via email at info@crawfordinvestment.com, or via regular mail at ATTN: Compliance Dept. 600 Galleria Parkway, Suite 1650, Atlanta, Georgia, USA 30339.