This Privacy Policy applies to information we collect: 

• Through the Website. 

• In communications, including email, text, chat, and other electronic messages, between you and the Website. 

• When you interact with our advertising and content on third-party websites and services, if that advertising or content links to this policy. 

• Offline or through other means, including over the phone, through the mail, in person, or from third parties. 

This Privacy Policy does not apply to: 

• Information collected by third parties.  If you have questions about how a third party collects, uses, or discloses your personal information, you should contact them directly. 

• Individuals outside of California with whom we only have a business-to-business relationship. 

• Our personal information collection practices specifically through myConradSiegel and the management of retirement and benefits plans.  For more information, please review the myConradSiegel privacy policy available at [https://www.myconradsiegel.com/privacy_policy.aspx]. 

Accessing the Website 

Except as required by law, all information we receive in the course of providing our services is held in strict confidence. We conduct our business with a strong understanding of the need to protect our clients’ confidential information. We will share your personal information for our everyday business purposes—such as processing your transactions, maintaining your account(s), responding to court orders and legal investigations, or running address search reports with credit bureaus. Personal information is accessed by our employees only in the performance of their jobs. Conrad Siegel will only discuss your personal information with you and, with your permission, the people who handle and assist in the management of your financial matters. 

We do not sell or market your personal information or personalized data to unaffiliated organizations. Unless you ask us not to, we may use this information (including your email address) to inform you of products, services, or other opportunities that may be available through either Conrad M. Siegel, Inc. or Conrad Siegel Investment Advisors, Inc. We do not share your personal information about your transactions, except for our affiliates’ everyday business purposes. We will not sell or market your information to any mailing list or to any unaffiliated organizations. 

Federal law gives you the right to limit the sharing of personal information for affiliates’ everyday business purposes and marketing to you. State laws and individual companies may give you additional rights to limit sharing. If you limit our sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. To limit our sharing, please contact a customer service representative. See Contact Us for our hours and telephone number. 

By law, we would release your personal information upon receipt of a valid court order, warrant, subpoena or your written authorization (with proper verification of your identity).  

Collection of Personal Information 

We collect personal information as necessary to provide the Website and our other services.  “Personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  The personal information we collect includes: 

• Full name 

• Home and mailing address 

• Email address 

• Phone number 

• Employment information 

• Electronic data, including IP address and device identifiers 

• Approximate geolocation data 

In the last 12 months, we have collected the following categories of personal information: 

Personal Information Category	Collected
Identifiers, such as real 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.	Yes
California Customer Records personal information, which includes 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. Some personal information included in this category may overlap with other categories.	Yes
Protected classification characteristics under California or federal law, such as 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, reproductive health decision-making, military and veteran status, or genetic information (including familial genetic information).	Yes
Commercial information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
Internet or other similar network activity, such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
Approximate geolocation data.	Yes
Sensory data, such as audio, electronic, visual, thermal, olfactory, or similar information.	Yes
Professional or employment-related information, such as current or past job history or performance evaluations.	Yes

Please note that while the tables above include examples of each category of personal information and sensitive personal information, we do not necessarily collect every example listed. 

We retain personal information for as long as necessary to provide our services to you, as required by law, and for compliance and reporting purposes. 

We also collect: 

• Statistics or aggregated information.  Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information.  For example, we may aggregate personal information to calculate the percentage of users who access a specific feature on the Website. 

• Technical information.  Technical information includes information about your internet connection and usage details about your interactions with the Website, such as clickstream information to, through, and from the Website (including date and time), content and pages that you view or search for, page response times, download errors, length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from a page. 

If we combine or connect non-personal statistical or technical data with personal information in a way that directly or indirectly identifies an individual, we will treat the combined information as personal information. 

How We Collect Personal Information 

As described in more detail below, Conrad Siegel collects your personal information when you interact with and use the Website, including when you enter it into forms and pages on the Website.  We also collect your personal information from other companies.  

Personal Information You Provide to Us 

We collect personal information from and about you when you interact with and use the Website, including when you enter it into forms and pages on the Website.  We also collect personal information from you when you provide it to us directly over the phone, by mail, by email or other electronic message, or through any other direct communication. 

Information We Collect Automatically 

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect information that may include personal information.  Information collected automatically may include usage details, IP addresses, operating system and browser type, and information collected through cookies, web beacons, and other tracking or analytics technologies including details of your interactions with our Website, such as traffic data, location data, logs, and other communication data, and which resources and pages you access and use. 

Using automatic collection technologies helps us to improve our Website and services and deliver a better and more personalized experience. 

The technologies we use for automatic data collection and analytics may include: 

• Cookies (or browser cookies). A cookie is a small file stored on your computer or mobile device. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser settings to refuse cookies, our system will issue cookies when you visit our Website.  The types of cookies we use include essential, functional, marketing, and advertising cookies. 

• Web Beacons. Pages of our 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 us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). 

• Session replay tools. To better understand our users’ needs and to optimize this Website, we may use session replay tools, such as Hotjar. Session replay helps us better understand our users’ experience, including how much time they spend on which pages, which links they click, what they do and do not like, etc.  Some session replay tools may allow us to visually represent where users click, move, and scroll on our Website.  This type of technology enables us to build and maintain our Website with user feedback. Session replay tools may use cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address, device screen size, device type (unique device identifiers), browser information, geographic location, and the preferred language for displaying our Website. 

• Google Analytics. We use Google Analytics to optimize our Website and services based on the traffic we receive and assist with marketing. To learn more about Google Analytics, including options for opting out and/or managing the ads you may see online please visit https://policies.google.com/technologies/partner-sites. Additional information regarding online advertising is available at: https://www.networkadvertising.org/understanding-online-advertising/what-are-my-options. To learn more about targeted advertising and the choices available to you, visit WebChoices:  Digital Advertising Alliance’s Consumer Choice Tool for Web US. 

• Hotjar. We use Hotjar on our Website to better understand how our users interact with it and to optimize our Website and user experience. Hotjar allows us to visualize user interactions so we can better understand our users’ experience and improve our services by identifying issues and friction points. To provide these services, Hotjar uses first-party cookies and other technologies to collect information on our users’ behavior and their devices on our behalf. This may include personal information like online identifiers (e.g., device’s IP address, user ID), technical data (e.g., device type and screen size, browser information), geographic location (country only), behavioral data (interactions with our Website, such as clicks, taps, scrolls), and any additional personal information that may explicitly be submitted through Hotjar.  Hotjar automatically suppresses and masks sensitive data that may be entered on our Website; therefore, personal information such as identification data (e.g., name, email address) and payment data (i.e., credit card numbers) is anonymized before reaching Hotjar’s servers. Hotjar may reuse this personal information to develop and improve tools and services for us and our users. The use of Hotjar is limited to the Website only.  For further details, please visit Hotjar’s Trust Portal and Privacy Policy. 

When you interact with the Website, third parties may use automated data collection technologies to collect information about you or your device.  These third parties may include analytics companies, your device manufacturer and operating system developer, your internet or mobile service provider, or others.  These third parties may use tracking technologies to collect information about you when you visit or use the Website.  The information they collect may be associated with your personal information, or they may collect information, including personal information, about your activities over time and across different websites, apps, platforms, and other online services. 

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 provider directly. 

How We Use Your Personal Information 

We use the personal information that we collect about you or that you provide to us to: 

• Provide you with the Website and any contents, features, information, products, or services that we make available through the Website. 

• Provide you with the products and services that we offer or that you request from us. 

• Fulfill and manage your purchases, orders, transactions, and other requests. 

• Improve our Website, including by analyzing your information and creating aggregated data derived from your information to develop, maintain, analyze, improve, optimize, measure, and report on our Website and its features and how users interact with them. 

• Promote our service, business, and offerings to you. 

• 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 Website updates are available and about changes to any products or services we offer or provide through it. 

We may also use your personal information in any other way we may describe when you provide it, or for any other purpose with your consent. 

The usage data we collect, whether connected to your personal information or not, helps us improve the Website and 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 needs and interests. 

• Speed up your searches. 

• Recognize you when you return to the Website. 

Disclosure of Your Personal Information 

We may disclose aggregated and/or non-identifiable information about users of the Website without restriction. 

We may also disclose personal information that we collect, or you provide, as described in this Privacy Policy: 

• To our subsidiaries and affiliates. 

• To contractors, service providers, and other third parties we use to support our organization and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. 

• 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 Conrad Siegel’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Conrad Siegel is among the assets transferred. 

• To fulfill the purpose for which you provide it. 

• For any other purpose disclosed by us when you provide the information. 

• With your consent. 

We may also disclose your personal information: 

• To comply with any court order, law, or legal process, and as necessary to respond to any government or regulatory request. 

• To enforce or apply our terms and conditions of use [https://conradsiegel.com/terms-of-use/] and other agreements, including for billing and collection purposes. 

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, our clients, or others, consistent with applicable law. 

In the past 12 months, we have disclosed the following categories of personal information: 

Personal Information Category	Business Purpose Disclosures	Sold or Shared
Identifiers.	Affiliates and subsidiaries Service providers and contractors Operating systems Analytics vendors Customer-directed entities	No
California Customer Records contains personal information.	Affiliates and subsidiaries Service providers and contractors Operating systems Customer-directed entities	No
Protected classification characteristics under California or federal law.	Affiliates and subsidiaries Service providers and contractors Operating systems Customer-directed entities	No
Commercial information.	Affiliates and subsidiaries Service providers and contractors Operating systems Customer-directed entities	No
Internet or other similar network activity.	Affiliates and subsidiaries Service providers and contractors Operating systems Analytics vendors Customer-directed entities	No
Approximate geolocation data.	Affiliates and subsidiaries Service providers and contractors Operating systems Analytics vendors Customer-directed entities	No
Sensory data.	Affiliates and subsidiaries Service providers and contractors Operating systems	No
Professional or employment-related information.	Affiliates and subsidiaries Service providers and contractors Operating systems Customer-directed entities	No

Sensitive Personal Information Category	Business Purpose Disclosures	Sold or Shared
Government identifiers.	Affiliates and subsidiaries Service providers and contractors Operating systems Customer-directed entities	No
Complete account access credentials.	Affiliates and subsidiaries Service providers and contractors Operating systems	No
Citizenship or immigration information.	Affiliates and subsidiaries Service providers and contractors Operating systems Customer-directed entities	No

“Do Not Track” and User Preference Signals 

We will honor “do not track” and other user preference signals, including universal opt-out mechanisms, as required by applicable law and consistent with industry standards. 

Your State Privacy Rights 

Certain state consumer privacy laws provide their residents with additional rights regarding our use of their personal information.  These rights are described below. 

The Right to Know and to Confirm, and the Right to Data Portability 

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 12 months (the “right to know” and the “right to confirm”). Once we receive your request and confirm your identity, we will disclose to you: 

• The categories of personal information that we collected about you. 

• The categories of sources for the personal information we collected about you. 

• Our business or commercial purpose for collecting or selling that personal information. 

• The categories of third parties with whom we share that personal information. 

• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: 

• Sales, identifying the personal information categories that each category of recipient purchased; and  

• Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. 

• The specific pieces of personal information we collected about you (also called a “data portability” request). 

• If you submit a data portability request, we will provide you with a copy of your personal information in a common and portable format that you may transfer to another organization of your choosing. 

The Right to Delete 

You have the right to request that we delete any of your personal information that we have collected and retained from you, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity, we will review it to determine whether an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:  

1. Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing relationship with you, or otherwise perform our contract with you. 

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 

3. Debug products to identify and repair errors that impair existing intended functionality. 

4. Exercise free speech, ensure the right of another individual to exercise their free speech rights, or exercise another right provided for by law. 

5. Comply with specific laws, such as the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). 

6. 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. 

7. Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us. 

8. Comply with a legal obligation. 

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it. 

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action. 

The Right to Correct Inaccurate Information 

You have the right to correct any inaccurate personal information about you that we have in our possession (the “right to correct”).  Once we receive your request and confirm your identity, we will disclose to you the specific pieces of personal information that we have collected about you.  You will then have the opportunity to direct us to correct any information you believe is inaccurate. 

We may deny your request to correct if we believe the updated information is incorrect or is being used for any fraudulent or deceptive purpose. 

The Right to Restrict Sensitive Personal Information Processing 

You have the right to restrict our processing of your sensitive personal information (the “right to restrict”).  Once we receive your request and verify your identity, we will cease the processing of your sensitive personal information for inferring characteristics about you.  Please note that we may continue to process your sensitive personal information for other purposes consistent with this Privacy Policy. 

The Right to Opt Out of the Processing and Sale of Personal Information 

You have the right to direct us not to process your personal information for targeted advertising and not to sell your personal information at any time (the “right to opt-out”). Once we receive your request, we will no longer use or process your personal information to provide targeted advertising to you based on your activity and interests.  We will also no longer sell (as that term is defined by relevant and applicable state law) your personal information to third parties for targeted advertising purposes. 

The Right to Opt Out of the Sharing of Personal Information for Cross-Contextual Behavioral Advertising 

You have the right to opt out of the sharing of your personal information with third parties for cross-contextual behavioral advertising.  Once we receive your request, we will no longer use or process your personal information for advertising purposes based on your individual activity. 

The Right to Opt Out of Targeted Advertising 

You have the right to opt out of the use of your personal information for targeted advertising.  Once we receive your request, we will no longer use or process your personal information for targeted advertising directed to you. 

The Right to Opt Out of Profiling 

You have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects on you.  Once we receive your request, we will no longer use or process your personal information to make decisions that have a legal or similarly significant effect on you. 

The Right to Be Free from Discrimination 

We will not discriminate against you for exercising any of your rights under applicable state privacy law.  Unless permitted by state law, we will not: 

• 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 with a different level or quality of goods or services. 

• 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 state privacy law that can result in different prices, rates, or quality levels. This may include loyalty and rewards programs. Any legally permitted financial incentive we offer will reasonably relate to the value of your personal information and will 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. 

Exercising Your Rights 

To exercise your rights described in this Privacy Policy, you may submit a request to us by: 

• Sending us a message online at https://conradsiegel.com/contact-us/  

• Calling us at (717) 652-5633 

• Mailing us at Conrad M. Siegel, Inc., Attn: Privacy Concern Officer, PO Box 5900, Harrisburg, PA 17110-0900 

Only you or someone legally authorized to act on your behalf may make a request related to your personal information.  You may also make a request on your child’s behalf.  You may only submit a request twice within 12 months. 

We may not require you to provide additional personal information to verify your identity for opt-out requests.  However, to process other requests, we may require you to: 

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: 

• Providing at least three (3) pieces of information that match the information we have about you. 

• Providing a signed declaration, under penalty of perjury, that you are the individual about whom you have submitted the request, or that you are legally authorized to submit the request on the individual’s behalf. 

• Describe your request with sufficient detail that allows us to understand, evaluate, and respond to it properly. 

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 that the personal information relates to you. 

You do not need to create an account with us to submit a request.  We will only use the personal information provided in the request to verify the requester’s identity or authority to make it. 

You may appeal a decision concerning your privacy rights by contacting us online at https://conradsiegel.com/contact-us/, or through the mail at Conrad M. Siegel, Inc., Attn: Privacy Concern Officer, PO Box 5900, Harrisburg, PA 17110-0900. 

Response Timing and Format 

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us online at https://conradsiegel.com/contact-us/, or by calling (717) 652-5633. 

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

If you have an account with us, we may deliver our written response to that account. Alternatively, or if you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 

Any disclosures we provide will only cover the 12 months preceding our receipt of your request. 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 allows you to transmit the information from one entity to another 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 explain why and provide a cost estimate before completing your request. 

Website Security and Protection of Your Personal Information 

Your personal information is kept private through multiple security features and procedures that comply with federal law. These measures include computer safeguards and secured files and buildings. See our Security Policy for additional details. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Website. The safety and security of your personal information also depend on you. Where we have given you (or you have chosen) a password for access to certain parts of the Website, you are responsible for keeping it confidential. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. 

Links to Other Websites 

The Website may contain links to other websites. The privacy and security policies of Conrad Siegel apply only to our respective websites. Before accessing other external websites, please review their privacy and security policies. 

Transfer of Information 

Your personal information may be transferred and maintained on computers located outside of your state, province, country, or other jurisdiction where the data protection laws may differ. If you are located outside the United States and choose to provide information to us, note that we transfer the data, including but not limited to personal information, to the United States and process it there. Your use of the Website and submission of such information represent your consent to our Privacy Policy, any terms of use, and to the transfer of your personal information. We will take reasonable steps to ensure your personal information is handled securely and not transferred to any organization or country unless appropriate security controls are in place. 

Children’s and Minor’s Personal Information 

The Website is not intended to be used by, and we do not knowingly collect personal information directly from, children under the age of 18.   

Contact Information 

If you have any questions regarding this Privacy Policy, please contact a customer service representative. See Contact Us for our hours and telephone number. If you have an issue with how your rights are being protected, you may lodge a complaint with our Privacy Concern Officer. 

To send an email to our Privacy Concern Officer, please use the Contact Us page or direct your letter to: 

Conrad M. Siegel, Inc. 
PO Box 5900 
Harrisburg, PA 17110-0900 
Attn: Privacy Concern Officer