Privacy Policy
Last modified: January 1, 2024
Introduction
Thank you for visiting the website of Hughes & Company and its affiliates (hereinafter, “Hughes”, “Company”, “we”, “us” or “our”). This Privacy Notice describes the types of information we may collect from you or that you may provide when you visit our website at https://hughes-co.com (the “Site”), as well as information we may collect via other means.
This Privacy Notice does not cover or include any Hughes & Company Investment Partners’ advisory or investment services or the investor portal accessible via the Site. If you are an investor in a fund or the holder of an account managed directly or indirectly by us (or, in either case, their representative), please refer to the Hughes & Company Investment Partners Privacy Notice last updated November 2023 (available in our investor portal or otherwise provided to you) for further information about how Hughes & Company Investment Partners collects and processes personal information about its current, prospective and former investors.
Information we Collect
When you interact with the Site, we collect information that directly identifies you (i.e., information that would allow someone to identify you or contact you, such as your full name, postal address, e-mail address, or telephone number), as well as information about your use of the Site. Below we describe the different types of information we collect from you and the devices you use when you interact with the Site.
Information You Provide to Us
We collect information you provide directly to us. For example, you share information directly with us when you fill out a form or communicate with us via our Site. The types of personal information we may collect include your name and email address, street address, phone number and any other information you choose to provide.
Information we Collect Automatically when You Interact with Us
When you access our Site, we automatically collect certain information, including:
- Device and Usage Information: We collect information about how you access our Site, including data about the device and network you use, such as your IP address, operating systems and browser type, hardware model, unique device identifiers. We also collect information about your activity on our Site, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Site.
- Information Collected by Cookies and Similar Tracking Technologies: Cookies are small text files that are stored on computer hard drives by websites that you visit. The serve various purposes, including helping users navigate websites more efficiently and providing information website operator about how the website is being used. When you visit our Site, we may place a cookie or other online tracking device (e.g., web beacons) in order to understand your use of the Site and improve your experience. These cookies or similar tracking technologies may collect information about your device and how you use the Site, including your IP address, web browser, mobile network information, pages viewed, time spent on pages, and links clicked. For more information about cookies and how to disable them, see the Your Choices section below.
How We Use Your Information
We use information that we collect about you or that you provide to us to:
- Provide the Site to you, maintain and improve it and personalize your experience using it;
- Respond to your inquiries and other communications and provide customer service;
- Communicate with you about services and events offered by Hughes and others and provide news and information that we think will interest you (see the Your Privacy Rights and Choices section below for information about how to opt out of these communications at any time);
- Monitor and analyze trends, usage, and activities in connection with our Site;
- Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Hughes and others;
- Comply with our legal and financial obligations; and
- Carry out any other purpose described to you at the time the information was collected.
Disclosure of Your Information
We may disclose personal information that we collect or you provide as described in this Privacy Notice:
- To our affiliates;
- To vendors, service providers, professional advisors, including accountants and lawyers, and consultants we use to operate this Site and support and manage our business, 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 fulfill the purpose for which you provide it such as to respond to your inquiries, or for any other purpose disclosed by us when you provide the information;
- With your consent and at your direction;
- 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 Hughes’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Hughes about our Site users is among the assets transferred;
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- If we believe that your actions are inconsistent with our terms of use, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Hughes, our visitors, the public, or others.
We do not sell personal information obtained about you to any third parties and have not done so in the twelve (12) months preceding the effective date of this Privacy Notice. We may share aggregated or de-identified information that cannot reasonably be used to identify you.
Your Choices
Communication Preferences
You may opt out of receiving promotional emails from Hughes by following the instructions in those communications or by emailing us at [email protected] or contact us by mail at 150 N. Wacker Drive, Suite 2925, Chicago, IL 60606. If you opt out, we may still send you non-promotional emails, such as those about our ongoing business relations.
Cookie Management
Most web browsers automatically accept cookies. We use Google Analytics to collect information about how often users visit the Site, what pages they visit when they do, and what other websites they used prior to coming to this Site. For more information about Google’s ability to use and share information collected by Google Analytics about your visits to the Site, please see the Google Analytics Terms of Service and the Google Privacy Policy. You can, however, change your browser to prevent this or to notify you each time a cookie is set. To learn more about how to manage cookies on different types of browsers, you can visit the website www.allaboutcookies.org.
Do-Not-Track Browser Signals
Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. We do not currently respond to such signals.
Your Privacy Rights
Some consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected] or contact us by mail at 150 N. Wacker Drive, Suite 2925, Chicago, IL 60606.
You may be afforded, in accordance with applicable law, the right to: (i) obtain information about the personal information we have collected about you and to request a copy of it; (ii) delete certain personal information we have about you; (iii) request correction of inaccurate personal information we have about you; (iv) object to or request the restriction of processing of your personal information; and (v) withdraw your consent.
To exercise any of these rights please send an email to [email protected]. California residents may also exercise their rights by calling 1.833.438.9600.
Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. We reserve the right to deny requests as allowed by applicable law, such as where we have a reasonable belief that the request is fraudulent, where your identity cannot be confirmed, or where we must retain your information consistent with applicable law. To appeal a decision regarding a consumer rights request please email us at to [email protected].
We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available to you may change or no longer be available to you.
Data Security
The security and confidentiality of your personal information is very important to us. We have implemented measures designed to appropriately protect your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
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 our Site and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information.
Additional Information for Visitors Outside the United States
The data controllers for your personal information are Hughes & Company Investment Partners, L.P., located at 150 N. Wacker Drive, Suite 2925, Chicago, IL 60606.
Transfer of Information to the United States and other Countries
Hughes is headquartered in the United States, and we have service providers in the United States and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.
Legal Basis for Processing
When we process your personal information, we will do so in reliance on the following lawful bases:
- To perform our responsibilities under our contract with you (e.g., providing the Site to you).
- When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our Site and Services, and communicate with you).
- To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
- When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.
Data Retention
We may retain your personal information for up to 26 months.
When deciding how long to keep your personal information, we take into account how long we need to retain the information to fulfill the purposes described in this Privacy Notice and to comply with our legal obligations, including obligations to financial services regulators. We may also retain personal information to investigate or defend against potential legal claims in accordance with the limitation periods of jurisdictions where legal action may be brought.
Privacy Notice Changes
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our Site or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.
Contact Information
To ask questions or make any complaints about this Privacy Notice or our privacy practices, please contact us at:
Hughes & Company
150 N. Wacker Drive
Suite 2925
Chicago, IL 60606
312.238.9600
833.438.9600