Effective Date: 8-2-17

Hughes & Company (hereinafter, “our company” or “we” or “us”) operates this website (hereinafter, the “Site”) to provide information about our company, our investment strategy and portfolio, industry news, etc.  This Privacy Policy (hereinafter, this “Policy”) describes how Hughes & Company collects, uses, and manages the information we collect about you when you the Site.  This Privacy Policy applies also to any other website or online service that we may operate in the future.

By using the Site, you accept and agree to be bound by this Policy and our Terms of Use.  If you do not agree with any provision of this Policy or our Terms of Use, please do not use the Site.

Information We Collect

When you contact us through the Site, we will collect your Personal Information. “Personal Information” means any information that can reasonably be used to identify you, such as your name, email address, address, and telephone number.

When you use the Site, we may also collect information about your use of the Site and your computer or other device you use to access the Site, such as your IP address, internet service provider, browser type, and pages viewed (hereinafter, collectively, “Usage Information”).  Such Usage Information cannot be used to identify you and therefore, we do not treat it as Personal Information under this Policy. Tracking technologies, like cookies and web beacons, help us collect this Usage Information. To learn more about cookies and how to control them, please review the “Data Collection Technologies” section below.

How We Use Your Information                                                                                        

When we collect your Personal Information, we use it only for the purposes for which it was collected. For example, if you submit your Personal Information through our Contact Us form, we will use your Personal Information only to respond to your message.

We use the Usage Information we collect to improve the Site and our content and for other internal business purposes. For example, Usage Information helps us better understand how our visitors use the Site, analyze their demographics, interests, and behaviors, and further develop our business and service offerings.

When We Share Your Information

We may share your Personal Information as disclosed to you at the time we collect it and for the following purposes:

• At your Direction: We will share your Personal Information with any third party with whom you direct us to share it.
• Service Providers: We may provide your Personal Information to our services providers that help us run and manage our business, such as technology service providers, analytics providers or the provider of our investor portal. We encourage you to review the privacy policy of any service provider you interact with.
• As Required By Law: We may disclose your Personal Information as required by law, such as to comply with a subpoena or similar legal process. Additionally, we may disclose Personal Information when we believe that disclosure is necessary to protect the safety and security of our property or the property or others. We may also disclose Personal Information in order to protect our rights, such as to investigate fraud or respond to a government request.
• Corporate Transaction: In the event Hughes & Company is involved in a merger, reorganization, acquisition or sale of all or a portion of its assets, or other corporate transaction, we may disclose your Personal Information as part of that transaction.

We do not share your Personal Information with third parties for their own marketing purposes.

We reserve the right to share any aggregated or other non-personally identifiable information with third parties for all lawful purposes.

Data Collection Technologies

We may use cookies, web beacons, and other data collection technologies to help us understand our visitors and improve our Site and the services we offer. “Cookies” are small, often encrypted text files that contain small amounts of information that are stored on your computer or your mobile device’s browser directory. Cookies help us track usage behavior so that we can tailor information to make your visits more enjoyable and meaningful. For example, 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 instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions or all functionality of the Site. To find more information about cookies, visit www.allaboutcookies.org.

Do Not Track Signals: Some web browsers have “Do Not Track” or similar features that allow you to tell each website you visit that you do not want your activities on that website tracked. At present, the Site does not respond to “Do Not Track” signals and consequently, the Site will continue to collect information about you even if your browser’s “Do Not Track” feature is activated.

Security

Protecting your information is important to us. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your information, we cannot ensure or warrant the security of the information you transmit to us through the Site.

Note to International Visitors

The information we collect about you on the Site is stored on servers located in the United States. The laws of the United States may differ from the laws in your home country. By using this Site, you consent to the processing of your Personal Information consistent with this Policy and the transfer of your Personal Information to the United States.

Children’s Privacy

This Site is not intended for or directed to children under 13, and we do not knowingly collect information directly from children. If we become aware that we have collected information from a child under 13, we will immediately delete such information.

Third Party Links

The Site may contain links to other websites not owned or operated by Hughes & Company, including, those of advertisers, news media, other third parties. Hughes & Company is not responsible for the information collection practices or the content of these third party websites.

Access and Choice

You may access and amend any Personal Information we have on you by contacting us using the contact information below. We will respond to your inquiry within a reasonable timeframe.

Changes to this Policy

Hughes & Company reserves the right to change the terms of this Policy. Since any changes will be posted on this page, we encourage you to check this page regularly. Your continued use of the Site following any changes to this Policy will constitute your acceptance of such changes.

Contact Us

If you have any questions about this Policy or our information practices, please contact us:

Hughes & Company
150 N. Wacker Drive, Suite 2925
Chicago, IL 60606
Phone: 312.238.9600
Email: info@hughes-co.com