Privacy Policy

Canal Row Advisors Privacy and Cookie Policy

Effective Date: September 15, 2025 

Canal Row Advisors, LLC navigates the FDA’s complexity in order to produce strategies that deliver solutions for our clients. In delivering these services, we value the privacy of not only our current but also our potential clients and visitors to our website.  

This Privacy Policy (“Policy”) applies to the information Canal Row Advisors and any affiliates under common ownership and/or control (together, “Canal Row,” “we,” “us,” “our”) collects from and about you when you visit our website, located at www.canalrow.com (the “Site”), interact with us through social media pages we have now or may in the future, or engage in any related interactions with us. Please read the Policy to understand how we will collect and use your information and the rights you have in relation to your information.

We encourage you revisit this Policy often to check for updates we have made, either to reflect changes in our personal information practices with respect to our Site or changes in applicable law. We will post a notice on our Site to notify you of material changes to this Policy and indicate at the top of this Policy when it was most recently updated. The most current version of the Policy will always be available here: https://www.canalrow.com/privacy-policy/

By providing information to us, you acknowledge you have read this Policy, and, to the extent your consent is necessary and valid under applicable law, you consent to the collection, use, and disclosure of such information by Canal Row and any third-party recipients in accordance with this Policy.

This Policy contains the following sections:

Information Collected

As you use our Site and have related interactions with us, the information that we may collect from you, should you choose to provide it to us, includes:

  • Basic information, such as your name, the company you work for, and your title or position;
  • Contact information, such as your postal address, email address and phone number(s);
  • Any other information relating to you that you choose to provide to us.

As you navigate through and interact with our Site, we may also automatically collect certain information about the device you use to access the Site, and browsing actions and patterns, including device identifiers, traffic data, referrer headings, error logs, IP address, browser and operating system type, general location data associated with your IP address, and information about the resources that you access and use on our Site.  This device and usage information may be collected through the use of cookies and similar technologies, which are further discussed below.

Our Site is not intended to collect sensitive information from and about you, such as financial account numbers or health information.  Please do not provide such information as you use the Site.

How We Use the Information We Collect

We may use the information we collect from and about you to:

  • Provide the Site and related services;
  • Process and respond to requests, inquiries, or complaints received from you;
  • Identify services you may be interested in and provide you with related marketing materials and event invitations;
  • Send communications to you about our Site and the services we provide;
  • Monitor and analyze use of the Site to improve our Site and our business offerings; and
  • To operate, evaluate, and improve our Site and our services, including developing and improving new and existing services, managing and improving our communications, and analyzing our services and customer base (including conducting market research).

We may aggregate and/or de-identify any information we collect so that such information is no longer personally identifiable to you and can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use such information for any purpose, including, without limitation, for research, and we may also disclose Aggregate/De-Identified information to third parties. 

Cookies and Site Analytics

Cookies. We use cookies, web beacons, and similar tracking technologies (collectively, “Cookies”) on our Site. Cookies are small amounts of data that are stored on your browser, device, or the page you are viewing. Some Cookies are deleted once you close your browser, while other Cookies are retained even after you close your browser so that you can be recognized when you return to our Site. Cookies may be placed by us (first-party Cookies) or by third-party partners and service providers (third-party Cookies).

These technologies are useful because they help us and our Site:

  • Remember your information so you will not have to re-enter it;
  • Personalize the Services to your preferences;
  • Track and understand how you use and interact with the Services;
  • Generally improve your user experience; 
  • Manage and measure the usability of the Services;
  • Understand the effectiveness of our communications; and 
  • Improve our Services.

We use the following types of Cookies on our site:

  • Necessary Cookies: these Cookies are required to enable the basic features of this site, such as providing secure log-in or adjusting your consent preferences.  These cooked do not store any personally identifiable information;
  • Analytics: these Cookies are used to understand how visitors interact with the website.  These Cookies help provided information on metrics such as the number of visitors, bounce rate, traffic source, etc.;
  • Performance Cookies: these Cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors;
  • Functional Cookies: these Cookies improve help perform certain functions like sharing the content of the website on social media platforms, collecting feedback and other third-party features; and
  • Advertisement Cookies: these Cookies are used to provide visitors with customized advertisements based on the pages you visited previously and to analyze the effectiveness of the ad campaigns. 

Your Choices Regarding Cookies

Depending on your jurisdictions of residence, you may be asked to consent to our use of certain cookies before they are placed on your browser. You can modify your browser settings to decline or accept certain Cookies. However, if you decline Cookies, some of our Site’s features may not function as they should and may affect your use of and experience on the Site. You may also use the preference options that appear in the Cookie banner on our Site to modify the use of certain Cookies.

Analytics Information 

We may use Google Analytics or other service providers for analytics services. These analytics services may use Cookies to help us analyze how users use our Site. Information generated by these services (e.g., your IP address and other usage information) may be transmitted to and stored by Google Analytics and other service providers on servers in the United States (“U.S.”) or elsewhere, and these service providers may use this information for purposes such as evaluating your use of our Site, compiling statistical reports on our Site’s activity, and providing other services relating to our Site activity and other Internet usage. You may exercise choices regarding the use of Cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.  

Third-Party Targeted Advertising 

You may opt out of the use of third-party targeting or advertising cookies on your browser. These third parties (e.g., social media platforms, ad networks, etc.) may use this information to serve relevant content and advertising to you as you browse the Internet, and access their own Cookies or other tracking technologies on your browser to assist in this activity. If you are interested in more information about these online advertising activities, and how you can generally Control cookies from being put on your computer to deliver tailored advertising, you may visit the Digital Advertising Alliance of Canada, Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt out of receiving tailored advertising from companies that participate in those programs.  

Please note that these opt-out tools are provided by third parties and not Canal Row. We do not control or operate these tools or the choices that advertisers and others provide through these tools.

Please see the “Your Rights and Choices” section below for additional information on how to effectuate your rights regarding online advertising.

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our Services for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals.  Please note that DNT is a different mechanism than the “global privacy control,” which signals that individuals want to exercise certain rights with respect to their data.  We do honor global privacy control signals as required by applicable law.

Sale of Personal Data and Targeted Advertising

Third-party trackers collect information to use for analytics and to personalize your experience with targeted ads. Under certain state data privacy laws, including the Colorado CPA, the Virginia CDPA, the Texas DPSA, the Oregon CPA, the Montana CDPA, and the Florida DBR, you have the right to opt out of the sale of your personal data to third parties, of targeted advertising related processing, and of some types of profiling.  You can exercise your rights and manage your cookie preferences through the Consent Management Platform (CMP) that we provide on our website.  This tool allows you to choose which categories of cookies you accept or reject.  These choice must be made directly by you through the CMP; we cannot make or change cookie preference selections on your behalf.

If you opt out, the ads and content that you see may not be as relevant to you. Under the Colorado CPA, you have the right to opt back into these categories at any time after you initially choose to opt out.

For detailed information regarding the rights residents of certain U.S. states have with respect to personal data collection and processing, including a required California Privacy Notice, please see Appendix A. 

As set forth in greater detail in Appendix A, depending on the state in which you live, state law may require us to set out in this Policy the legal grounds on which we rely in order to collect or process your information. In such cases, we rely on one or more of the following conditions:

  • To satisfy any legal and regulatory obligations to which we are subject;
  • Where you have consented to us processing your information for the relevant purpose; or
  • Our legitimate interests in the effective delivery of information and services to you and in the effective and lawful operation of our businesses (provided these interests do not interfere with your rights).

Your Rights and Choices

You have certain rights with respect to your information as further described in this section.

General information rights.  Your local laws (e.g., if you are a citizen or resident of the European Economic Area (“EEA”) or certain U.S. states, such as California) may permit you to request that we:

  • Provide access to and/or a copy of certain information we hold about you;
  • Update information which is out of date or incorrect;
  • Delete certain information that we are holding about you;
  • Restrict the way that we process and disclose certain of your information; and/or
  • Revoke your consent for the processing of your information.

We will consider all requests and provide our response within the time-period set forth in the applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request. To submit a request, please contact us at info@canalrow.com.

Marketing Communications

If, in accordance with applicable legal requirements, we send you marketing communications regarding our services or the services of third parties that we believe will be interesting to you, you can ask us to stop sending such communications at any time by contacting us at info@canalrow.com.  In our marketing email messages, you can also opt out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and disclose certain information as permitted by this Policy or as required by applicable law. For example, you may not opt out of certain transactional emails from us, such as those confirming your requests or providing you with updates regarding our legal terms.

Sale/Targeted Advertising Opt-Out Rights

Under certain state data privacy laws, you have the right to opt out of our processing or sharing of your information for online targeted advertising purposes. Note that certain jurisdictions also allow you to opt out of the “sale” of your information to third parties in exchange for valuable consideration. We may use analytics and online advertising tools that result in the disclosure of your information to our third-party partners and that are subject to this opt-out right. You can opt out of both of these activities by clicking “Opt out of Sale of Personal Data and Targeted Advertising” here or in the footer of our website.

How We Disclose Your Information

We may transfer or disclose information we collect to other Canal Row affiliates and to their third-party contractors, subcontractors, and/or their subsidiaries and affiliates for our legitimate business purposes.  Specifically, in accordance with applicable legal requirements, we may disclose your information to the following entities:

  • Our professional advisers, auditors, and insurers;
  • Service providers to whom we outsource certain support services, such as word processing, marketing, data storage, translation, photocopying, and document review;
  • IT service providers to Canal Row (including identity management, Site hosting and management, data analysis, data backup, security, and storage services);
  • Online advertising and related analytics partners that help us serve you with more relevant ads about our services as you use the Internet and analyze the effectiveness of such ads;
  • Legal or regulatory bodies where we believe in good faith that disclosure of your information is required by law or necessary to protect Canal Row, our clients, and the public;
  • Other businesses or organizations in the event that we undergo a business transaction that involves the sale or transfer of some or all of our assets to that other entity; and
  • Any other entity where we have your consent to do so.

The Site may contain links to third-party websites and features. If you choose to visit these sites and use their services, please note that we are not responsible for their content or privacy practices. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites, and not this Policy. We urge you to read the privacy policies of these third parties.

Information for International Users

Our Site and our related services are provided in the U.S., among other jurisdictions.  Please note that the level of information privacy protection in the U.S. may differ from the privacy protections in your jurisdiction of residence.  By accessing or using the Services or otherwise providing information to us, you consent to the processing, transfer, and storage of information in and to the U.S. and other countries, where you may not have the same rights as you do under local law.

When we transfer the personal data of users in the EEA, UK and/or Switzerland, we rely on the Standard Contractual Clauses approved by the European Commission for such transfers or other transfer mechanisms deemed ‘adequate’ under applicable laws.

Users in the EEA and UK have the right to request access to, rectification of, or erasure of their personal data; to data portability in certain circumstances; to request restriction of processing; to object to processing; and to withdraw consent for processing where they have previously provided consent. These rights can be exercised by contacting us at info@canalrow.com.  EEA users also have the right to lodge a complaint with their local supervisory authority.

As required by applicable law, we collect and process information about individuals in the EEA and UK only where we have a legal basis for doing so. Our legal bases depend on the Services you use and how you use them. We process your information where:

  • It is necessary to fulfill our contract with you, including to provide, operate, and improve the Site and related services, provide customer support, personalize features and to protect the safety and security of the Site;
  • It satisfies a legitimate interest (which is not overridden by your data protection interests), such as preventing fraud, ensuring network and information security, enforcing our rules and policies, protecting our legal rights and interests, research and development, personalizing the Site and related services, and marketing and promoting the Site and related services;
  • You have consented for us to do so for a specific purpose; or
  • We need to process your information to comply with our legal obligations.

Data Security

We use a variety of security, technical, and organizational measures to help protect your information from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction, accidental loss, and to comply with applicable data protection laws. Despite our best efforts, however, security cannot be absolutely guaranteed against all threats, and the transmission of information via the internet can never be completely secure. Although we will do our best to try and protect your information, we cannot guarantee the security of your information transmitted to our Site; any transmission is at your own risk.

Data Retention

We will retain your information for as long as is necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

Our retention periods are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used, taking into account legal and regulatory requirements, best practices, and Canal Row’s business purposes.

We keep contact information (such as mailing list information) until a user unsubscribes or requests that we delete that information. If you choose to unsubscribe from a mailing list or newsletter, we may keep certain limited information about you so that we may honor your request.

Children’s Personal Information

Unless otherwise specified, our Site and related services are designed for a general audience aged 18 and older and are not directed to children. In connection with our services, we do not knowingly solicit or collect personal information online from children under the age of 13 without parental consent. If we learn that we have collected personal information online from a child under age 13 without parental consent, we will either seek parental consent or promptly delete that information. If you believe that a child under age 13 may have provided us with personal information without parental consent, please contact us as specified in the Contact Us section.

Contact Us

If you would like to make a privacy request, update your preferences, or have a privacy concern, you may contact info@canalrow.com.  

Appendix A – Additional Rights Available in Certain States and Jurisdictions

Certain U.S. jurisdictions provide residents with certain rights with respect to their Personal Information or “personal data” as defined under applicable law. These rights are subject to the specific laws of that jurisdiction and that certain other rights might apply. 

Below you can find our California Privacy Notice; Nevada Privacy Notice; and Colorado, Connecticut, Utah, and Virginia Privacy Notices. These provide more information on rights and terms specific to your location or place of residence.

Exercising your state privacy rights.  Please note that any request you submit to us is subject to an identification and residency verification process as permitted under applicable law, as well as certain other procedural requirements that may be noted in the sections below. Additionally, all requests are subject to certain exceptions under applicable law, which may vary. If you are a visually-impaired customer, a customer who has another disability or a customer who seeks support in other language, you may access your privacy rights by emailing us at info@canalrow.com.

We do not charge a fee to process or respond to your verifiable consumer request unless it’s excessive, repetitive, manifestly unfounded, or in accordance with applicable law.  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. 

Depending on applicable law, you may be limited in how many verifiable or authenticated consumer request you make within a twelve (12) month period. If we have inadvertently collected information on your minor child, you may exercise the above rights on behalf of your minor child. Additionally, in some jurisdictions, you may designate an authorized agent to submit a request on your behalf, and if so, we may require proof of the agent’s authorization by you and/or verification of the agent’s own identity. Generally, a rights request must include:

  • Sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which must include, at a minimum, your first and last name and email address.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to the request.

We cannot respond to your request or provide you with Personal Information if we cannot verify or authenticate your identity or authority to make the request and confirm that the Personal Information relates to you. We will only use Personal Information provided in a verifiable or authenticated consumer request to verify your (or your authorized agent’s as applicable) identity or authority to make the request.     

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 info@canalrow.com.  Except where otherwise noted, we will respond to your request within forty-five (45) days after receipt and we reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days. As described below, in some jurisdictions, an authorized agent may submit a request to exercise your rights on your behalf.

How to submit a request. To exercise any of the rights described in this Privacy Policy, please send your request(s) using one of the following methods:

11. California Privacy Notice

This California Privacy Notice applies to any California residents about whom we collect Personal Information (for the purposes of this Article 11, “consumers”). The provisions contained within this section are intended to provide notices in compliance with the California Consumer Privacy Act of 2018 (“CCPA”) and other relevant California laws and regulations. 

For the purposes of this California Privacy Notice, except where a different definition is noted, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal Information does not include Publicly Available Information, information that has been de-identified or aggregated, or other information subject to certain federal and state regulation, such as protected health information.

If you are a visually-impaired customer, a customer who has another disability or a customer who seeks support in other language, you may access your privacy rights by emailing us at info@canalrow.com. 

a. Personal Information We Collect

We may collect, or have collected, the following categories of Personal Information about you:

  • Identifiers
  • Commercial information
  • Financial information
  • Internet or other electronic activity information
  • Geolocation data
  • Professional or employment-related information
  • Audio, electronic, visual, or similar information
  • Characteristics of protected classifications under California or federal law
  • Inferences drawn from any of the above

Certain of the Personal Information that we collect may constitute “Sensitive Personal Information” as defined by California law. This may include: 

  • Your account login information
  • Content of messages sent through the Site or Services

b. How We Use Your Personal Information

We use the Personal Information we collect about you for the following purposes:  

  • Contact you and provide information
  • Provide customer service
  • Perform identity and age verification as required under applicable law
  • Provide and maintain the Site 
  • Facilitate interactive features 
  • Internal analytics
  • Market our products and Services directly to you
  • Market the products and services of others directly to you
  • Promotions and sweepstakes
  • Internal business purposes, including general business administration
  • Audit, compliance, legal, policy, procedure, and regulatory obligations
  • Customer claims and fraud investigation and prevention
  • Systems and data security 
  • Protecting the safety of our employees and others
  • Targeted Advertising
  • Profiling

c. Sources of Personal Information

We may collect Personal Information about you from the following categories of sources.  

  • Directly from you through your interactions with us, such as when we collect Self-Reported Information. 
  • Through Cookies and other tracking technologies, as discussed in more detail in Cookies and Other Tracking Technologies (Section 5 of this Policy). 
  • From our Partners, with your permission and in accordance with applicable law.  
  • From other third parties, including our third-party service providers, business and marketing partners, affiliates, analytics providers, ad network providers, ad agencies, and advertisers. 
  • From government agencies or public records.
  • From social media and other content platforms, such as Google and Meta, if you access the Site through a third-party connection or interact with us on those platforms. 

We may supplement such information with information we obtain from other sources, including from both online and offline information providers.

d. To Whom We Disclose Personal Information

We limit our disclosure of the categories of Personal Information above to our service providers for one or more business purposes. “Business purposes,” for the purposes of this California Privacy Notice, means the reasonably necessary and proportionate use of Personal Information for our operational purposes, other purposes described in this Privacy Policy, for the operational purposes of our service providers and contractors, as well as other purposes compatible with the context in which the Personal Information was collected.

We do not and have not sold Personal Information to third parties for any monetary value.  We do gather Personal Information from consumers via Cookies as part of our targeted advertising initiatives, which is technically considered a “sale” and/or “share” of Personal Information under California law, even though we do not receive monetary payment for sharing or disclosing Personal Information to these third parties. In this connection, during last 12 months (from the last updated date listed at the top of this Privacy Policy), we have “sold” or “shared” the following categories of Personal Information as those terms are defined under the CCPA:

  • Identifiers
  • Commercial information
  • Internet or other electronic network activity information 

If you wish to opt-out of the “sale”/“sharing” of Personal Information that is gathered via Cookies when you visit our websites and/or use our Services, please exercise your preferences to do so using “Your Privacy Choices” link that is available at the bottom of our websites or by following the further instructions at Section 11(f) below.

As those terms are defined by California law, we do not “sell” or “share” your Self-Reported Information without your express, affirmative consent.

e. Your California Privacy Rights

If you are a California resident, you the following rights under applicable California law:

  • Right to know and access. You have the right to know what Personal Information we collect, use, disclose, and sell and/or share, as those terms are defined under applicable law. You may ask us to provide you a portable copy of this information up to two times in a rolling 12-month period.
  • Right to delete and erase. You have the right to request under certain circumstances that we, as well as our service providers and contractors, delete the Personal Information that we collect about you.
  • Right to correct inaccurate Personal Information. You have the right to request the correction of inaccurate Personal Information.
  • Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
  • Right to opt out of sale and/or sharing. You have the right to opt-out of the sale and/or sharing of your Personal Information by a business. 
  • Right to limit use and disclosure. You have the right to limit the use or disclosure of your sensitive Personal Information to only the uses necessary for us to provide goods or services to you. We will not use or disclose your sensitive Personal Information after you have exercised your right unless you subsequently provide consent for the use of your sensitive Personal Information for additional purposes. 
  • Sharing with third parties for their own direct marketing purposes. We do not disclose Personal Information to third parties for their own purposes without your consent.  If you wish to request information regarding such practices under California’s “Shine the Light” Law, please contact us at info@canalrow.com.  You must include your full name, email address, and postal address in your email or mail request so that we can verify your California residence and respond.

You may exercise any of the rights described in this section by following the instructions in Section 10, supra (“Your Privacy Rights”).

f. Notice of Right to Opt-Out of Sale/Sharing

You have the right to opt-out of the sale and/or sharing of your Personal Information by a business. As noted above, we may “sell” and/or “share” your Personal Information for purposes of cross-context behavioral advertising. You may opt-out by following the instructions in Section 10, supra (“Your Privacy Rights”)

You can opt out of such sale or sharing by clicking the Your Privacy Choices link at the bottom of our website and selecting your preferences. You may also opt out by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC). To download and use a browser supporting the GPC browser signal, click here or visit: https://globalprivacycontrol.org/orgs. Please note that your opt-out request will be linked to your browser identifier only. 

We also encourage you to utilize the Cookie preferences options that appear in the Cookie banner on the Services.  Finally, you may also visit the websites of the Network Advertising Initiative and the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising for more information about opting out of seeing targeted digital advertisements and how to opt bank in if desired. You may also learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings.

We do not knowingly sell or share the Personal Information of minors under 16 years of age without legally-required affirmative authorization. If you are a parent or guardian and you believe that your child has provided us with information without your consent, please review the Children’s Privacy section and contact us by email at info@canalrow.com. 

g. Retention of Personal Information

We will retain your Personal Information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. 

We will also retain certain Personal Information for internal analysis purposes. This information is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods. 

Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position, including regard to applicable statutes of limitations, litigation or regulatory investigations.

13. Privacy Notice for Residents of Other U.S. States

This Privacy Notice contains additional information for residents of Colorado, Connecticut, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia about personal data that we collect, how we use it, what sources it is derived from, and who we disclose it to, and provides information regarding your rights, and our responsibilities, under applicable laws and regulations. For the purposes of this section, “personal data” means information that is linked or reasonably linkable to an identified or identifiable individual. Personal data does not include de-identified data or publicly available information. This section does not apply to certain personal data that is already subject to certain federal and state regulations, such as protected health information.  

The provisions contained within this section are intended to provide notices in compliance with the Colorado Privacy Act, the Connecticut Data Privacy Act, the Delaware Personal Data Privacy Act, the Iowa Consumer Data Protection Act, the Montana Consumer Data Privacy Act, the Nebraska Data Privacy Act, the New Hampshire Privacy Act, the New Jersey Privacy Act, the Oregon Consumer Data Privacy Act, the Texas Data Privacy and Security Act, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act (collectively, the “State Privacy Laws”). 

The State Privacy Laws provide or will provide rights to residents of Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia, respectively, to receive certain disclosures and access regarding collection, use, sale, and sharing of personal data.

a. Our Personal Data Practices

The State Privacy Laws provide rights to residents of those states, to receive certain disclosures and access regarding collection, use, sale, and sharing of personal data.  Detail about what kinds of personal data we may collect or have collected, how we collect it, why we collect it, and who we may disclose it to is found in the “Personal Information We May Collect, Use, and Disclose”; “Sources of Personal Information”; and “Disclosure of Personal Information” sections of this policy.  

We do not and have not sold Personal Information to third parties for any monetary value.  We do gather Personal Information via Cookies for the purposes targeted advertising; however, we do not sell or share your Self-Reported Information without your express, affirmative consent.

b. Your Privacy Rights 

If you are a resident Colorado, Connecticut, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia, you have the following rights under applicable law in relation to your personal data, subject to certain exceptions: 

  • Right to know and access. You have the right to know what personal data we collect, use, disclose, and/or sell or share as those terms are defined under applicable law. You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period.
  • Right to delete and erase. You have the right to request under certain circumstances that we, as well as our service providers and contractors, delete the personal data that we collect about you.
  • Right to correct inaccurate personal data. You have the right to request the correction of inaccurate personal data.
  • Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
  • Right to opt out. You have the right to opt-out of targeted advertising, the sale of your personal data, and profiling decisions that could produce legal or similarly significant effects concerning the consumer.
  • Rights concerning sensitive personal data. If you are a Connecticut, Colorado, Delaware, Montana, Nebraska, New Jersey, Oregon, Texas, or Virginia resident, we cannot and will not process your sensitive data (as defined by applicable law) or your sensitive data inferences, or use your personal data for certain purposes, without your affirmative consent. If you are an Iowa or Utah resident, you have the right to opt out of having your sensitive personal data processed and/or used. 

How to exercise your rights. You may exercise any of the rights described in this section by following the instructions in Section 10, supra (“Your Privacy Rights”)

How to appeal decisions about your rights. Colorado, Connecticut and Virginia residents can appeal our decisions concerning privacy rights requests, as follows:

  • Colorado residents. If you are a Colorado resident and want to appeal our decision with regard to a request that you have made, please contact us at info@canalrow.com.  Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Colorado’s Office of the Attorney General by phone at (720) 508-6000 or by submitting a form here.  
  • Connecticut residents. If you are a Connecticut resident and want to appeal our decision with regard to a request that you have made, please contact us at info@canalrow.com.  Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Connecticut’s Office of the Attorney General by phone at (860) 808-5420 or by submitting a form here.  
  • Delaware residents. If you are a Delaware resident and want to appeal our decision with regard to a request that you have made, please contact us at info@canalrow.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Delaware’s Department of Justice by phone at (302) 683-8800 or by submitting a form here.  
  • Iowa residents. If you are an Iowa resident and want to appeal our decision with regard to a request that you have made, please contact us at info@canalrow.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Iowa’s Office of the Attorney General by phone at (888) 777-4590 or by submitting a form here.  
  • Montana residents. If you are a Montana resident and want to appeal our decision with regard to a request that you have made, please contact us at info@canalrow.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Montana’s Office of the Attorney General by phone at (406) 444-4500 or by submitting a form here.  
  • Nebraska residents. If you are a Nebraska resident and want to appeal our decision with regard to a request that you have made, please contact us at info@canalrow.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Nebraska’s Office of the Attorney General by phone at (402) 471-2683 or by submitting a form here.  
  • New Hampshire residents. If you are a New Hampshire resident and want to appeal our decision with regard to a request that you have made, please contact us at info@canalrow.com.  Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact New Hampshire’s Office of the Attorney General by phone at (603) 271-3658 or by submitting a form here.  
  • New Jersey residents. If you are a New Jersey resident and want to appeal our decision with regard to a request that you have made, please contact us at info@canalrow.com.  Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact New Jersey’s Office of the Attorney General by phone at (800) 242-5846 or by submitting a form here.  
  • Oregon residents. If you are an Oregon resident and want to appeal our decision with regard to a request that you have made, please contact us at info@canalrow.com. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision.  If the appeal is denied, you may contact Oregon’s Office of the Attorney General by phone at (877) 877-9392 or by submitting a form here.  
  • Texas residents. If you are a Texas resident and want to appeal our decision with regard to a request that you have made, please contact us at info@canalrow.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision.  If the appeal is denied, you may contact Texas’s Office of the Attorney General by phone at (800) 621-0508 or by submitting a form here.  
  • Virginia residents. If you are a Virginia resident and want to appeal our decision with regard to a request that you have previously made, please contact us at info@canalrow.com or notify the Office of the Attorney General of Virginia online here. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Virginia’s Office of the Attorney General by phone at (804) 786-2071, written correspondence to 202 North 9th Street, Richmond, Virginia 23219, or online here.

14. Changes to This Privacy Policy 

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Site, prior to the change becoming effective and update the “Effective Date” at the top of this Privacy Policy. We recommend reviewing this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

15. Contact Us 

Please contact us at info@canalrow.com if you have any questions about this Privacy Policy, or if anything in here does not make sense or seem right to you. We are always open to feedback around our privacy policies and practices. Because email communications are not always secure, please do not include any sensitive information in your email to us. You can also write to us at: Canal Row Advisors, LLC, 4800 Hampden Lane, Suite 430, Bethesda, MD 20814.

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