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Fuller & Thaler Asset Management, Inc.

Privacy Policy

        Effective date: 9/30/2024

        This Privacy Policy tells you how Fuller & Thaler Asset Management, Inc. (“we,” “our,” “us”) collects, uses and shares information we collect about you when you interact with us in-person, by phone, by email, through our website www.fullerthaler.com  (“Site”), or by another method.  This includes information that:

  • you provide to us directly,

  • we collect from you automatically,

  • we may collect from third parties such as service providers, affiliated companies, marketing or data partners, or other third parties with whom you interact,

  • we collect about employees and business partners and vendors from references, referrals or consumer reporting agencies. 

        Information collected

        We automatically collect information when you visit the Site including your device’s IP address and statistics about how you use the Site. We also collect information that you submit when you interact with us online or offline. Not all information is collected from everyone who interacts with us. For example, we may collect different information from our customers, our vendors or service providers and our employees. During the past 12 months we may have collected the following categories of personal information:

  • Identifiers such as contact information (your name, phone number, email address), general location (postal address), user names with an encrypted version of your password, date of birth, communications with us, and device identification information.

  • Professional, educational or employment-related information collected from suppliers, vendors, or employees including business contact information, phone number, email and postal addresses and titles, resume information and professional credentials.

  • Protected information such as financial account information, immigration status and health information.

  • Commercial information such as your transaction histories.

  • Electronic network activity information such as your computer’s or device’s internet protocol (IP) address, your interactions with our Site or our computer network, through the use of cookies and similar technologies, system logs, and analytics monitoring.

  • Audio or video information such as call and meeting recordings and security video recordings at our facilities.

  • Protected anti-discrimination classification information collected for legal compliance such as race, ethnicity, citizenship, gender, and medical or disability information or other categories of information that are protected for anti-discrimination purposes.

  • Sensitive Personal Information such as social security, driver’s license, state ID card or passport number, account log-in, racial or ethnic origin, religious or philosophical beliefs, or union membership, genetic data, biometric information, health, or sexual orientation.  Please note that we collect, process and disclose sensitive personal information only for purposes permitted by law which includes complying with our legal obligations under anti-discrimination laws and disability accommodation laws.

  • Other types of personal information that we may disclose to you prior to the point of first collection.

        How your information is used

        We use your information for our general commercial purposes in order to operate and grow our business, improve our Site and our services, and to offer our or third-party products or services that we think you may find of interest. More specifically, we collect personal information for the following business purposes:

  • Provide the services and information you have requested from us and notices about the services including providing customer support, and billing and collection.

  • Verify your identity.

  • Provide information to you about our products or services and third-party products and services that we think may be of interest to you.

  • Provide you with marketing communication and information.

  • Analyze, improve, and customize our services including measuring the effectiveness of advertising and internal research on users’ interests and behaviors to better serve our customers.

  • Administer the website, web platform and services and for internal operations, including troubleshooting, data analysis, testing, research, security, statistical and survey purposes.

  • For the prevention, detection, or investigation of a crime; loss prevention; or fraud.

  • Internal and external audit requirements, information-security purposes, and as we otherwise believe to be necessary or appropriate: (a) under applicable law; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities; (c) to enforce our terms and conditions or other agreements; and (d) to protect our rights, privacy, safety, or property, or those of other persons.

  • Employee administration, vendor oversight and legal compliance.

        Cookies and similar technologies

        We use cookies and similar technologies to collect aggregate (non-personal) information about Site usage by all of our Site visitors and to help us remember you and your preferences when you revisit the Site. These cookies may stay on your browser into the future until they expire or you delete them. We also use technology that is necessary for the functionality of our Site.  These cookies usually are erased when you close your browser window.  Further general information about cookies and how they work is available at www.allaboutcookies.org.

        We may allow selected third parties to place cookies through the Site to provide us with better insights into the use of the Site or user demographics or to provide relevant advertising to you.  These third parties may collect information about a consumer’s online activities over time and across different websites when he or she uses our website. We may also permit third party service providers to place cookies through our Site to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third party cookies or the resulting information and we are not responsible for any actions or policies of such third parties.

        Except as otherwise provided in this policy we do not use technology that recognizes a “do-not-track” signal from your web browser.

        Children’s Privacy

        Our Site and our services are not designed nor intended to be attractive to use by children under the age of 13.  We do not knowingly collect information from children under the age of 13.  If you are under 13, please do not submit any information to us.

        Accessing your information and your choices

        You can update, amend or delete your information at any time by logging into your account.

        

        You can choose to delete or block cookies by setting your browser to either reject all cookies or to allow cookies only from selected sites.  If you block cookies, performance of the Site may be impaired and certain features may not function at all.  

        Disclosing your information

        We may reveal information about you in the course of operating our business and providing our services, including:

  • if you request or authorize it;

  • if the information is provided to help complete a transaction for you;

  • if the information is provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, to enforce our agreements, or to protect our rights, property or safety or the rights, property or safety of our users or others (e.g., to a consumer reporting agency for fraud protection etc.);

  • if the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, customer information may be one of the transferred assets); and

  • if the information is provided to our agents, outside vendors or service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.

We do not share your information with third parties for their marketing purposes.

During the past 12 months we have disclosed the following categories of personal information to the following types of third parties for our business purposes.

  • Within our company: We may have shared your information such as identifiers and commercial information within our company for the purposes of decision making, reporting, management, analysis, administering programs, promoting service offerings and other business purposes.

  • Service providers: We may have shared your information such as identifiers, commercial information and financial information with our service providers who provide us support services such as hosting our Site, processing payments, legal and accounting professional services, providing employee benefits, postal delivery and electronic mail, mobile messages, conducting analysis to improve our services and Site, fulfilling requests you make, managing payments and answering your questions. Service providers only use the information they receive from us for the purposes we hired them for; we don’t allow them to retain, use or otherwise handle the data for their own purposes.

  • With Third Parties, including governmental authorities and law enforcement, for legal or compliance purposes: We may share any or all categories of your information where we believe the disclosure is required by law or otherwise necessary to comply with the law, regulatory requirements, requests from public authorities, or to enforce our agreements or policies or protect or defend the rights and property of our customers, the company, our partners or the public (including for fraud prevention purposes).

        We do not disclose your information for monetary or other valuable consideration or for cross-context behavioral marketing purposes (advertising based on your online activities on other websites).

        Security

        We use reasonable technical, administrative and physical measures to protect information contained in our system against unauthorized access, destruction, misuse, loss or alteration.  We may use standard encryption technology to protect information being transferred to our site, but no method of electronic transmission or storage is 100% secure.  If we receive instructions using your log-in information we will consider that you have authorized the instructions.

        Data Processing and Cross-Border Data Transfers

        Our Site is maintained on servers maintained by a U.S. based third party who may have servers  within and outside the United States, and personal information submitted is stored on these servers.  If you are visiting our Site from outside the United States, please be advised that your information is transferred to these servers.  Disclosing your personal information to us pursuant to this Privacy Policy is at your own risk.  We strive to comply with laws of jurisdictions in which we maintain operations but we make no representations that the practices described in this Privacy Policy are compliant with laws outside those jurisdictions that apply to the collection, security, use and disclosure of personal information.

        Notices to California Residents

        Your California Privacy Rights.  California residents with an established business relationship with us are permitted by California law once a year to request information about the manner in which we shared certain categories of information with others for their marketing purposes during the prior calendar year. We do not share your personal information with third parties for their direct marketing use.

        California Consumer Privacy Act Notice

        California residents are provided certain rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA). Please read our CCPA Notice here.

        Notice to Colorado, Connecticut, Florida, Montana, Oregon, Texas, Virginia and Utah Residents

        We are currently not subject to the Colorado Privacy Act, the Connecticut Personal Data Privacy Act, Florida Digital Bill of Rights, the Montana Consumer Data Privacy Act, the Oregon Consumer Privacy Act,  the Texas Data Privacy and Security Act, the Utah Consumer Privacy Act, or the Virginia Consumer Data Protection Act.

 

        Notice to Nevada Residents

        We do not transfer personal information for monetary consideration. 

        Links to other sites

        We may permit others to link to this Site or to post a link to their site on ours.  We do not endorse these sites and are not responsible for other sites or their privacy practices.   Please read their privacy policies before submitting information.

        Changes to the Privacy Policy

        We may amend this Privacy Policy.  The Policy in effect at the time you use the Site or provide information to us governs how we may use your information.  If we make material changes we will post the revised Policy and the revised effective date on this Site. Please check back here from time to time to review any changes.

        Contacting us

        This Site is owned and operated by Fuller & Thaler Asset Management, Inc.  You can contact us using our Site’s Contact Us page or at Fuller & Thaler Asset Management, Inc., 411 Borel Avenue, Suite 300 San Mateo, CA 94402; Toll Free Tel: (866) 204-0769.

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The Behavioral Edge

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FullerThaler is a brand name of Fuller & Thaler Asset Management, Inc.

This website is directed only to US institutional investors. FullerThaler may only transact its investment advisory business in states where it is notice-filed as an investment adviser or otherwise exempt from state requirements. The information on this website is neither an offer to sell nor a solicitation of an offer to buy any product or service in any jurisdiction where such offer, solicitation, purchase or sale would be unlawful. Nobel Prize is a trademark of the Nobel Foundation.

Copyright 2024 FullerThaler. All rights reserved.

Fuller & Thaler Asset Management, Inc.

411 Borel Avenue, Suite 300

San Mateo, CA 94402

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