This website is for informational purposes only and does not constitute a complete description of our investment services or performance. This website is in no way a solicitation or offer to sell securities or investment advisory services except, where applicable, in states where we are registered or where an exemption or exclusion from such registration exists. The products described by this website are intended to be made available only to persons residing in the United States. This website should not be considered a solicitation or an offering of any products to investors residing outside of the U.S. Information throughout this site, whether stock quotes, charts, articles, or any other statement or statements regarding market or other financial information, is obtained from sources which we, and our suppliers, believe reliable, but we do not warrant or guarantee the timeliness or accuracy of this information. Investment Advisory Services offered through Clifford Swan Investment Counselors, a Registered Investment Advisor with the U.S. Securities & Exchange Commission. Registration does not imply a certain level of skill or training. Nothing on this website should be interpreted to state or imply that past results are an indication of future performance. Neither we or our information providers shall be liable for any errors or inaccuracies, regardless of cause, or the lack of timeliness of, or for any delay or interruption in the transmission thereof to the user. THERE ARE NO WARRANTIES, EXPRESSED OR IMPLIED, AS TO ACCURACY, COMPLETENESS, OR RESULTS OBTAINED FROM ANY INFORMATION POSTED ON THIS OR ANY ‘LINKED’ WEBSITE.

Restrictions on use. You may not:

• Copy, display, reproduce, republish, upload, post, transmit, or otherwise distribute any of the pages, text, images, material or other content of this website without express written consent.
• Copy, modify, or display any of the products or Clifford Swan name, logo, text, or images in any way without express written consent.
• Modify or use the pages, text, images, material or other content of this website for any other purpose.

Doing any of the foregoing will be a violation of copyrights and other proprietary rights.

Website Privacy Policy

Welcome to Clifford Swan’s website at cliffordswan.com (the “Site”). Clifford Swan is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, it will only be used in accordance with this privacy statement.

This policy may change through updating this page. You should check this page periodically to stay appraised of the changes.

This policy applies only to the website located at cliffordswan.com. If you do not agree with this policy, then you should not use the Site.

What data we collect

Personally Identifiable Information

Clifford Swan may collect and store personally identifiable information about you if you voluntarily submit such information to Clifford Swan through the forms on this Site. Personally identifiable information may include your name, email address, physical address and other information that specifically identifies you.

Non-Personally Identifiable Information

Clifford Swan may also automatically collect (through cookies, described below, and other methods) and store aggregate or anonymous information about user contact with and use of the Site. Examples of this type of information include demographic information, the type of internet browser you are using, the type of computer operating system application software and peripherals you are using, the domain name of the website from which you linked to our Site and your browsing habits on and usage of the Site. Non-Personally identifiable information may also include personally identifiable information that has been aggregated so that no one individual is specifically identifiable (e.g., how many users in a particular metropolitan area have accessed the Site).

Cookies

We may use cookies and similar technologies to collect non-personally identifiable information from you and to customize your use of the Site. A cookie is a small data file that certain websites write to your hard drive when you visit them. We may also use web bugs, clear gifs and similar technologies that collect data similar to that collected by a cookie. A cookie file can contain various types of information, including a user ID that the site uses to track the pages you have visited.

Most browsers are initially set up to accept cookies; however, you can reset your browser to refuse all cookies or indicate when a cookie is being sent or you can flush your browser of cookies from time to time.

Links

The Site may contain links to websites maintained by third parties. Clifford Swan is not responsible for the privacy practices of such third-party sites. You should carefully read their own privacy policies before providing any information to such third parties.

How We Use This Data

Personally Identifiable Information

Clifford Swan will only use your personally identifiable information as described in this policy.

When you submit an inquiry to us through the forms on our website, Clifford Swan may use the personally identifiable information we collect to contact you about our products and services.

We do not sell or share your personally identifiable information with third parties without your consent. However, we may share your personally identifiable information with technical consultants and other third parties who make our Site available, enhance its functionality, or provide associated services (but only for the purpose of them providing such services to Clifford Swan and to enhance your experience with the Site).

We reserve the right to transfer any information to our assignees and successors.

We also reserve the right to access and/or disclose any information as required by courts or administrative agencies and to the extent necessary to permit us to investigate suspected fraud, harassment or other violations of any law, rule or regulation, the Site rules or policies, or the rights of third parties or to investigate any suspected conduct which Clifford Swan deems improper.

Non-Personally Identifiable Information

We may use and share non-personally identifiable information with third parties for any number of reasons, including advertising, analytics, promotional and/or other purposes.

Your California Privacy Rights

We will not share any Personally Identifiable Data with third-parties for their direct marketing purposes to the extent prohibited by California law. If our practices change, we will do so in accordance with applicable laws and will notify you in advance.

Opt-Out & Deletion Procedures

You have the option to opt-out of receiving information from Clifford Swan. This opt-out messaging will appear at the bottom of every promotional email that is sent out to you by Clifford Swan in relation to this Site.

Clifford Swan also gives you the option to remove your information from its database of active users. If you no longer wish to take advantage of this Site or to receive any form of direct contact from Clifford Swan, whether it is email, newsletters, or other promotional offers or materials, or wish us to delete your personally identifiable information from our database of active users, send us a request marked “Privacy-Urgent”, address as follows: info@cliffordswan.com

Please note that, notwithstanding the fact that we may have removed your information from our list of active users, we reserve the right to keep any information submitted or collected for business reasons, such as archiving data.

Clifford Swan is not responsible for removing information from third-party lists or databases of any kind if we have shared your information with such third parties as permitted by this policy. However, you can opt-out of receiving interest-based ads from third parties who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website and DAA website. (http://www.networkadvertising.org/choices/) and (http://www.aboutads.info/choices/). You can also opt out of Google’s use of cookies by visiting Google’s Ads Settings.

Reviewing or changing your information

If you would like to change your information currently in our database, please contact us at info@cliffordswan.com

Clifford Swan is not responsible for updating information contained in third-party lists or databases.

Security

We are committed to taking reasonable steps to ensure the security of your information. To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of information, we have put into place physical, electronic, and managerial procedures to help safeguard and secure the information we collect online. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and us or information stored on the Site or our servers, will be completely free from unauthorized access by third parties such as hackers and your use of the Site demonstrates your assumption of this risk.

Protection for Children

This Site is not intended for users under the age of 13, and we have no intention of collecting personally identifiable information from children (i.e., individuals under the age of 13). If a parent or guardian learns that a child has provided us with personally identifiable information, that child’s parent or guardian should send us a request marked “Privacy — Urgent” to info@cliffordswan.com if they would like the information submitted by the child deleted from our database. We will use all reasonable efforts to delete such information from our database.

United States of America

Our Site is maintained in the United States of America. By using the Site, you freely and specifically give us your consent to export your personally identifiable information to the USA and to store and use it in the USA as specified in this policy.

Your Consent

We may amend our privacy policy at any time and will post those changes on this page, so you are always aware of what information we collect, how we use it and under what circumstances we may disclose it. However, if we plan to materially change the way in which we use or disclose your personally identifiable information, we will provide you with prior notice and a chance to opt-out of such differing uses.

Contacting Us

If you have any questions about this privacy policy, the practices of this Site, or your dealings with this Site, you can contact us at info@cliffordswan.com

In addition, our mailing address is:

Clifford Swan Investment Counselors
177 East Colorado Blvd., Suite #550
Pasadena, CA 91105

Last Updated: January 29, 2025