This Privacy Statement sets forth the information gathering, use and dissemination practices of Greene, Tweed & Co. (“Greene, Tweed”) in connection with the World Wide Web site located at www.gtweed.com (the “Site”). This Privacy Statement addresses Greene, Tweed’s practices regarding information collected only directly through or from the Site–it does not address or govern any information gathering, use or dissemination practices related to information collected other than directly through or from the Site, including, without limitation, from or via telephone, facsimile, postal mail, personal delivery or other or additional offline means or media. Greene, Tweed can be contacted by mail at Greene, Tweed, 2075 Detwiler Road, P.O. Box 305, Kulpsville, Pa., 19443-0305, USA; by phone at 215-256-9521; by facsimile at 215-256-0189; or by e-mail at webmaster@gtweed.com.

Greene, Tweed complies with the U.S. EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Greene, Tweed has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. To learn more about the Safe Harbor program, and to view the company’s certification, please visit http://www.export.gov/safeharbor/.

1. Collection of Personal Information from Site Visitors

Greene, Tweed may collect or track (1) the e-mail addresses of visitors that communicate with Greene, Tweed via e-mail, and (2) information knowingly provided by the visitor in online forms, registration forms, surveys, e-mail and other online avenues (including, without limitation, demographic and personal profile data). Greene, Tweed also may collect or track (3) the home server domain names, e-mail addresses, type of client computer, files downloaded, search engine used, operating system and type of web browser of visitors to the Site, and (4) aggregate and user-specific information regarding which pages Site visitors access.

Greene, Tweed may place Internet “cookies” on visitors’ hard drives. Internet cookies save data about individual visitors, such as the visitor’s name, password, user-name, shopping cart, screen preferences and the pages of a site viewed by the visitor. When the visitor revisits the Site, Greene, Tweed may recognize the visitor by the Internet cookie and customize the visitor’s experience accordingly. Visitors may decline Internet cookies, if any, by using the appropriate feature of their web client software, if available.

When a visitor performs a search within the Site, Greene, Tweed may record information identifying the visitor or linking the visitor to the search performed. Greene, Tweed may also record limited information for every search request and use that information to solve technical problems with the services available directly or indirectly in connection with the Site and to calculate overall usage statistics.

2. Use of Personal Data Collected

Personal data collected by Greene, Tweed may be used by Greene, Tweed for many reasons, for example, for editorial and feedback purposes, for marketing and promotional purposes, for a statistical analysis of users’ behavior, for product development, for content improvement, for fulfillment of a requested transaction or recordkeeping, or to customize the content and layout of the Site. Aggregate visitor data may be used for internal purposes, and individually identifying information, such as names, postal and e-mail addresses, phone numbers, and other personal information that visitors voluntarily provide to Greene, Tweed may be added to Greene, Tweed’s databases and used for future calls and mailings regarding Site updates, new products and services, and upcoming events.

Greene, Tweed also may use Site visitor data to contact the Site visitors regarding account status and changes to the subscriber agreement, privacy statement, and any other policies or agreements relevant to Site visitors.

3. Disclosure of Personal Data to Third Parties

Aggregate visitor data may be provided to third parties, such as marketing firms and other organizations.

Identifiable or nonidentifiable data may be disclosed or distributed (1) to another party with which Greene, Tweed enters or reasonably may enter into a corporate transaction, such as, for example, a merger, consolidation, acquisition or asset purchase, or (2) to a third party (a) pursuant to a subpoena, court order or other form of legal process, (b) in response to a request by or on behalf of any local, state, federal or other government agency, department or body, whether or not pursuant to a subpoena, court order or other form of legal process, or (c) if determined by Greene, Tweed in its sole judgment that such disclosure or distribution is appropriate to protect the life, health or property of Greene, Tweed or any other person or entity.

While Greene, Tweed may undertake efforts to see that any third party to or with which Greene, Tweed shares, rents, sells or otherwise discloses personal data is under a contractual obligation to use the personal data solely for the purposes for which the data was disclosed, such third parties are independent third parties over which Greene, Tweed exercises no control, and Greene, Tweed is not responsible for their conduct, actions, omissions, or information handling or dissemination practices and Greene, Tweed will not be liable therefor.

This Site may contain links to other World Wide Web sites or advertisements for or placed by third parties. Greene, Tweed is not responsible for the privacy practices of such websites, advertisers or third parties, or for the content of such sites or advertisements. It is possible that these links or advertisements themselves may be used by third parties or others to collect personal or other information about Site visitors. It is solely the visitors’ obligation to review and understand the privacy practices and policies of these other websites and of these advertisers and third parties.

4. Security Measures

Greene, Tweed has implemented numerous security features to prevent the unauthorized release of or access to personal information. For example, (1) hardware- and software-level firewall, (2) file-level password protection, and (3) database-level password protection. Please be advised, however, that the confidentiality of any communication or material transmitted to or from Greene, Tweed via this Site or e-mail cannot be guaranteed. Accordingly, Greene, Tweed is not responsible for the security of information transmitted via the Internet. Instead of communicating with Greene, Tweed via e-mail or the Internet, visitors can contact Greene, Tweed by mail, phone or facsimile at the address or numbers set forth at the beginning of this Statement.

5. Opt-Out Right

Except as necessary for Greene, Tweed to provide the services, information or products requested by a visitor, the visitor may opt out of having his or her personally identifiable information, which has been voluntarily provided to Greene, Tweed through an online form, registration form, survey or other similar mechanism prospectively retained by Greene, Tweed, used by Greene, Tweed for secondary purposes, or disclosed by Greene, Tweed to third parties by contacting Greene, Tweed via postal mail, e-mail, facsimile, or telephone at the addresses or numbers set out above. (This does not apply to collection of the type of web browser of the visitor to the Site or to information provided or collected that does not meet the above description.)

6. Access to and Ability to Correct Personal Data

Upon a visitor’s request via postal mail, e-mail, facsimile or phone, Greene, Tweed will provide to the visitor a summary of any personally identifiable information retained by Greene, Tweed regarding the visitor, which information has been voluntarily provided to Greene, Tweed through an online form, registration form, survey or other similar mechanism. A visitor may modify, correct, change or update their personally identifiable information by contacting Greene, Tweed via postal mail, e-mail, facsimile or telephone at the addresses or numbers above.

7. Right to Change Privacy Statement

Greene, Tweed may change this Privacy Statement at any time. Notice of any new or revised Privacy Statement, as well as the location of the new or revised statement, will be posted on the Site for at least 60 days after the change. It is the obligation of users visiting the Site before the change to learn of changes to the Privacy Statement since their last visit. Any change to this Privacy Statement shall be effective as to any visitor who has visited the Site before the change was made.



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