Privacy Policy (last revised June 30, 2020)

This is the Privacy Policy for the website currently located at http:/ (the “website”). Your privacy is important to Andrew Berger, the author of the website. He wants you to understand what Personal Information and Non-Personal Information (defined below) is collected, used, and protected when you visit the website and to explain your choices for managing your information preferences. By using the website, you signify your agreement and consent to this Privacy Policy posted on the website.

1. Information You Choose To Submit

You can visit the website without entering any Personal Information. Only if you choose to share such information when you opt to subscribe to the website or send the author an email in response to a post or for some other reason, will the website collect information that personally identifies you, such as your email address, firm name or phone number (“Personal Information”). The decision to provide this information is yours.

2. Managing Information Preferences

You may review, correct, update, or change your Personal Information or remove your Personal Information at any time by contacting the website at: We may take steps to verify your identity before providing you access to your personal information. If you subscribe to the website, the website will save your email address and other information you provide, which will be used to provide periodic email alerts and announcements.

3. Information Automatically Collected

The website automatically collects information that does not reflect or reference an individually identifiable user (“Non-Personal Information”) to help the website understand how its visitors use the website.

a. Log Files. The website, like most others, automatically collects and uses the data contained in log files. Your browser automatically reports log file information each time you access a web page. The information in the log files may include your IP (internet protocol) address, your ISP (internet service provider), the web browser you used to visit the website, the date and time you visited the website, which web pages you visited on the website, and other anonymous website usage data. name of the domain and host from which you access the Internet. The website does not match data collected automatically with the data you voluntarily give the website, referred to above; and the website does not track specific users or profile their browsing activities.

b. Cookies. The website may send cookies to your computer. Cookies are a small text file containing a string of characters that uniquely identifies your web browser which are downloaded to your hard disc or your browser’s memory. Cookies uniquely identify your browser and enhance your navigation on the website. A cookie may also convey information to the website about how you use it (e.g., pages you view, links you click and other actions you take). But cookies do not reveal or disclose your personal information.

Cookies allow the website or the third-party analytics tools the website uses (such as Google Analytics, which also uses cookies) to track your usage of the website so may improve its quality. You may opt out of web analytics by installing an opt-out browser add-on on your computer. For more information please go to:

There are persistent and session cookies. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser when you later access the website. A session cookie is temporary and disappears after you close your browser.

Most web browsers are initially set up to accept cookies; but you can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, certain features of the website may not function properly if you delete or disable cookies.

The website does not use cookies to collect and distribute information to third parties for marketing or sales purposes.

4. How Personal Information and Non-Personal Information Is Used

The website uses Personal Information and Non-Personal Information for internal purposes, including to keep you informed of topics of interest to you if you subscribe to the website or otherwise express interest in the content it contains. The website will not sell, license or rent Personal Information to third parties and the website will not otherwise disclose Personal Information to third parties without your express permission or as expressly disclosed in this Privacy Policy.

From time to time, the website will establish business relationships with others with whom the website believes are trustworthy (“Service Providers”) and with whom the website has asked to confirm that their privacy practices are consistent with the website’s. For example, the website has and will contract with Service Providers to provide web hosting, web development and design services. Further, the website may contract with other Service Providers to provide web analytics and data management, among other services. The website provides its Service Providers only with the information reasonably necessary for them to effectively perform these services. Each Service Provider must agree to implement and maintain reasonable security procedures and practices appropriate to the nature of the information provided to protect your information from unauthorized access, destruction, use, modification, or disclosure.

In certain instances the website may disclose Personal Information and Non-Personal Information when the website believes it is necessary to identify, contact, or bring legal action against persons or entities to protect the website or its users or when the website believes that the law or legal process requires that disclosure, such as when the website receives a subpoena.

5. Security

The information the website collects is stored on servers the website manages, using security procedures and practices appropriate to the nature of the information in an effort to protect it from unauthorized access, destruction, use, modification, or disclosure. However, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, although the website strives to protect information transmitted on or through the website, it cannot and does not guarantee or warrant the security of any information you transmit on or through the website. You do so at your own risk. THE WEBSITE DISCLAIMS ANY LIABILITY FOR ANY SECURITY BREACHES OR FOR DISCLOSURE OF YOUR INFORMATION DUE TO TRANSMISSION ERRORS, THIRD-PARTY ACCESS OR CAUSES BEYOND OUR CONTROL.

6. Children’s Privacy Statement.

The website does not knowingly collect Personal Information from children under the age of 13. If it becomes aware that of its inadvertent receipt of Personal Information from a child under the age of 13, that information we be deleted.

7. Links to Other Sites

The website links to other websites. Although the website tries to link only to websites that have a respect for privacy, the website is not responsible for the content, security, or privacy practices of the other websites. Those linked sites have their own privacy policies, which may differ significantly from the website’s policies. Information you submit to linked sites is subject to the privacy policies of those sites. We recommend that you review the privacy policy of any site that you access through the website.

8. EU Data Protection Laws and Regulations

To the extent that the European Union’s (“EU”) General Data Protection Regulation or other data protection laws or regulations apply, the provisions in this section of the Privacy Policy apply, in addition to or instead of the general provisions above.

If your Personal Information is subject to the EU Data Protection Laws you may have the following rights, which, in most cases, may be exercised free of charge:

a. The right to obtain information regarding the processing of your Personal Information and access to the Personal Information that the website holds concerning you;

b. The right to withdraw your consent to the processing of your Personal Information at any time. Please note, however, that the website may still be entitled to process your Personal Information if it has another legitimate reason for doing so, such as, for example, compliance with a legal obligation;

c. In some cases, you may have the right to receive some Personal Information in a structured, commonly used and machine-readable format and/or request that the website transmit that data to a third party when technically feasible. Please note that this right only applies to Personal Information that you have provided directly to the website;

d. The right to request that we rectify your Personal Information if it is inaccurate or incomplete;

e. The right to request that we erase your Personal Information in certain circumstances. Please note that there may be circumstances in which the website will not be able to honor such a request because it is legally entitled to retain the information;

f. The right to object to, or request the website to restrict its processing of your Personal Information in certain circumstances. Please note that there may be circumstances inwhich the website may not honor your request because it is legally entitled to refuse the request;

g. The right to lodge a complaint with the relevant data protection regulator if you think that the website has infringed any of your rights.

9. Privacy Policy Changes

The website may in its sole discretion change this Privacy Policy from time to time. The website will post a copy of the Privacy Policy as changed on the website. You can tell if the Policy has changed by checking the revision date that appears at the beginning of the policy. Your continued use of the website constitutes your agreement to abide by the Privacy Policy as changed. If you object to any such changes, you may opt not to use the website.