Privacy Policy

The words “we,” “us,” and “our” refer to ProManage, LLC (“ProManage”), a registered investment adviser, and its affiliates, agents and third parties.  The words “you” and “your” mean you, the individual visiting or using our Website.

ProManage is committed to your privacy protection.  This Privacy Policy describes our privacy practices with respect to your use of this Website.   By using or accessing this Website, you signify your acknowledgment and assent to this Privacy Policy, and consent to the collection, processing and use of your information as described. If you do not agree to this Privacy Policy or such terms, please do not use this Website or otherwise provide information to us.

As used in this Privacy Policy, “personal information” means data that identifies, relates to, describes, or that could be linked to a particular identified or identifiable natural person or is otherwise considered personal information under applicable privacy and/or data protection laws or regulations.

Nondisclosure of Personal Information
We will not sell, reveal or share your personal information with third parties except in the following limited circumstances:
  • We have your permission to share the information;
  • We need to share your information with companies who work on our behalf to provide a product or service you have requested or to maintain or service your account. For example:
  • We may work with a financial institution, such as your plan administrator, plan sponsor or its recordkeeper/custodian, to make services available to you or effect a transaction you have requested.
  • If you have consented or otherwise requested to receive e-mail or other electronic communications from us, we may provide your e-mail address to companies that perform mailing services for us. (Unless we tell you differently, these companies do not have any right to use the personally identifiable information we provide to them beyond what is necessary to assist us.);
  • We are required or authorized by law to disclose your information (for example, to comply with a subpoena or regulatory requirement, or to protect against fraud or illegal activity or for institutional risk control or the safety of plan participants and their property);
  • We need to provide information to our attorneys, accountants and auditors or others determining compliance with industry standards;
  • We reserve the right to disclose personal information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury or interference with (either intentionally or unintentionally) our rights or property or anyone else that could be harmed by such activities; or
  • In the event ProManage or its affiliates or their assets are sold, merged or otherwise involved in a corporate transaction, your personal information will likely be transferred as part of that transaction – we reserve the right to transfer your personal information in such situation provided that we will make reasonable efforts to see that your privacy preferences are honored by the transferee.
We may anonymize, pseudonymize, aggregate or de-personalize personal information and/or Usage Information to create non-personally identifiable information (“Anonymized Data”). We may disclose and use Anonymized Data and other non-personally-identifying information for industry analysis, statistical purposes, demographic profiling, marketing and advertising, and other business purposes (which may include reporting on trends in the usage of our Website).

Data Encryption and Security
We maintain appropriate physical, electronic and procedural safeguards and controls to help protect against the loss, misuse, alteration and unauthorized disclosure of personal information in our possession or under our control. We use industry-standard encryption technologies when transferring and receiving confidential information.  Our physical facilities where confidential data is stored have security measures in place to protect against the loss, misuse or alteration of information that we have collected. We will comply with all privacy laws and make any legally required disclosures regarding breaches of the security, confidentiality, or integrity of personal information consistent with our ability to determine the scope of a breach and our obligations to law enforcement.

NOTE: You are cautioned to not use e-mail to share any confidential information with us.

Use of Cookies and Usage Information
We and third-party analytics providers may collect information about your usage and interaction with our Website, including domain name, referring web page, and the length of time spent and the pages accessed while visiting our Website (collectively, “Usage Information”). Usage Information may be collected via tags, cookies, device identifiers, IP addresses, and other tracking mechanisms. We use cookies for site administration purposes.  Temporary cookies are used to provide users with information relevant to them as they use the Website.  Temporary cookies are removed when you close your browser. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, this may prevent you from taking full advantage of our Website. Usage Information is collected to help us manage and administer our Website, systems, improve the content of our Website, and customize and improve user experience.

Specific Data Collection
For those who voluntarily choose to contact us using the “Contact Us” feature on this Website, we collect your e-mail address.

Your mobile device may use biometric identifiers to provide you with access to your device.  We do not obtain access to these biometric identifiers.

How is my information used?
We may track your online activities over time by collecting Usage Information through automated means. We do not currently employ a process for responding to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms.  We do not have arrangements with any third parties (such as third party advertising networks and social media platforms) authorizing them to collect personal information about your online activities over time when you use our Website.

Controlled Use of Information
Aggregate information about your use of this Website may be used to improve the quality and usability of the Website.

Policy Change Notification
From time to time, we may alter our Privacy Policy to reflect changes to our information practices related to this Website. If we make any material changes, we will post an updated version of this Privacy Policy on the Website. We encourage you to periodically review our posted Privacy Policy for the latest information on our privacy practices. Any modifications to this Privacy Policy will be effective upon our posting, and your continued use of this Website indicates acceptance of the modified Privacy Policy and reaffirmation of your consent. If you do not agree to any part of a modified Privacy Policy, then you must stop accessing this Website.

Contact Us
If you have questions about the above Privacy Policy, please feel free to contact us but do not share confidential information in your e-mail:

Postal Address:
Privacy Officer
ProManage, LLC
130 E. Randolph Street, Suite 2825
Chicago, IL 60601
Via E-mail: [email protected]

Version 08/25/2021