This Privacy Policy applies to the websites (together, the “Sites”) that are owned or operated by McPherson (referred to herein as “we,” “us,” and “our”), including www.mcpherson2006.com and any other websites that display or link to this Privacy Policy. We collect certain personal information based upon and as a result of the use of our Sites by visitors and subscribers (referred to herein as “you” or “your”). Our collection and use of your information will be conducted in accordance with this Privacy Policy.

1. Information That We Collect.

Cookie Policy

Introduction

The purpose of this Cookie Policy is to describe how McPherson LLC, and its affiliates, subsidiaries, divisions and brands (collectively, “McPherson,” “we,” “us,” or “our,” as the context may require) collect, use and share cookies at and through websites owned and controlled by McPherson, including but not limited to www.mcpherson2006.com (the “Site“), including all content, functionality, applications and services offered on or through the Site (together with the Site, the “Services“). Please read this notice carefully to understand what we do. If you do not understand any aspect of this Cookie Policy, please feel free to contact us as described at the end of this policy.

What Are Cookies?

To allow the Services to work properly and to provide you with a personalized experience, we sometimes place cookies on your device. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store unique identifiers, user preferences, and other information, such as what pages you visit, your IP address, or how you arrived on the Site.

What Types of Cookies Do We Use?

McPherson uses both persistent and session cookies.  Session cookies are only stored in the cookie file while you are actually using the Site. Persistent cookies are stored for a specific time, but each cookie may have a different lifespan.

The Site uses both first party cookies (set by McPherson) [and third party cookies (set by third parties). Third party cookies are cookies provided by our service providers for analytics and advertising. The information that they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. We do not control these third parties’ use of cookies or how they may be used.

How Do We Use Cookies?

We and our service providers use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with the Services through your computer or mobile device. Cookie information allows us to analyze use of the Services and our online advertisements, improves your experience on the Services, and allows you to use certain features on the Services.  We also use cookies to help ensure the marketing you see on the Services is relevant to you and your interests.

How Can You Control Cookies

You can control and/or delete cookies as you wish. You can delete all cookies that are already on your computer, and you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. You may refuse the use of cookies or modify or withdraw your consent to the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full functionality of the Site.

2. Consent.

By providing your Personal Information through the Sites, you consent to our collection and use of your Personal Information and other information in accordance with the terms of this Privacy Policy.

3. Our Use of Your Personal Information.

a.

We will use your Personal Information to process your subscription or requests for information. We may also use such Personal Information to offer additional information to you about us, our products and/or services, personalize the types of information you receive from us, evaluate how our Sites are being used and the audience our Sites are reaching, identify market trends and market interests that help us improve the products and services that we offer, and develop and improve the content and operation of our Sites to better serve the needs of our customers.

(1) Online Orders.

When you purchase a subscription from us, we will request certain Personal Information, including credit card information. Individuals who do not have a Visa, MasterCard or American Express credit card are not permitted to make purchases with us online.

(2) Sharing Information with Other Companies.

We may share your Personal Information (but never your credit card or password information) with our affiliates, Anthony Kirk and his affiliated companies  or with third parties who provide services to us and agree to keep your Personal Information confidential.

(3) Mailing and Email Addresses.

We will use your mailing and email addresses to send you the publications you have subscribed to. We may also contact you with questions about your subscription or service, or to remind you of your password, if necessary. If you submit an inquiry via email about one of your subscriptions, for security reasons we may ask you to provide additional information so we can verify your identity.

b.

We may send you information and special offers on our other products. We may also, on occasion, use your mailing or email address to send you information or special offers from select companies that offer products, services or information we believe may be of interest to you or from companies that are affiliates of Anthony Kirk. Though we hope you gain value from the email messages you receive, you can choose to opt out of receiving further messages by following the instructions provided at the bottom of each email.

c.

We will only disclose your Personal Information to our employees, affiliates, agents, contractors, or other third parties including Anthony Kirk affiliated companies who have a need to know such information for the uses listed above. Except as provided above, we will not disclose Personal Information to any other third parties.

d.

Personal Information may also be aggregated with such information from other visitors to the Sites such that the information no longer personally identifies you. We may use the aggregated information for the general purpose of evaluating our market and/or business trends, our customer demographics, interests and behavior, our past and future product or service offerings and/or pricing, or other aspects of our business. We may share such aggregated information with our business partners, vendors, distributors or other collaborators, for these same purposes. We may also sell or license such aggregate information to one or more third parties for use in a similar manner.

e.

We also retain the right to release your Personal Information when required by law or when we, in good faith, believe that we must release the information in order to: (1) satisfy a legal order or comply with legal process; (2) defend our rights or those of our affiliates or business partners; or (3) protect the personal safety of our employees, agents, affiliates, business partners, customers, or site users. We also retain the right to transfer your Personal Information in the context of the sale of all or part of our business.

4. Security.

Although we take the security of your Personal Information very seriously and are constantly improving our efforts to protect it, no electronic communication over the Internet can be guaranteed to be completely secured. Though we take great care to protect your personal information, we cannot guarantee the security of any information that you submit to us, and you do so at your own risk.

5. Advertising and Linked Websites.

Our Sites may feature products and services that are co-sponsored by other websites. One example of such a feature is our stock quote data, which is provided to us by a third party. Additionally, our Sites contain links to other websites, including those of advertisers. We are not responsible for the claims or representations made by advertisers or sponsors. While these co-sponsored activities, banner ads, and links originate on our Sites, we do not necessarily operate them.

For example, if you click on a link or banner advertisement, you’ll be directed to the advertiser’s site. These other sites may use cookies, collect data, or solicit personal information from you. Since we do not have control over the privacy practices or the content of these sites, we recommend that you check their privacy policies before giving out any personal information. We do not own, control, have access to, or maintain any information collected by our co-sponsors or advertisers. Some e-letter issues also include advertising. By opting to receive e-letters from McPherson, you also agree to receive such advertisements.

6. Changes to Privacy Policy.

From time to time, we may revise this Privacy Policy. If we make revisions that change the way we collect or use your Personal Information, those changes will be posted in this Privacy Policy and the effective date will be noted at the bottom of the Privacy Policy. You should review it periodically so that you are up to date on our most current policies and practices. If we make material changes to this Privacy Policy, we will notify you by placing a notice on the Sites and by sending a notice to you via email to your last email address in our records.

Please note that you are responsible for updating your personal information with us, including any changes to your email address. In the event that the last email address you have provided us is not valid, or for any other reason is not capable of delivering to you the notice described above, our sending of the email containing such notice will nonetheless constitute effective notice of the changes described in the notice.