Privacy Policy

The policies and procedures enumerated below (“Privacy Policy”) set forth the guidelines concerning how Marram Investment Management, LLC, its subsidiaries and affiliates (referred to herein collectively as “Marram”) gathers and uses information about you through your use of this website (“Site”). Please review the Privacy Policy carefully and in conjunction with the Terms and Conditions of the Site which detail other important information surrounding your use of the Site. By visiting or submitting information through the Site, you are deemed to have consented to the practices described in this Privacy Policy.

Information Collection

In order to obtain access to certain information or materials contained on the Site, you may be required to provide Marram with personally identifiable information about you which may include, but is not limited to, name, postal address, e-mail address, telephone number and investor type, in addition to any other information you choose to provide to us in your communication with the firm.

Additionally, Marram may collect certain information about you through the use of technology. For example, we may collect your IP address (which is associated with the portal through which you access the Internet) each time you request a page during a visit to the Site, which allows Marram to collect information regarding the frequency with which users browse various parts of the Site. The Site may also use cookies. “Cookies” are pieces of information, or files, placed on your hard drive that provide information including how and when pages on the Site are accessed by users. You may configure your browser to set preferences regarding cookies such that you can have your computer warn you each time a cookie is sent. Note that you may decline placement of cookies if your internet browser permits, though certain portions of the Site may be inaccessible to you if you choose to do so. You may at any time delete any cookies from your hard drive. Aggregated data gathered from cookies is used by Marram to help maintain and improve the information provided on this Site for users.

Marram may also employ other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send Site users to determine whether such users have opened those e-mails and/or clicked on links in those e-mails. Marram may collect the information from use of these technical methods in a form that is personally identifiable.

During some Site visits, Marram may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), and methods used to browse away from the page. Marram may use this information to measure Site activity, to develop ideas for improving the Site and for any other purpose to the extent permitted by applicable law.

Information Use

Marram does not sell your personally identifiable information. However, the firm may share your personally identifiable information with the firm’s affiliated companies, service providers, vendors, contractors, and agents (“Service Providers”) that enable such entities to perform services for the firm as part of normal business operations. For example, processing your requests for forms or other literature or materials and performing research with respect to the usage of the Site. Personnel employed by Service Providers generally may have access to your personally identifiable information for the purpose of performing duties for the firm but are prohibited from using such information for other purposes.

Marram also may disclose personally identifiable information to the extent permitted by law. For example, to protect the security of records, to protect against fraud, to comply with applicable law, or to respond to judicial process or regulatory authorities.

Safeguarding of Information

Marram maintains established internal policies and procedures with respect to safeguarding access to your personally identifiable information in the firm’s possession from unauthorized use or disclosure. Please note that such safeguards, however, do not guarantee that personally identifiable information transmitted via the internet or stored in the firm’s systems or is otherwise under Marram’s care will be absolutely safe from unauthorized use or intrusion from third parties due to the inherent nature of the Internet.

Links to Third Party Websites

This Site may contain links to third party websites which, in some cases, may be integrated into, and appear to be part of, the Site. Marram encourages you to read the privacy policies of others websites you link to from this website and disclaims any responsibility for the privacy policies and procedures of any third party websites that you reach via a hyperlink contained on this Site.

Amendments to this Privacy Policy

Marram reserves the right in the firm’s sole discretion to modify or amend this Privacy Policy in any way at any time. Any such changes are effective upon posting. You should review this Privacy Policy periodically for changes applicable to you. Additionally, note that by accessing this Site subsequent to any modification, you are deemed to have agreed to all terms of this Privacy Policy as modified or amended.

Contact Us

If you are visiting this Site from the United Kingdom, member state of the European Union, or any other jurisdiction outside of the United States, please note that this Site is hosted within the United States and only complies with the applicable rules and regulations of the United States. Please direct any questions regarding Marram’s Privacy Policy to vivian@marramllc.com.