Smith Equity Consulting

 Smith Equity Consulting, LLC

Smith Equity Consulting, LLC (“SEC” or “we” or “our” or “us”) values individual privacy, and we are committed to protecting individuals’ personal information.

This Privacy Statement (this “Statement”) explains what personal information we collect, how we collect that information, and what we do with the personal information we collect. This Statement also explains the rights you may have related to your personal information, and how you can contact us with questions about our privacy practices or to request changes or updates to the personal information we have about you.

Explanations about our general personal information practices are provided below, or you may wish to skip one of the following topics:

Scope of this Privacy Statement

This Statement applies to information that we collect about you as an individual user (“you”):

  • by your use of our public website at (directed to the United States) (“Public Site”),
  • by your use of online services available to our clients that may be accessed via our websites (“Client Services”), and
  • by providing your personal information to us or to a partner, service provider, or other entity for the purpose of obtaining information (whitepapers, newsletters, etc.), products or services from us, or
  • when applying for a position with us.

This Statement does not apply to personal information that we receive or collect from or on behalf of our clients in connection with the use of our products or services (including, but not limited to, when information is provided to us through Client Services). We process this data in our role as a service provider or data processor, and only in connection with products and services that we provide to our clients, and according to our clients’ instructions.

  2. Information We Collect and How We Collect It
  3. Information that You Decide to Provide to Us. When you register as a user, request information from us, subscribe to a service, apply for an available position with us, visit our booth at an industry event, or communicate with us through our Public Sites or Client Services, we may ask you to provide certain information about yourself, such as your name, email address, phone number, employer, or similar information to respond appropriately to your request. In these cases, you will know what information is collected through the Public Site or Client Services because we collect the information you provide to us. If there is information that you are required to provide to us or that we are required to collect, based on either law or contract, we will advise you of the requirement at the time we collect that information, and we will also provide information about any consequences of a failure to provide required information.
  4. Information that We Collect Automatically. As part of the standard operation of the Site, we automatically collect information from your computer or device, including IP address, domain name (that you visited from, for example), referral or exit data (the last website that you visited before coming to the Site and the next website you visit afterwards), as well as browser and platform type (a Google browser or an Apple platform, for example). In addition, we collect information about how you use the Site, such as the date and time of your visit, the amount of time you spend on the Site, how often you visit the Site, the areas, or pages that you spend the most time on, and other click-stream data.
  5. Cookies, Beacons and Tags. A cookie is a small text file that is stored on your computer or device when you access the Site. We use cookies on the Site to collect some of the information described above as information we collect automatically, to remember your settings, and for authentication. You can manage the use of cookies through your browser. You may still use the Site if you reject cookies, but it may limit your ability to use some areas of the Site. In addition, with the assistance of our third-party partners and service providers, we may use technologies such as web beacons, tags, Flash cookies or HTML5 to collect or use information about visitors to our Public Sites or Client Services and your actions on those sites for site operations/functionality purposes, and content and/or formatting effectiveness.
  6. Information We Collect Indirectly About You. We may receive personal information about you from others, for example: submitted through our Client Services if you request additional information about our products or services through one of our business partners, through employment recruiters, by referral from a current client or from another third party who may share your personal information with us. We may also collect your personal information through our relationship with our clients, in accordance with the contractual relationship we have with a client.

For information about opting out of or managing the collection or use of such information, please see the section below regarding “Your Choices.”

  1. How We Use Information We Collect

Information that we collect, including your personal information, may be used for the following purposes:

  • To present the Public Sites and Client Services and their content to you.
  • To provide online services that you may access through the Public Sites or Client Services.
  • To provide, maintain and improve our products and services.
  • To respond to your questions or requests for information, or to fulfill any other purpose for which you provide your information to us through the Public Sites or Client Services.
  • To provide you with information about our services, product updates, industry education, invitations to upcoming events, and similar information.
  • To conduct surveys to ensure the Public Sites and/or Client Services are relevant to your needs, or to follow up with you personally to make sure your needs are being met.
  • To better understand how people, use our Public Sites and Client Services, including measuring and monitoring user traffic and using aggregate statistical analysis, which informs future enhancements and changes to the websites.
  • To better understand how our clients, use and interact with our products and services, including by combining information collected through the Public Site and Client Services with information about our clients collected by other means.
  • To consider your application for a position available with us.
  • To contact you about our products and services in response to your visiting our booth at a tradeshow, through a partner that you provided your information to, or other platform that facilitates targeted or other marketing based on their direct relationship with you (such as LinkedIn).
  • For the purpose of providing contracted services to our clients.
  • For any other purpose that we describe at the time we collect your information.

Referrals. If you choose to use our referral service to tell a friend about our website, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the website. We will use information you submit only to send this email and track the success of the success of our referral program.

In addition, if you use the Site or access client services through the Site on behalf of one of our clients, we may combine information about you that is collected through the Site with information about you that has been provided by our client.

  1. Disclosures of Your Information

We may disclose information about visitors to our Public Websites and our Client Services, or that we may otherwise have about an individual, which does not identify the individuals, without restrictions.

Personal information about you, that you provide or that we collect as described in this Statement, that may identify you, may be disclosed to third parties as follows:

  • To our subsidiaries and affiliates.
  • To agents and service providers who are bound by confidentiality obligations and who use the personal information only on our behalf.
  • With your consent.
  • To deliver requested products or services, or otherwise to fulfill a contractual obligation to you or to a client.
  • To initiate a background check if you have applied for a position with us.
  • As otherwise described in this Privacy Statement.

We may also disclose your personal information:

  • As required by law, court order, or legal process, including responding to a subpoena, to respond to a government or regulatory request, or to cooperate with law enforcement investigations.
  • To enforce our contractual rights, take precautions against liability, investigate suspected or actual illegal activities, or to investigate and defend ourselves against third party claims or allegations.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about users of the Site is among the assets transferred.
  • When we believe that disclosure is necessary or appropriate to protect the rights, property, or personal safety of ourselves, our clients, or others.

Whenever we disclose personal information to a third party, we endeavor to minimize the disclosure to only information that is necessary for the purpose of that disclosure.

The types of personal information that may be disclosed about you include unique identifiers (your name, date of birth), demographic information (phone number, mailing address), transaction history with us or our websites, etc.

It is our policy not to sell, rent or exchange your personal information with any third party for commercial purposes. It is our policy not to provide your personal information to third parties for those third parties’ direct marketing purposes without your consent.

  1. How Long We Retain Your Information

We retain the personal information we collect for as long as needed to facilitate the purpose(s) for the collection and as required or permitted by law, or until you tell us to delete it (if we are not otherwise required to retain it).

  1. Transfers of Personal Information to Other Countries

For the purposes described in this Statement, we may transfer personal information outside of its country of origin. The countries where we transfer personal information may not provide the same level of data protection as the laws of your local jurisdiction. We will ensure that any such transfers of personal information are made subject to appropriate safeguards.

  1. Your Choices
  2. Client Controls.If you are one of our clients, you may control the personal information we have about you through your account profile page.
  3. Non-Client Controls. If you are not one of our clients – for example, if you are a former client, a website visitor, a sales/marketing or vendor contact, or job applicant – and you wish to inquire about, access, correct, update, or delete personal information that we may hold about you, please submit your request via:
  • For U.S. by email: or
  • contact us by mail or phone as provided under Section A.9 (Contact Us) below.

Please understand that before responding to your request, we may ask you for additional information in order to verify your identity or take other actions that we believe are appropriate in order to verify your identity.

Please also understand that we may not be able to alter or delete your personal information if we are required under applicable law to maintain that information. We are also not obligated to comply with requests that are unreasonably burdensome or expensive, or with requests that would interfere with the rights of another individual.  In some circumstances, we may charge a reasonable fee to fulfill your request.

  1. Personal information held on behalf of our clients. In some cases, we may hold personal information as a service provider, solely on behalf of our clients (who determine the means and purposes of processing that personal information). In those cases, we may have no direct relationship with individuals whose personal information we hold, and any inquiries or requests to access, correct, update, or delete personal information about you should be made directly to our client. We will honor and support any instructions we receive from a client with respect to your personal information that we process on behalf of that client.

In some cases, we may simply not be aware that we have personal information about an individual, because it was collected through the direct relationship between the client and the individual. We may also encourage requests to be directed to our clients for this reason.

  1. Marketing and Advertising.We have engaged third parties to manage marketing and advertising communications on other sites, which may collect personal information about you and provide advertising to you based upon your browsing activities and interests. If you prefer not to have information used for the purpose of serving you personalized ads, you may opt-out or change your preferences at,  if you are located in the European Union at

To show videos on our websites, we have engaged a third party that uses local shared objects such as Flash cookies and local storage such as HTML5 to save content and viewing preferences (volume, for example). Flash cookies may be managed at: Your browser may offer tools to manage HTML5.

  1. Opting out of communications. If you no longer wish to receive our newsletter or marketing emails, you may stop those communications by following the unsubscribe instructions included in the emails, or if you are a client, by accessing the email preferences in your account settings page, by contacting us as follows:

Existing SEC clients and All others: or as provided under Section A.9 (Contact Us) below.

  1. Do-not-track settings. The Public Site and Client Services do not respond to “do-not-track” requests or similar browser settings.
  2. Security

We take reasonable steps and follow generally accepted industry data practices to protect the personal information submitted to us from accidental loss and from unauthorized access, use, alteration, and disclosure. There is no totally secure or error-free method of transmitting data over the Internet, and we cannot guarantee the absolute security of your personal information.

You are also responsible for the safety and security of your information. It is your responsibility to keep secret any username and password that you use for client login or to access other features of the Site. Please do not share this information with any other person and remember that you are responsible for any use of the Site when it is accessed with your username and password. If you ever suspect or believe that your username or password have been compromised or used by somebody else, please promptly tell us by emailing us at

  1. Changes to Our Privacy Statement

We review this Privacy Statement annually, or as otherwise required, and update it to reflect changes to our information practices, applicable legal requirements, or other changes as we deem appropriate or are required of us. If we make any material changes to how the personal information, we collect about you or how we process it, we will provide a notice on our websites by updating the date the Statement was last revised. We encourage you to periodically review this Statement.

  1. Contact Us

Please feel free to contact us with any questions, comments, complaints, to exercise a right or control related to your personal information or submit suggestions regarding this Privacy Statement or our information practices.

You can contact us by any of the following methods:

  • Via webpage contact form:  (Before using this form please note: This form is hosted in the United States and data entered on this form will be reviewed in the United States)
  • For U.S. by email: or
  • By postal mail or telephone at:

Smith Equity Consulting, LLC
18 Oak Street, #311, Brentwood, CA 94513
Phone: (925) 337-5924 | Toll-free: (866) 470-6333 (select option #4)

Our Data Protection Officer can address any concerns or complaints. If you are a resident of a country in the European Economic Area, you may elect to lodge complaints with a supervisory authority, particularly the supervisory authority in your place of residence, place of work, or in the place where any alleged improper acts occurred.


We are required under the California Consumer Privacy Act of 2018 (the “CCPA”) to provide California residents with certain information about the rights granted to California residents under the CCPA and about our practices with respect to the collection, use and sharing of personal information. For the purposes of this section of this Privacy Policy, “personal information” has the meaning given to that term under the CCPA.

  1. Privacy Rights of California Residents

Where applicable and with certain exceptions, California residents have the following privacy rights under the CCPA:

  • The right to request information described below about how we have collected and used personal information about you within the past 12 months, subject to certain exceptions and limitations:
    • The categories of personal information we have collected about you;
    • The categories of sources from which we collected personal information about you;
    • The categories of third parties to whom your personal information was disclosed;
    • The business or commercial purpose for which your personal information was collected and/or sold;
    • Whether we have disclosed your personal information for a business purpose, and if so, the categories of personal information received by each category of third-party recipient; and
    • Whether we have sold your personal information for a business purpose, and if so, the categories of personal information sold to each category of third-party recipient.
  • The right to request a copy of the specific pieces of personal information we hold about you;
  • The right to request that we erase your personal information, subject to certain exceptions;
  • The right to direct a business that sells your personal information to cease selling your personal information; and
  • The right to be free from discrimination for exercising any of the rights above.

In certain instances, we are only obligated to comply with verified consumer requests, and we will need to verify your identity prior to addressing or fulfilling a request made pursuant to the CCPA. Your request must provide information that allows us to reasonably verify that the request comes from the person about whom we collected personal information, or a person authorized to act on their behalf.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to personal information collected about you. If a request is made by an agent on your behalf, the agent must provide sufficient information for us to reasonably verify that they have been properly designated or authorized by you to act on your behalf.

Please also be aware that the regulation establishes our obligation to provide you, upon request, a copy of your personal information held by SEC up to twice in a 12-month period.

  1. How to Exercise Your Rights

If you are a California resident, you can exercise your rights by contacting us as provided under Section A.9 (Contact Us) above.

  1. Personal Information that We Collect, Use and Share

We are also required under the CCPA to provide California residents with certain information about how we collect, use, and share personal information by reference to statutory categories set forth in the CCPA. The chart below summarizes our practices with respect to personal information of California residents during the 12 months preceding the date of this Privacy Policy, by reference to the information provided above.

Please note that we do not and will not, “sell” personal information collected about you, as “selling” is defined in the CCPA.

Statutory Category

Information Collected

Sources of Information

Purposes of Collection

Disclosures to Third Parties

Identifiers (such as name, email, address, phone number)

See Section A.1

See Section A.1

See Sections A.2 and A.3

See Section A.3

Financial, medical or insurance information (such as payment cards, financial account numbers)

See Section A.1

See Section A.1

See Sections A.2, and A.3

See Section A.3

Characteristics of protected classifications under California or federal law (such as age, gender, race, citizenship)

See Section A.1

See Sections A.1

See Sections A.2, and A.3

See Section A.3

Commercial activity and information (such as transaction history)

See Section A.1

See Section A.1

See Sections A.2 and A.3

See Section A.3

Internet or network activity and information (such as usage and browsing data)

See Sections A.1(b) and A.1(c)

See Section A.1

See Sections A.2 and A.3

See Section A.3

Professional or employment information

See Section A.1

See Section A.1

See Sections A.2 and A.3

See Section A.3

Geolocation data

Not collected in ordinary business operations

Not collected in ordinary business operations

Not collected in ordinary business operations

Not collected in ordinary business operations

Sensory information (such as photos, other recorded electronic information)

Not collected in ordinary business operations

Not collected in ordinary business operations

Not collected in ordinary business operations

Not collected in ordinary business operations

Inferences drawn from any personal information collected

Not collected in ordinary business operations

Not collected in ordinary business operations

Not collected in ordinary business operations

Not collected in ordinary business operations

  1. Transfer of Your Personal Information Outside of Europe

For the purposes described in this Statement, we may transfer personal information out of Europe as follows:

  • To the United States, including for purposes of recruiting through our online portal, as well as for purposes of communications and engagement with our customers, vendors, and service providers.
  • In connection with data practices described above, under How We Use Information We Collect.

These countries may not have enacted laws that provide the same level of protection of personal information as the laws of the EEA, and the European Commission has not issued any formal decision that these countries provide an adequate level of protection of personal information.

In continuing compliance with Privacy rules and regulations, Smith Equity Consulting commits to resolve complaints about our collection or use of your personal information. We are committed to addressing complaints raised to us and will investigate and seek to resolve any complaints within 45 days of receipt. 

  1. Your Rights

If you are a resident of a country within Europe, you have certain individual rights under the General Data Protection Regulation (Regulation 2016/679) or related local legislation. You have the right to obtain confirmation from us as to whether or not we process personal information about you. And if we do process your personal information, your other rights may include, subject to certain exceptions:

  • The right to access your personal information and receive certain information about our privacy practices.
  • The right to have us correct incorrect information that we hold concerning you, or to complete incomplete information.
  • The right to request that we erase information concerning you and to have that information erased under certain conditions.
  • The right to restrict our processing of information concerning you under certain conditions.
  • The right to object to our processing of information concerning you under certain conditions.
  • The right to object to our use of information concerning you for direct marketing, or for profiling relating to direct marketing.
  • The right to receive personal information that you provided to us in a structured and commonly used electronic format and the right to transmit that information to another entity, in certain situations.
  • The right to object to decisions based on automated processing of information concerning you if those decisions have legal effects or similarly significant effects.

If you would like to exercise any of these rights, please contact us as provided in this Statement under Section A.9 (Contact Us) above.

Please understand that, before responding to your request, we may ask you for additional information in order to verify your identity.

If we hold information concerning you on behalf of one of our clients, please understand that we may not be aware that we have your information because we avoid receiving personally identifying details from many of our clients. Or, if we are aware that we hold or process information about you on behalf of a client, we may not be able to accommodate your request to exercise these rights, and we may direct you or your request to our client who controls that data.

In addition, we may not be obligated to fulfill your request to exercise your rights if we are restricted by applicable local laws, or when fulfilling your request would negatively impact the rights and freedoms of other individuals.

We may decline to fulfill requests or charge a reasonable fee based on our administrative costs if requests are clearly excessive or unfounded, and particularly in cases where requests are repetitive.