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Your privacy is important to us at Halvorson Research Associates, LLC (“HRA”), and we are providing this Privacy Policy to explain our policies regarding personal information about you. The phrase “Personally Identifiable Information” in this policy refers to information or a combination of information that you provide to us through the use of www.HRAstockpicks.com. This can include your a) first and last name, b) address, c) email address, d) telephone number, and any other personally identifiable information that can be used to uniquely identify you. HRA may collect, use and disclose Personally Identifiable Information about you to its affiliates and others; however, HRA will not sell any Personally Identifiable Information about you to outside parties without permission.

The effective date of this Privacy Policy is October 20, 2004. HRA reserves the right to modify or amend this Privacy Policy at any time. If HRA modifies or amends this Privacy Policy, changes will be posted on this website. Changes will be effective immediately upon their posting to this website. It is solely your responsibility to check this Privacy Policy for any updates or modifications. By accessing or using this website after such changes are posted, you agree and consent to all such changes. Our Privacy Policy is described in more detail below.

COLLECTION AND USE OF INFORMATION BY HRA

HRA may collect any content, record, or electronic communication of any kind, including Personally Identifiable Information, subject to applicable laws. This includes both information that you share with us, as well as other information collected, for example through Internet Protocol (“IP”) addresses.

HRA may collect Personally Identifiable Information about you (for example, requesting a combination of your name, telephone number, e-mail address, mailing address, or related information) in order to provide you with services, and in order to communicate with you and send you information and materials. HRA may also disclose and share Personally Identifiable Information about you with affiliates for HRA’s business purposes.

However, HRA will not sell any Personally Identifiable Information about you to any outside parties. HRA may sell information that is not Personally Identifiable Information, such as aggregate statistics regarding the number of visitors to our website and other information that does not uniquely identify you. HRA and its affiliates may also send you e-mail and other promotions and other information that may be of interest to you from HRA or its affiliates or other third parties.

HRA maintains full rights to any information collected on this website, and may freely collect, use and disclose such information, unless otherwise prohibited by this Privacy Policy or applicable law. In the event of a change in control of HRA or sale by HRA of substantially all of its assets, any Personally Identifiable Information or other information owned by HRA may be transferred to such HRA successor who will comply with the terms of this Privacy Policy.

Requests for Access to Your Information, or Corrections to Errors or Changes in This Information

If you wish to have access to Personally Identifiable Information about you in our records, please contact us with your request. You may also request that we update Personally Identifiable Information about you, or request correction of any factual errors that you believe may exist regarding this information. We will use commercially reasonable efforts to accommodate such requests.

SECURITY

To prevent unauthorized access, and maintain data accuracy and the correct use of information, we have put in place appropriate procedures to safeguard and secure the information we collect online. HRA strives for the best possible data security, especially with regard to such sensitive information as your credit card information. While we cannot guarantee that loss, misuse or alteration to data will not occur, we try to prevent such unfortunate occurrences. In the event someone should obtain your credit card information, consumer protection laws also seek to protect you against the unauthorized use of your credit card. For further information on credit card fraud, you can visit the Federal Trade Commission website at www.ftc.gov.

PRIVACY PRACTICES OF THIRD PARTY WEBSITES

This website may contain advertisements and links to other websites. HRA is not responsible for the privacy policies or practices of any third-party websites, including websites of any sponsors or linked Websites, or for the privacy policies or practices of any other third parties. To the extent that you disclose Personally Identifiable Information to any sponsors’ websites, linked websites or other third parties, different rules may apply to their use or disclosure of any Personally Identifiable Information you disclose to them, and we encourage you to review their privacy policies before disclosing Personally Identifiable Information to them.

CHILDREN

This Website is not directed toward children under thirteen years old, and HRA does not knowingly collect or use information from children under the age of thirteen through this Website without first obtaining parental permission.

AGREEMENT TO TERMS

By your use of this Website, you hereby agree to the terms of this Privacy Policy and consent to the collection and use of information as discussed in this Privacy Policy. HRA reserves the right to change this Privacy Policy at any time.

By your use of this Website, you also hereby agree to the full Terms and Conditions of Use of the Website, which are incorporated into this Privacy Policy by reference. Please carefully review the full Terms and Conditions of Use at the following link. Terms and Conditions of Use

CONTACTING US

If you have any questions or concerns regarding this Privacy Policy, or any requests for access to or changes to information about you, please contact:

Jim Halvorson
4329 E. Ahwatukee Drive
Phoenix , AZ 85044
602-625-5327

JLH@HRAstockpicks.com