Privacy Policy


Horsesmouth, LLC (alternately, “Horsesmouth,” “we,” “us” or “our”) respects your privacy and is committed to complying with this privacy policy (“Privacy Policy”), which describes what information we collect about you, including how we collect it, how we use it, with whom we may share it and what choices you have regarding our use of information we have about you. This Privacy Policy applies to information collected on our network of websites, including,,,,,,,,, and (the “Websites”).

Changes to our Privacy Policy

We may change this Privacy Policy at any time. The most recent version of the Privacy Policy is posted on our Websites. All such updates and amendments are effective immediately upon notice thereof, which we may give by posting a revised version of this Privacy Policy or other notice on the Websites. The version of this Privacy Policy posted here [] on each respective date you visit the Websites shall be the Privacy Policy applicable to your access and use of the Websites on that date. Our electronically or otherwise properly stored copies of this Privacy Policy shall be deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this Privacy Policy which were in force on each respective date you visited the Websites.

What Information Do We Collect?

As described in detail below, we may collect certain identifying information from or about you in connection with your use of, or your submissions to, the Websites (the “Collected Information”). Collected Information includes, without limitation, any information that may be used to identify you, including, but not limited to, a first and last name, a home, business, or other physical address, business name, a phone number, an email address, employer name, employer information (i.e., employer address and other identifying information).

Cookies and Usage Reports

By placing a small file known as a “cookie” on your computer (or other device), Horsesmouth and its third party service providers’ servers passively gather information about all visitors’ use of the Websites for several reasons, including, but not limited to, the following: statistics collection and analysis, Website optimization, analytics (as described below), market research, and maintenance of user login information. The information that we and our third party service providers track with cookies includes, but is not limited to, the type of browser (such as Google Chrome or Internet Explorer) and Internet-connected devices being used to access the Websites, your Internet protocol (“IP”) address, your home domain or Internet service provider, your referrer URL (which is the URL for the website that you were viewing prior to visiting the Websites), how you were directed to the Websites, which specific pages you access on the Websites, how long you view each page, the time and date you access our Websites and the total number of visitors to the Websites and any portions thereof. We, and/or our third party service providers, may use the information collected from cookies or similar files on your computer for security purposes (such as authentication), to facilitate site navigation and to personalize your experience while visiting the Websites. This data helps us and our third party service providers improve our respective product and services.

Most popular Internet browser applications will allow you to configure the browser so as not to accept cookies. However, setting your browser to reject cookies may, in certain instances, prevent you from taking full advantage of the Websites (or some portion thereof) and its capabilities, or cause some features of the Websites to function improperly or more slowly.

Google Analytics and Web Beacons

Our Websites may use Google Analytics, a web analysis service provided by Google, in order to better understand your use of our Websites and how we can improve it. Google Analytics collects information such as how often users visit a website, what pages you visit when you do so, and what other websites you used prior to coming to such website. Google Analytics collects only the IP address assigned to you on the date you visit a website, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with your identifying information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit a website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to Websites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Google utilizes the data collected to track and examine the use of the Websites, to prepare reports on its activities and share them with other Google services. Google may use the data collected on the Websites to contextualize and personalize the ads of its own advertising network. To more fully understand how Google may use the data it collects on the Websites, please review “How Google uses data when you use our partners’ sites or apps,” (located here or any successor URL).

Some of the areas of the Websites may contain electronic images known as web beacons (sometimes known as clear gifs) that allow Horsesmouth, and its third party providers or affiliates, to count and track users who have visited certain portions of the Websites. Web beacons collect only limited information and do not collect any of your identifying information. Specifically, Horsesmouth may use a type of web beacon known as a “retargeting pixel,” which will allow users to receive targeted advertising from Horsesmouth via certain social media websites, including Facebook.


We appreciate your questions and comments about the Websites and welcome your messages at our “Contact Us” page, which you can find here. If you correspond with Horsesmouth through the Websites or via email, the Collected Information may include the content of, and metadata regarding, any correspondence you may have with us. We may share your messages with those within our organization who are most capable of addressing the issues contained in your message.

How Can I Opt-Out of Promotional Correspondence?

We may send you emails with promotional offers. If you would no longer like to receive information, newsletters or other promotional messages from us, please click the link at the bottom of any such email you receive from us and follow the instructions. Your email address will be removed from the appropriate list. Please allow us a reasonable period of time in order to satisfy your request, as some promotions may already be in process.

Online Account Management

If you elected to subscribe to any online services provided via the Websites, including the ability to access any password-protected areas of the Websites, you will be required to submit identifying information (including some Collected Information) for the purpose of verifying your identity and your authority to manage the account. This Collected Information will be used exclusively by Horsesmouth, our agents, suppliers and third-party service providers for internal use and to respond to your service requests.

How Do We Use The Information That We Collect?

Horsesmouth and our third party services providers collect and use the Collected Information to operate the Websites and deliver the services, including to provide certain services and improve the user experience, address integrity of Websites or security issues, and conduct research and analysis to maintain, protect, develop, and improve the Websites, sell services, and, additionally, use any information submitted by users as described below or elsewhere in this Privacy Policy. We may send you information that you request from us, promotional materials regarding Horsesmouth or any third party entity or individual affiliated with individual members of Horsesmouth, and any other communication for any other legitimate and lawful business purposes. Additionally, we may retain and use certain Collected Information to facilitate and otherwise address certain inquiries or requests regarding the services or the Websites, or respond to your questions or requests for information about or from Horsesmouth. We may also use Collected Information as necessary to ensure compliance with any Horsesmouth policies and any applicable law, regulation or order.

Except as set forth in this Privacy Policy, Horsesmouth will not use, disclose, or transfer your Collected Information unless:

  1. you expressly authorize Horsesmouth to do so,
  2. it is necessary to allow Horsesmouth’s service providers, agents, or other third parties to provide products or services for or to Horsesmouth,
  3. it is necessary in order to provide the Websites or the services,
  4. Horsesmouth sends you other information that may be useful to you,
  5. Horsesmouth sends you surveys and you voluntarily complete and submit such surveys such as in connection with our Advisor Focus Group program,
  6. subject to applicable contractual or legal restrictions, it is disclosed to entities that perform marketing services on Horsesmouth’s behalf or to other entities with whom Horsesmouth has joint marketing agreements,
  7. it is necessary to protect the confidentiality or security of your records,
  8. it is necessary in connection with other business purposes including, without limitation, verifying identity, age, and/or payment details, investigating complaints about the Websites, risk assessment, security, fraud and crime prevention/detection, monitoring, research and analysis, marketing, establishing and maintaining relationships with your employer and/or affiliated firms, customer purchasing preferences and trends and dispute resolution,
  9. it is necessary to comply with law enforcement, governmental mandate, or other legal requirement, if appropriate, for your protection or in connection with an investigation or prosecution of possible unlawful activity;
  10. subject to applicable contractual or legal restrictions, it is necessary in connection with a sale of all or substantially all of the assets of Horsesmouth or the merger of Horsesmouth into another entity or any consolidation, share exchange, combination, reorganization, or like transaction in which Horsesmouth is not the survivor, or
  11. it is otherwise necessary for Horsesmouth to disclose it as required or permitted by law.

With Whom Do We Share Information That We Collect?

In addition to the uses mentioned or described elsewhere in this Privacy Policy, we may catalog and add Collected Information to our database.

For any purchases that you make through our online store, it will be necessary for us to share some of your Collected Information with the third party payment processors in order to process your requested transaction.

We do not sell, rent, or lease our user lists or the identity of individual users to third parties. However, Horsesmouth may use, sell and/or disclose certain aggregated, anonymized information, such as Websites usage data and survey results, to our trusted business partners such as asset management firms and their service providers. Such information may also be shared with other users or the general public for advertising, informational, or comparison purposes. However, such information shall not be personally identifiable to any user.

We may also disclose Collected Information if we become subject to a subpoena or court order, or if we are otherwise legally required to disclose information. We may also use and disclose Collected Information to establish or exercise our legal rights, to assert and defend against legal claims, or if we believe such disclosure is necessary to investigate, prevent, or take other action regarding actual or suspected illegal or fraudulent activities or potential threats to the physical safety or well-being of any person.

As Horsesmouth grows and develops its business, it is possible that its corporate structure or organization might change or that it might merge or otherwise combine with, or that it or portions of its business might be acquired by, another company. In any such transactions, customer information generally is, and should be expected to be, one of the transferred business assets. Also, if any bankruptcy, liquidation or reorganization proceeding is brought by or against us, your information may be considered a company asset that may be sold or transferred to third parties.

Job Applicants

Any identifying information you provide us when applying for a career position with Horsesmouth will be used solely to consider and act upon your application. We may retain your identifying information for a period of time. We may disclose your identifying information to our agents for the purpose of evaluating your qualifications for the particular position you applied for, or other available positions. We may also disclose your identifying information to third parties hired by us to collect, maintain, and analyze candidates for career positions.

What Choices Do You Have?

When submitting information, corresponding, making requests for information, and otherwise interacting with Horsesmouth and its representatives through or in connection with the Websites, you choose what information to supply or submit, whether you wish to receive further information, and how you may be contacted. Please take care to share only such information as is needed or that you believe is appropriate. Any promotional email we send to you will contain a link which will allow you to opt out of receiving any further correspondence. If you have created an online account, you may request a change your correspondence preferences by contacting us here. You may disable your online account access at any time; however, this will not necessarily result in the deletion of any Collected Information.

How Do We Protect Information Collected About You?

Horsesmouth takes commercially reasonable measures to secure and protect information transmitted via or stored on the Websites. Nevertheless, no security system is impenetrable. We cannot guarantee that information that users of the Website may happen to transmit or otherwise supply will be totally secure. You agree to immediately notify us of any breach of Websites’ security, or this Privacy Policy, of which you become aware.

Linked Websites

For your convenience, some hyperlinks may be posted on the Websites that link to other websites not under our control. We are not responsible for, and this Privacy Policy does not apply to, the privacy practices of those sites or of any companies that we do not own or control. We cannot be responsible for the privacy practices of any such websites or pages not under our control and we do not endorse any of these websites or pages, the services or products described or offered on such sites or pages, or any of the content contained on those sites or pages. We encourage you to seek out and read the privacy policy of each website that you visit. In addition, should you happen to initiate a transaction on a website that our Website links to, even if you reached that site through the Websites, the information that you submit to complete that transaction becomes subject to the privacy practices of the operator of that linked website. You should read that website’s privacy policies to understand how your Collected Information is used and protected.

User-Provided Content

Any information, communications, or material of any type or nature that you submit to the Websites by email, posting, messaging, uploading, downloading, or otherwise (collectively, a “Submission”) is done at your own risk and without any expectation of privacy. We cannot control the actions of other users of the Websites and we are therefore not responsible for any Submissions contained on the Websites. By visiting any of our pages that are contained on the Websites, you are representing and warranting to us that you have reviewed this Privacy Policy and that you will abide by all such provisions contained therein.

Additionally, in the event that we offer a message board or any other interactive or social-type feature on the Websites, please be aware that these areas may allow you to post, and share with other users, certain messages, content, or other information. We encourage you to be wary of giving out any personal information, or any personal information of others to which you may have access, in such forums. The information you post can be collected and used by other people. We cannot guarantee the privacy and safety of these areas and are therefore not responsible for any information you choose to post. Your use of these features is fully at your own risk.

Social Media Platforms and Websites

Any Submission that you submit to any of our pages contained on a social media platform or website by email, posting, messaging, uploading, downloading, or otherwise is done at your own risk and without any expectation of privacy. We cannot control the actions of other users of a social media platform and we are therefore not responsible for any Submissions contained on a social media platform or website. By visiting any of our pages that are contained on any social media platform or website, you are representing and warranting to us that you have reviewed the applicable privacy policy and terms of use of such website or social media platform and that you will abide by all such provisions contained therein.


The Websites are intended for a general audience and is not intended for use or view by children under 13 years of age without parental consent, and we do not knowingly collect information about children or sell products to children. Consistent with the Children’s Online Privacy Protection Act, we will not knowingly collect any information from children under the age of 13. If you are under the age of 13, you must ask your parent or guardian to assist you in using the Websites. Furthermore, we may restrict entries to any contests, sweepstakes or promotions to entrants who are at least 18 years of age.

Visiting The Websites From Outside The United States

If you are visiting the Websites, or any part thereof, from outside of the United States of America, please be aware that your information may be transferred to, stored or processed in the United States, where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to protect your privacy. By using any portion of the Websites, you understand and consent to the transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this Privacy Policy.

Do Not Track Requests

Certain State laws require that we indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. “Do Not Track” is a standard that is currently under development. As it is not yet finalized, we adhere to the standards set out in this Privacy Policy and do not monitor or follow any Do Not Track browser requests.

Whom Can You Contact For More Information?

If you have any questions or suggestions about the Websites, Horsesmouth, our services, or our privacy practices, please contact us at

This Privacy Policy was last updated on 5/28/19.