Privacy Policy

The Needham Group, Inc. Privacy Policy

The Needham Group, Inc. is committed to safeguarding your privacy. This Privacy Statement describes the types of non-public personal information The Needham Group, Inc., Needham & Company, LLC, Needham Capital Partners and Needham Funds collect about you, the ways we safeguard the confidentiality of this information and when this information may be shared with others. In addition, this Privacy Statement explains how your personal information may be shared among our affiliates to make you aware of valuable products and services, and the ways that you can let us know if you prefer that your non-public personal information not be shared. The following policy applies to users of needhamgrp.com, needhamco.com, needhamcapital.com and neehamfunds.com, including clients who have a brokerage account with Needham & Company, LLC. By using these websites, you consent to the policies and practices described in this Privacy Statement.

1. Non-Public Personal Information We Collect

In order to provide you with superior products and services and to maintain our relationships with our clients, we may collect certain non-public personal information about you. We obtain this non-public personal information from varying sources, including the following:
(1) Applications forms and other communications. We collect information such as your name, address, telephone/fax numbers, assets, income and investment objectives through these documents. Also, we collect information such as name, address, telephone number, e-mail address through needhamfunds.com’s “E-Delivery” and “Request Literature” functions.
(2) Consumer reporting agencies. We obtain information about your creditworthiness and credit history through these sources.
(3) Third-party vendors. We collect background information from various outside sources to verify representations you have made to those sources or us.
With respect to The Needham Funds, we may collect the following non-public personal information about you:
(1) Information we receive from you on or in applications or other forms, correspondence, or conversations, including, but not limited to, your name, address, phone number, social security number, assets, income and date of birth; and
(2) Information about your transactions with us, our affiliates, or others, including, but not limited to, your account number and balance, payments history, parties to transactions, cost basis information, other financial information and information about how you vote your shares. Cookies. As with many websites, our sites use a technology called “cookies.” A cookie is a piece of information that is sent to your browser from a web server and stored on your computer’s hard drive. A cookie allows us to determine that a visit has occurred within our site, as well as which pages were viewed. Cookies are not used to identify you and will not collect personal information. You can decide if and how your computer will accept cookies by configuring your preferences option within your web browser. If you choose to decline cookies, however, some of the functionality of the Site may be impaired.

2. Information Security

We maintain physical, electronic and procedural security measures to safeguard your non-public personal information. Access to such information is restricted to employees who are trained in the proper handling of personal information. Third parties that provide support or marketing services on our behalf may also have access to the non-public personal information we collect about you while carrying out these services, but are required not to share that information with any other third party. While we employ reasonable measures to protect personal information, we cannot guarantee that unauthorized third parties will not defeat those measures or use non-public personal information for improper purposes.