Privacy Policy

Welcome to, the Web Site for SES ESOP Strategies (SES). We are committed to maintaining the privacy of information that you might share with us while visiting our site and interacting with us online. This privacy policy and agreement (the Privacy Policy or Policy) covers how we collect, use, and treat personal information that you may provide through the Web Site (the Web Site or the Site).

The terms you and your refer to any visitor to the Web Site, including (i) casual visitors to our Site, who wish to learn more about our services (Site Visitors); and (ii) clients and others who choose to subscribe to our publications, and to receive announcements and other information from our Site (Information Recipients). The terms we and us refer to SES ESOP Strategies, and the term refers to our Web Site. For your convenience, we have provided a full set of definitions used in this Privacy Policy.

Your Consent

Please read this Privacy Policy carefully; when you consent to this Policy’s terms, it creates legal obligations on you and on SES. We ask you to show your consent to the terms of this Privacy Policy in different ways, depending on your relationship to the Site. The procedures for consenting to this Policy are (a) less formal if you are a casual Site Visitor, and (b) more formal if you are seeking to become an Information Recipient.

Consent by Site Visitors

By accessing and using our Web Site as a Site Visitor, you are acknowledging that you have read and understood this Privacy Policy and agree to be legally bound by it. If you do not agree with the terms of this Privacy Policy, please refrain from using our Site.

Consent by Information Recipients

If you register to become an Information Recipient via our Web Site, you will be prompted to click an I Accept button linked to this Policy during the registration process. Clicking I Accept further confirms your agreement to be bound by this Privacy Policy.

Connection to Our Web Site Terms

Clicking the I Accept button will also confirm your agreement to comply our Web Site Terms, including our Code of Conduct, as further specified during the registration process.

Components of our Web Site

Our Web Site is divided into two broad areas and features: (i) those areas and features that are accessible to all Users (the General Site); and (ii) those areas and features that are password-protected, and that are designed to be available only to authorized users.

Our General Site

Our General Site is designed to provide Users with a range of information concerning (i) the services we offer; (ii) our professionals and their experience; (iii) the geographic and other subject matter areas in which we practice; (iv) employment opportunities; and (v) other materials concerning our firm. On our General Site, for example, Users can request newsletters, and other updates from SES.

The Types of Information You May Provide

Information you may provide while visiting our Site or while participating as an Information Recipient falls into two broad categories: (i) Personal Information; and (ii) aggregate information. We use the term Personal Information to mean any information you provide to us over the Site that could reasonably be used to identify you, including your name, address, email address, birth date, telephone number or any combination of such information that could be used to identify you. Anonymous Information is information that does not identify you, and may include statistical information concerning, for example, the pages on our Site that users visit most frequently.

Our Uses of the Information You Provide

We use information you provide to us via the Web Site only as provided in this Policy. First, we use the Personal Information you provide via the Web Site only for purposes of providing you information concerning SES and for otherwise responding to requests you may make, as permitted by our Web Site. We do not share your Personal Information with any third parties (except as provided in Disclosures to Third Parties).

Specifically, we collect, or receive, information from Site Visitors and Information Recipients at different points on our Web Site, and use this information as follows:

Registration Information. In order to become an Information Recipient on our Site, we require that you complete a registration form. This form asks for contact information, which includes such items as (i) name; (ii) mailing address; and (iii) e-mail address. We use this information to provide our Information Recipients with materials, as outlined below.

E-mail Addresses. We use your e-mail address to send newsletters, announcements concerning SES or developments, notifications, and other information relating to our Site. In addition, we may use your e-mail address to invite you to presentations, or other functions we believe may be of interest to you. You will have the ability to opt out of receiving these materials, as provided in Changing or Removing Information; Opting Out.

Informational Notices and Bulletins. Periodically, we may choose to send news, bulletins, or other information to Users, and will use Personal Information to send such communications. If we choose to undertake such communications, you will have the ability to opt out of receiving these communications as provided in Changing or Removing Information; Opting Out.

Anonymous, Aggregate Information. We use Anonymous Information to analyze the effectiveness of our Site, and for other similar purposes. In addition, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics of Users of the Site, and may share Anonymous Information with third parties for this purpose. Rest assured, though, that Anonymous Information provided to third parties will not allow anyone to identify you, or determine anything personal about you. We may collect Anonymous Information through features of the software that supports our Site, through cookies, and through other means described below.

IP Addresses; Logs. We may automatically receive and record information in our server logs from your browser, including your IP address (the Internet address of your PC), your computers name, the type and version of your Web browser, referrer addresses, where the computer is routing from, and other generally-accepted log information. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Web Site is being used, and for security and monitoring purposes.

Cookies. A cookie is a small amount of data, which often includes an anonymous unique identifier, which is sent to your browser from a Web Sites computers and stored on your computers hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a Web Site upon a future visit. We may include cookies on our Web Site and use them to recognize you when you return to our Web Site. You may set your browser so that it does not accept cookies. Cookies must be enabled on your web browser, however, if you wish to access certain personalized features of our Services.

Tags. We may use so-called pixel tags, which are small graphic images (also know as Web beacons, single-pixel GIFS, or Web bugs),to tell us what parts of our Web Site have been visited, to measure the effectiveness of searches customers perform on our Site, and for other purposes. Pixel tags also enable us to send e-mail messages in a format Users can read, and they inform us whether e-mails have been opened, to help ensure that our messages are of interest to our Information Recipients and others. None of this data includes Personal Information, and you can opt-out of receiving these types of e-mails from us by following the directions provided in Changing or Removing Information; Opting Out. If any Personal Information is collected using such tools, it will be subject to the terms of this Privacy Policy.

Click-Throughs. We may send e-mail messages which use a click-through URL linked to content on our Web Site. When you click one of these URLs, you pass through our Web server before arriving at the destination web page. We track this click-through data to help determine Users interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked simply do not click text or graphic links in the e-mail, or notify us in accordance with Changing or Removing Information; Opting Out.

Any Information Linked With Your Personal Information Is Protected As Personal Information

To enable us to better understand the characteristics of our Users and to provide information tailored to your needs, we may link (a) the Personal Information you have provided with (b) Anonymous Information. If we combine or link any Anonymous Information or other information with your Personal Information, the resulting combination will be treated and protected as Personal Information under this Privacy Policy.

The Relationship Between Information You Provide At Our Site, And Information From Offline Sources

This Privacy Policy applies to information that you provide through using our Web Site. This Privacy Policy does not apply to information you provide to SES through other means.

Disclosures to Third Parties

As an exception to the policies set out in Our Uses of the Information You Provide, we will disclose your Personal Information to third parties without your express consent in the following circumstances:

Site Vendors. We may employ other companies to perform functions on our behalf, such as maintaining the Web Site, providing services related to the Site, collecting information, responding to and sending electronic mail, or other functions necessary to our business. In order to obtain these services, we may need to share your Personal Information with these companies (collectively, Site Vendors). We will provide Site Vendors with only that information necessary to perform their duties with respect to our Web Site, and we do not allow them to use your Personal Information for any other purpose.

Questions of Harm; Legal. We may reveal your Personal Information on a case-by-case basis in order to comply with applicable Ethics Rules.

Changing or Removing Information; Opting Out

Discretionary Account Information. To allow appropriate control over Personal Information, you can access your account (after supplying your user name and password) to change your password, or to correct your e-mail address for errors.

Opt-Out. If we send to you bulletins, updates, or other communications, we will provide you with the ability to decline or opt out of receiving such communications. Instructions for opting out will be provided either (a) with each such communication, or (b) in a prominent location on our Web Site. Please understand that you will not be allowed to opt out of formal notices concerning operation of this Web Site, and legal and other related notices concerning your relationship to the Site.

Deleting Information Provided Via this Web Site. If you have provided us with Personal Information in connection with your use of this Site, upon your request, we will remove this Personal Information from our Web Site databases. Please understand, however, that it may be impossible to remove this information completely, due to backups and records of deletions. In addition, please understand that, if you request deletion of your information, you will be unable to utilize associated features of the Web Site and any associated Services. You may not remove de-identified, anonymous, or aggregate data from our databases.

Limitations on Deleting Information. Please keep in mind that this Privacy Policy applies only to information provided through this Web Site, and does not apply to Non-Web Site Information, which is information SES obtains or is provided via other channels, such as public databases. Therefore, if we remove information from our Web Site databases in accordance with Deleting Information Provided Via this Web Site, this will not remove Non-Web Site Information from our databases. We will retain this Non-Web Site Information in our databases, including Personal Information that may relate to our users, where applicable law permits us to retain the Information.

If you have questions concerning Non-Web Site Information, you may contact us as provided in Contact Us.


Concerning Site Functionality and Availability. SES does not promise that the Web Site will be error-free or uninterrupted, or that the Site will provide specific results from your use of any content, search, or link on the Site.


Advisory; No Legal Advice Provided Via the General Site. The information presented on the General Site is provided as a courtesy by SES. The General Site is not intended a substitute for professional legal advice. If you have, or suspect that you may have a legal problem, you should consult your lawyer to obtain legal information and recommendations specific to your problem.


Persons accessing this information assume full responsibility for the use of the information and understand and agree that SES is not responsible or liable for any claim, loss or damage arising from the use of the information.

We have put in place security systems designed to prevent unauthorized access to or disclosure of Personal Information you may provide to us, and we take all reasonable steps to secure and safeguard this Information. Our sites Password-Protected Areas require Users to give us unique identifiers such as their user id and password. Employees of SES (and employees of our Site Vendors) are required to acknowledge that they understand and will abide by our policies with respect to the confidentiality of Personal Information. Our security systems are therefore structured to deter and prevent hackers and others from accessing information you provide to us. We also use software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage. Please understand, though, that this information should not be construed in any way as giving business, legal, or other advice, or warranting as fail proof, the security of information provided by or submitted to our Site. Due to the nature of Internet communications and evolving technologies, we cannot provide, and disclaim, assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.

Notice of Security Incident

If we detect unauthorized access to or use of Personal Information, we will (i) notify affected users of such access or use if the information at issue is sensitive, as determined by law, (ii) deliver this notice by the means we deem most efficient under the circumstances (such as, for example, first class mail or email); (iii) use contact information for each effected user that is current in our files; and (iv) use commercially reasonable efforts to accomplish these steps and effect this notice in a timely manner. To the extent applicable law requires steps in addition to those specified above, we will comply with applicable law.

Notification of Changes

From time to time, we may change this Privacy Policy. If we make any changes regarding disclosure of Personal Information to third parties, upon your next login we will inform you of the modified policy. We will post notice of the new Policy from the privacy link on our Web Site. With respect to Site Visitors, your use of our Site following any such change constitutes your agreement to follow and be bound by the Privacy Policy, as changed. With respect to Information Recipients, no such changes will take effect unless and until you have provided us with your consent to such changes, in accordance with Your Consent, above.

Relationship to Terms of Use and Other Contracts

This Privacy Policy must be read in conjunction with our Terms of Use, and the provisions of our Terms of Use are incorporated herein. To the extent the Terms of Use conflict with the terms of this Privacy Policy, the terms of this Privacy Policy will control.


Anonymous Information has the meaning provide in The Types of Information You May Provide.

Information User means an SES client or other person who chooses to subscribe to publications, or receive announcements and other information, from our Site.

Password-Protected Area means that area or those areas of the Site where, in order to obtain access, a user must provide a password.

Personal Information means a natural persons name, mailing address, e-mail address, telephone number, cell phone number, and other information by which that person can be identified.

Privacy Policy means the Web Site privacy policy, located at

Site Visitor means a casual visitor to the Web Site, who does not seek to become an Information Recipient.

Terms of Use or Terms means the Web Site terms of use, located at

User means a Site Visitor or Information Recipient.

You and you refer to any User of the Web Site.

Site Administration

If you have comments or questions about the administration of this Site, you may contact us at the following address:

SES ESOP Strategies

555 City Avenue, Suite 910

Bala Cynwyd, PA 19004

Effective Date

The effective date of this Privacy Policy is October 1, 2018.


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