Privacy Policy

Last Revised: February 24, 2015

Thank you for visiting the web site. This Privacy Policy
is subject to change by Gorham Associates (hereinafter “Company”) at any time and
at our discretion without notice by updating this posting. We understand the
importance that Internet users place on privacy, and this Privacy Policy describes
how we use personal information that is collected at our web sites. Please read this
Privacy Policy before using this web site or submitting any personal information.
By using this web site, you accept the privacy practices contained in this Privacy
Policy. You are encouraged to review the Privacy Policy whenever you visit the web
site to make sure you understand how any personal information you provide will be
used. We take Children’s Privacy very seriously. Our Terms & Conditions only allow
this web site to be accessed by persons eighteen (18) years or older. Due to the age
restrictions of this web site, none of the information obtained by this web site falls
within the Child Online Privacy Act (COPA).

1. Information We Collect
In order to serve our customers, we collect personally identifiable information, like
names, addresses, phone numbers, email addresses, and sometimes credit card
information when such information is voluntarily submitted by our visitors. We will
only use your personal information for the following purposes: (1) to deliver the
products and/or services to you that you have requested; (2) to validate your
compliance with the terms and conditions; (3) for content improvement and
feedback purposes; and (4) to reach you, when necessary, regarding your use of the
web site or product(s).

We may disclose personally identifiable information collected if we have received
your permission beforehand (such as to fulfill a third party order) or in very special
circumstances, such as when we believe that such disclosure is required by law or
for other special cases described below. We may also periodically conduct surveys
of our subscribers and customers from time to time so we can improve on the
products and services that we provide.

We may use aggregated and non-identifying information from our subscribers and
customers for various purposes, such as to tailor our advertisements, find the most
suitable joint venture partners, develop proper survey questions, improve our
business, etc. By permitting us to collect this information, you will be able to
receive information on products and services that may be of interest to you,
including related third party offers that we may send to you. You also enable us to
personalize your experience with us so that we can provide you with the highest
quality of service.

By submitting your email address on this web site, you agree to receive email from
us. You can cancel your participation in any of these email lists at any time by
clicking the opt-out link or other unsubscribe option that is included in the
respective email. We only send emails to people who have authorized us to contact
them, either directly, or through a third party. We do not send unsolicited
commercial emails, because we hate spam as much as you do.

In addition, you agree that by submitting your telephone contact information on this
web site and/or registering to receive the product and/or service offered herein,
such act constitutes a purchase, an inquiry, and/or an application for the purposes of
the Amended Telemarketing Sales Rule (ATSR), 16 CFR ‘310 et seq. and any
applicable state and local “do not call” regulations. We retain the right to contact
you via telemarketing in accordance with the ATSR and the applicable state

2. Third Party Actions
We do not control and are not liable for the actions of any third parties who we may
promote. We pride ourselves in working with quality companies, but have no control
over the actions of those third parties. While we are not liable for any of the actions
of those third parties, you should feel free to give us feedback from time to time on
your experiences with any third parties to whom we work with so that we may
enhance our future service to all customers.

3. Cookies
We may use cookies to deliver content that is specific to your interests. Cookies are
text files that are used by your computer’s web browser to store your preferences,
and enable us to enhance your user experience with our web site.

4. IP Addresses
We may use your IP address to help prevent fraud, to help diagnose problems with
our server, to gather broad demographic information, and to offer you products and

5. Third Party Web Sites
This web site and/or the products and/or services offered herein may direct you to
web sites that are owned and/or controlled by third parties. We have no control
over those third parties and are not responsible for the content or the privacy
practices of those sites or companies.

6. Commitment to Data Security
All information collected from you is stored in a technically and physically secure
environment. We use SSL encryption to protect sensitive information online, and we
do everything we can to protect user information offline. Unfortunately, no
transmission over the Internet can be guaranteed to be 100% secure. As a result,
while we take reasonable measures to protect your information, we cannot ensure
or warrant the security of the information that you transmit to us, and you do so at
your own risk.

7. Contacting Us
If you need to contact us, you can email us at or send us a
letter at: Jon Gorham, c/o Gorham Associates, 264 Amity Road, Suite 209 Road,
Woodbridge, CT 06525. We strive to provide excellent products, along with equally
excellent customer service. If you have any questions about this Privacy Policy or
our practices, please feel free to contact us using one of the methods listed above.