This privacy policy (“Policy”) describes how (“Company,” “we,” and “our”) processes, collects, uses and shares personal data when using this website (the “Site”).

  1. We only collect information about you that you provide directly do us. This includes:
    Your name, email address, username and password for
    This is to allow you to login once and access all newsletters where a valid subscription exists.
  2. We only share your data with our third party service providers. These service companies provide essential infrastructure services such as payment processing, authentication, and customer service.
  3. Security Notice: We seek to use reasonable organizational, technical, and administrative measures to protect personal data within our organization. No transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us.
  4. Data Retention: We only retain the above noted personal data as long reasonably required for you to use the Site until your subscription term has ended and access is no longer required.
  5. Opt-Out: Anyone may opt-out of messaging from the Site by unsubscribing any free memberships or cancelling free memberships.
  6. Newsletter subscribers will receive the benefit of Hilary Kramer’s commentary, analysis, opinions, advice and recommendations. Each Newsletter is impersonal and does not provide individualized advice or recommendations for any specific subscriber or portfolio.
  7. The Editor does not directly own the securities which are the subject of the commentary, analysis, opinions, advice, or recommendations in, or which are otherwise mentioned in, the newsletter. However, the Editor indirectly owns many of those securities through mutual funds and hedge funds that her management company operates.
  8. Investing involves substantial risk. Neither the Editor, the publisher, nor any of their respective affiliates make any guarantee or other promise as to any results that may be obtained from using the Newsletter. While past performance may be analyzed in the Newsletter, past performance should not be considered indicative of future performance. No subscriber should make any investment decision without first consulting his or her own personal financial advisor and conducting his or her own research and due diligence, including carefully reviewing the prospectus and other public filings of the issuer. To the maximum extent permitted by law, the Editor, the publisher and their respective affiliates disclaim any and all liability in the event any information, commentary, analysis, opinions, advice and/or recommendations in the Newsletter prove to be inaccurate, incomplete or unreliable, or result in any investment or other losses.
  9. The Newsletter’s commentary, analysis, opinions, advice and recommendations represent the personal and subjective views of the Editor, and are subject to change at any time without notice.
  10. The information provided in the Newsletter is obtained from sources which the Editor believes to be reliable. However, the Editor has not independently verified or otherwise investigated all such information. Neither the Editor, the publisher, nor any of their respective affiliates guarantees the accuracy or completeness of any such information.
  11. The Newsletter is not a solicitation or offer to buy or sell any securities.
  12. Subscribers may submit questions to the Editor by e-mail to However, since the Newsletter is impersonal and does not provide individualized advice for specific subscribers, the Editor can only answer questions of a general nature about the markets or specific securities. The Editor will make every effort to answer subscriber questions on our website or in the pages of an upcoming issue of the Newsletter.
  13. Neither the Editor, the publisher, nor any of their respective affiliates is responsible for any errors or omissions in any Newsletter.