Privacy Notice

Introduction

Privacy is very important to us. We also understand that privacy is very important to you. This Privacy Policy describes what information we collect and how we will gather, share, use and protect that information. As used in this Privacy Policy, terms such as “we,” and “our” and “Our Firm” refer to the entity identified on this website. “You,” “your,” “user,” and similar terms refer to you, the individual interacting with Our Firm and this website, any person on whose behalf you are interacting with Our Firm and this website, and any person or entity that has rights through you. You agree to follow and be bound by the terms of this Privacy Policy by your interaction with Our Firm or use of the website. Amendments to this Privacy Notice will be posted to the Site and will be effective when posted. If you do not agree, you must not interact with Our Firm or access, use, or download material from this website. All contact information can be found on the home page of Our Firm’s publicly available website.

California Residents: For information relating to additional rights for California residents, please review the California Residents Section.

EU Residents: For information relating to additional rights for EU residents, please review the EU Residents Section.

Changes to Privacy Policy: We will post changes or updates to this Privacy Policy on this or a similar page of this website.

 

Scope of this Privacy Policy

This Privacy Policy (“Policy”) informs about Our Firm’s information processing practices. It applies to any personal information collected on or through the websites owned and operated by Our Firm or through other interactions with Our Firm. This Privacy Policy only applies to individuals who are not investment advisory clients of this firm. If you are an investment advisory client of this firm, you will receive a notice relating to information you provide pursuant to these services prior to or at the time of your investment advisory relationship. This Privacy Policy also does not apply to information collected by any third party, including through any link, content, or application that is accessible from or on our website.

 

Personal Information

The type of personal information that identifies you individually which we collect from and about you online will depend on how you interact with us and may include:

• Contact details, such as your name, address, and email address
• Personal details, such as your social security number, and driver’s license number
• Digital access details, such as your unique personal identifier (e.g., device ID, online identifier) or Internet Protocol address
• Financial details, such as your account name, financial account type, and financial account number, or any other information reported on applications or forms provided by you, or
• Other similar identifiers
• Characteristics of protected classifications under state/federal law (e.g., age, race, sex, etc.)
• Financial information, including financial account numbers and financial account types
• Commercial information (e.g., purchase history)
• Internet or other electronic network activity information (e.g., browsing history, interaction with our website, etc.)
• Geolocation data
• Audio, electronic, visual, thermal, olfactory, or similar information (e.g., call recordings)
• Professional, employment-related, occupational or other similar information
• Healthcare or any healthcare-related information, including information about your health or habits

In some places on this website, you can send us Personal Information about yourself. To elect to receive information, or to participate in an activity, we will ask you to provide us with certain Personal Information about yourself. For example, you may fill out a registration form, a survey, or an e-mail form and you may elect to receive informational material about our products and services. It is your choice whether you want to provide any Personal Information on this website.

You also may choose to allow us to personalize your visits to the website, in which case we will ask you for certain Personal Information to make your visits to our website more helpful to you. When this information is combined with the information that we collect through cookies (described below), we will be able to tell that you have visited our website before and can personalize your access to our website, for example, by telling you about new features that may be of interest to you.

 

Collecting Personal Information

We may collect personal information about you in various ways such as through your computer or mobile devices using cookies and similar tracking technologies (see our Cookie Policy for details) and any personal information you provide to us.

We may collect personal information in the following ways:

• Directly from clients and/or prospective clients’ interactions with us, including with our applications, websites, services, and representatives
• Publicly available sources
• Organizations with whom we partner to provide services
• Apply for or open a new account
• Register for a new product or service, or request information about a product or service
• Request for educational or informative material through our website
• Register as a participant in one of our events or seminars
• Complete a survey, contest or sweepstakes, or other promotion

How we use your Personal Information

We may keep and use the Personal Information we collect from you through this website to provide you with access to this website. In addition, we may keep and use your Personal Information:

• to respond to your requests
• to personalize your access to our website, for example, by telling you about new features that may be of interest to you
• to develop records, including records of your Personal Information
• to process your transactions and/or maintain your account(s)
• to contact you with information that might be of interest to you, including, to the extent permitted by law, information about educational and marketing communications and/or about products and services of ours and others
• for analytical purposes and to research, develop and improve programs, products, services, and content
• to remove your personal identifiers (your name, e-mail address, social security number, etc.). In this case, you would no longer be identified as a single unique individual. Once we have de-identified information, it is non-personal information, and we may treat it like other non-personal information.
• to enforce this Privacy Policy and other rules about your use of this website
• to protect someone's health, safety, or welfare
• to protect our rights or property
• to comply with laws or regulations, court orders, or other legal processes

Sharing Personal Information with Third Parties

We will only share your Personal Information as indicated in this Privacy Policy and otherwise permitted by law.

• We may share or transfer your Personal Information if all or part of Our Firm is sold, merged, dissolved, acquired, reorganized, or subject to a similar transaction.
• We may share your Personal Information with third parties if we use those third parties to perform services for Our Firm or on our behalf. These third-party services may include:
  • processing your order
  • managing your account
  • receiving payment
  • or sending you an email message on our behalf.
• We may also use third parties to host or operate some of our websites or related computers and software applications.
• We may share your Personal Information with our subsidiaries and affiliates.
• We may share your Personal Information to comply with a court order or other legal process or requirements or to protect the safety of you, members of the public, other users of this website, or any other person, or to protect our rights or the rights of others.
• In addition, we may share or use your Personal Information for any other legally permitted business purpose at our sole discretion.
• Depending on the features of this website, we may use or share Personal Information to track your activities/progress on and through this website.

 

Reviewing My Information, Access, and Choice

You have the ability and right to opt in or out of receiving various communications of our website or app, as well as a clear and easy-to-follow method for opting in or out which is required by law in certain circumstances. You can exercise any applicable rights by emailing the email listed on our publicly available website or contacting us at the phone number listed on our publicly available website.

 

Cookies and Data Collection

This website uses the first party “cookies” only to track your return visits but not to identify you personally by name, email, or any other data. Cookies and similar tracking technologies (collectively, “cookies”) are small data files that are sent to your browser and placed on your computer’s hard drive when you visit a website. You do not have to accept cookies to use our website, however, some sections of our website may not work properly if you decline cookies. Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, cookie-enabled websites will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies, visit www.aboutcookies.org. Visit the Network Advertising Initiative site, http://www.networkadvertising.org/choices/, to learn about setting preferences and opting out of third-party targeting cookies.

 

Social Media and Third-Party Platforms

Certain situations or functionalities on this website may permit you to choose to cross-post or share information on a third-party social media site or platform such as Facebook, Instagram, LinkedIn, Twitter, Google+, or other similar sites (collectively, “Social Media Sites”). Our Firm does not own or control such social media sites and posting your information on Social Media Sites is subject to the third party’s privacy policy and other legal terms, which may or may not provide privacy protections you agree with. Our Firm is not responsible for any act or omission of any Social Media Site, nor are we responsible for the consequences of choosing to share your information on Social Media Sites.

 

Children’s Privacy

We are committed to protecting the privacy of children. We ask that children between the age of 13 and 18 obtain the permission of their parent or guardian before viewing our website. We do not knowingly allow children to order our products, communicate with us, or use any of our online services. If you think that a child has provided us with Personal Information, please contact us. We will use reasonable efforts to delete this information. We are not liable for any unauthorized use of this website by minors.

 

Transfer of Personal Information

We operate in the United States, so your Personal Information may be stored and processed, transferred between, and accessed within the United States and some states may not guarantee the same level of protection of Personal Information as of the one in which you reside. In such a case, we may rely on mechanisms permitted under the laws of the state where you are located to affect the transfer with appropriate safeguards.

 

Links to Other Websites

This Privacy Policy only applies to Our Firm’s website and does not apply to websites of other organizations to which this site links. These links are provided for your convenience. These sites may send their cookies to you and may collect and use data in ways that Our Firm would not. Please note that Our Firm is not responsible for the privacy practices of those third-party websites. We encourage you to review the Privacy Policy for each website you visit once you leave our website.

 

Security

We take steps to protect against the loss and misuse of the information under our control. Please keep in mind that no Internet transmission is 100% secure. Any information you send to or receive from this site may not be completely secure, and you do so at your own risk. We are not responsible or liable for illegal acts, such as hacking, by third parties.

 

Data Retention

We will retain your Personal Information for as long as needed or permitted considering the purpose(s) for which it was obtained and as outlined in this Privacy Policy. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the Site to you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable considering our legal position (such as regarding the enforcement of the Site Terms of Use, applicable statutes of limitations, litigation or regulatory investigations).

 

Contact Us

If you have any questions or comments about this Privacy Policy or if you want to execute any of your rights regarding your Personal Information, please contact us using the contact information available on our publicly available website.

 

State and Country Privacy Notices

You may have certain rights and choices regarding our processing of your Personal Information.  Depending on your jurisdiction, applicable laws may entitle you to additional consumer rights.

 

California Residents

Your Rights

If you are a California resident, the California Consumer Privacy Act (CCPA) may provide you with additional rights regarding the use of your Personal Information (with certain limitations and exceptions). These rights include:

• The right to access the Personal Information we process about you.
• The right to know what Personal Information is collected about you and if any information is sold or disclosed, and to whom.
• The right to request the deletion of your Personal Information, when applicable.
• The right to opt-out from the sale of your Personal Information, when applicable.
• The right to not be discriminated against for exercising any of the rights above.

We do not sell the personal information of California consumers, including minors.

 

Do Not Track Disclosure

Because there currently is not an industry or legal standard for recognizing or honoring Do Not Track signals, this website does not monitor for or adjust any use of information as a result of so-called Do Not Track beacons or notices.

 

California Personal Information Exclusions

Personal information under the California Consumer Privacy Act does not include information that is

• publicly available from government records,
• de-identified or aggregated consumer information,
• certain personal or financial information covered under certain sector-specific privacy laws.

Sharing Your Personal Information

We will only share your Personal Information as indicated in this Privacy Policy and otherwise permitted by law.

• We may share or transfer your Personal Information if all or part of Our Firm is sold, merged, dissolved, acquired, reorganized, or subject to a similar transaction.
• We may share your Personal Information with third parties if we use those third parties to perform services for Our Firm or on our behalf. These third-party services may include:
  • processing your order
  • managing your account
  • receiving payment
  • or sending you an email message on our behalf. (Target advertising)
• We may also use third parties to host or operate some of our websites or related computers and software applications.
• We may share your Personal Information with our subsidiaries and affiliates.
• We may share your Personal Information to comply with court orders or other legal processes or requirements or to protect the safety of you, members of the public, other users of this website, or any other person, or to protect our rights or the rights of others.
• In addition, we may share or use your Personal Information for any other legally permitted business purpose at our sole discretion.
• Depending on the features of this website, we may use or share Personal Information to track your activities/progress on and through this website.

Sensitive Information

We collect, process, and share sensitive personal information in the operations of Our Firm. The categories of sensitive information we process are:

• Tax ID, Financial Information, and account information to complete financial transactions and contracts. This information is shared with business partners and government agencies.

Exercising your rights

You can exercise any applicable rights by emailing the email listed on Our Firm’s publicly available website or contacting us at the phone number listed on Our Firm’s publicly available website.

We reserve the right to verify your identity in connection with any requests regarding Personal Information to help ensure that we provide the information we maintain to the individuals to whom it pertains and allow only those individuals or their authorized representatives to exercise rights concerning that information. If you are an authorized agent requesting on behalf of a consumer, we may require and request additional information to verify that you are authorized to make that request.

We reserve the right to deny your request if we cannot verify your identity. Where we deny your request in whole or in part, we will endeavor to inform you of the denial and provide an explanation of our actions and the reasons for the denial.

We will not restrict or deny you access to our website or services because of choices and requests you make in connection with your Personal Information. Please note, that certain choices may affect our ability to deliver services or interact with you. For example, if you sign up to receive marketing communications by email, and then ask Our Firm to delete all your information, we will be unable to send you marketing communications.

 

 

EU Residents 

Your Rights

Under data protection laws, you may have rights as an individual concerning the Personal Information we hold about you (with certain limitations and exceptions). These rights include:

▪ The right to object to direct marketing - your preferences, including concerning direct marketing, may be found in your account.

▪ The right to access the Personal Information that we process about you.

▪ The right to request the deletion of your Personal Information.

▪ The right to request the rectification of your Personal Information - you can manage some of this information in your account. You also have the right to file a complaint with a supervisory authority.

 

Processing Your information

We may need to hold, process, and transfer your Personal Information but will do so solely for legitimate business purposes per applicable laws, regulations, and guidelines. We will only disclose your Personal Information on a need-to-know basis to those who are authorized to use it for these purposes.

We process the Personal Information listed above for purposes including:

▪ User consent – This is where you have permitted us to process Personal Information for a given purpose. You have the right to withdraw this consent at any time.

▪ Legitimate business purposes – This is where we have a legitimate interest, as a business, to process Personal Information. We take due care to balance our interests against your right to privacy.

▪ Contractual necessity – This is where we must process Personal Information to meet our contractual obligations.

▪ Legal obligation – This is where we must process Personal Information to comply with the law.