We have adopted general policies and procedures concerning confidentiality, proprietary data and privacy of customer personal information, and the information we gather over the Site is protected by those policies and procedures. Generally, we collect non-public personal information about our clients from the following sources:
- Account applications and other forms;
- Clients’ professional advisers such as attorneys and accountants;
- Clients’ account history; and
- Correspondence between us and our clients, their brokers and their custodians
We will not release information about you or your accounts to any third party unless one of the following conditions is met:
- We receive your prior consent;
- We believe the recipient is your authorized representative, including your attorney or accountant;
- The recipient is a broker, custodian or other service provider with whom we must share information in order to manage your account properly; or
- We are required by law to release the information to the recipient
We will only use information about you and your accounts to:
- Help us better serve your investment and financial needs;
- Suggest services or other materials that may be of interest to you; and
- Administer our business
Our policy is that:
- We do not disclose any non-public personal information about our clients or former clients to anyone, except as permitted by law.
- We restrict access to non-public personal information about our clients to employees who need to know that information to provide services to our clients.
- We maintain physical, electronic and procedural safeguards that comply with federal standards to guard clients’ personal information.
COLLECTION OF INFORMATION
However, we do automatically track certain information that your browser makes available whenever you visit a website. This information includes your Internet Protocol address, browser type, browser language and one or more files that may uniquely identify your browser. This information may include the URL that you just came from (whether this URL is on the Site or not), which URL you next go to (whether this URL is on the Site or not), your computer browser information and your IP address.
We also may use data collection devices such as “cookies” on certain pages of the Site to help analyze our web page flow, measure effectiveness, and promote safety. “Cookies” are small files placed on your hard drive that assist us in providing our services. We offer certain features that are only available through the use of a “cookie.” Cookies can also help us provide information that is targeted to your interests. Most cookies are “session cookies,” meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits.
USE AND DISCLOSURE OF INFORMATION
We may also share information about you if we believe that disclosure is required under law. For example, we may need to disclose information in response to a subpoena or to cooperate with regulatory or law enforcement authorities.
LINKS TO THIRD PARTY WEBSITES
The Site may contain links to third party sites that are not owned or controlled by the Firm. The Firm is not responsible for the privacy practices of such other sites and we encourage you to read the privacy policies of each site that you visit from our Site.
CALIFORNIA DO NOT TRACK NOTICE
Under California law, website service operators are required to disclose how they respond to web browser “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about a consumer’s online activities over time and across third party websites. At this time, the Firm does not track visitors’ personally identifiable information over time and across third-party websites and therefore this requirement does not apply to the Firm.
Your information is stored on our servers located in the United States. We use procedural and technical safeguards to protect your personal information against loss or theft as well as unauthorized access and disclosure to protect your privacy, which may include encryption, “firewalls” and Secure Socket Layers. We treat data as an asset that must be protected against loss and unauthorized access. We employ security techniques to protect such data from unauthorized access by users inside and outside the company.
It is possible, however, that a third party will circumvent such security measures, and we do not guarantee that our security measures will successfully prevent third parties from accessing the information we collect. In the event of a security breach involving your personal information, we will make any legally required disclosures to you in the most expedient time possible and without unreasonable delay, consistent with the legitimate interests of law enforcement, or any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Identity theft and the practice currently known as “phishing” are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your username, password, credit card information or any identification number in an unsolicited email or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
Children (persons under the age of 18) are not eligible to use the Site and, therefore, we do not knowingly collect any personal information from persons under the age of 18.
CONDITIONS OF USE
CHANGES TO THIS POLICY
If you have any additional questions, please feel free to contact Dominic Heil, our Chief Compliance Officer, at firstname.lastname@example.org.