Collection of Personal Information
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. We collect Personal Information through our Services, including:
- Postal address
- Telephone number
- Email address
- Broker/dealer, financial advisor, custodian and similar parties
- Date of birth
- Government-issued IDs, such as driver’s license number or Social Security number
- Income, assets, bank account, tax, and other financial and transaction-related information, including investment amounts, purchase dates, and share class
If you are a California resident, please see our California Privacy Notice for more information about how we handle your Personal Information and how to exercise your privacy rights.
Use of Personal Information
We and our service providers may use Personal Information for the following purposes:
- Providing the Services functionality and fulfilling your requests
- To provide the Services’ functionality and related services to you.
- To respond to your inquiries, create and maintain your registered accounts, and fulfill your transactions and requests.
- To send administrative information to you, such as changes to our terms, conditions, and policies.
- Providing you with our newsletter and/or other marketing materials
- To send you marketing related emails, with information about our services, new products, surveys, and other news about our company.
- Analyzing Personal Information for business reporting and providing personalized services.
- To analyze or predict our users’ preferences, so we can improve our Services.
- To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information tailored to your interests.
- Aggregating and/or anonymizing Personal Information.
- We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
- Accomplishing our business purposes.
- For data analysis, for example, to improve the efficiency of our Services;
- For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
- For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
- For enhancing, improving, repairing, maintaining, or modifying our Services;
- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users; and
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
Disclosure of Personal Information
We may disclose Personal Information:
- To our third party service providers, to facilitate services they provide to us.
- These can include providers of services such as website hosting, data analysis, transaction processing, fraud prevention, information technology and related infrastructure provision, customer service or support, marketing and ad agencies, email delivery, auditing, and other services.
- To third parties with which we do business that have a pre-existing relationship with you, such as broker/dealers, financial advisors and custodians.
- To other third-party business partners, such as financial institutions and other entities that are involved in the investment process.
- By using the Services, you may elect to disclose Personal Information.
- On message boards, online groups, and other services to which you are able to post information and content. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
Other Uses and Disclosures
We may also use and disclose Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, to respond to requests from public and government authorities, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of you, or others. We may use, disclose or transfer your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our assets or stock (including in connection with any bankruptcy or similar proceedings).
Collection of Other Information
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. We and our service providers may collect Other Information through the Services in a variety of ways, including:
- Your browser or device.
- Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version. We use this information to ensure that the Services function properly.
- Analytics and Pixel tags
- Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
- IP Address
- Your IP Address is a number that is automatically assigned to your computer by your Internet Service Provider. An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the pages visited. We use IP Addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Services. We may also derive your approximate location from your IP Address.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
We give you choices regarding your Personal Information. You may opt out from:
- Receiving marketing-related emails from us. If you no longer want to receive marketing related emails from us on a going-forward basis, you may update your email preferences, including opting out of all marketing emails from us, by clicking the “Update Email Preferences or Unsubscribe” link at the bottom of each such email.
Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide our services to you;
- Whether there is a legal obligation to which we are subject, for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them; or
- Whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations.
THIRD PARTY SERVICES
USE OF THE SERVICES BY MINORS
The Services are not directed to individuals under the age of thirteen (13), and we do not knowingly collect Personal Information from individuals under 13.
JURISDICTION AND CROSS-BORDER TRANSFER
We are located in the United States. We may store and process your Personal Information in any country where we have facilities or in which we engage service providers. By using the Services, you understand that your information will be transferred to countries, states and/or provinces outside of your place of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
ADDITIONAL INFORMATION REGARDING NEVADA RESIDENTS
We do not sell Covered Information as defined under Nevada law. If you would like to make a further inquiry regarding the selling of your Covered Information, as defined under Nevada law, please email us at email@example.com.
ADDITIONAL INFORMATION REGARDING CANADA
If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company, or withdraw your consent for processing of your Personal Information, you may contact us in accordance with the “Contacting Us” section above. We will respond to your request consistent with applicable law.
For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to making your request.
Data Protection Officer
The Chief Compliance Officer is the data protection officer responsible for Canada and may be contacted at firstname.lastname@example.org.