Financial companies choose how they share your personal information. Federal law also requires us to tell you how we collect, share, and protect your personal information.
We receive your personal information from your Adviser and from the Qualified Custodian that holds your account. This information can include your social security number and date of birth. We also receive information regarding your account number, balance, holdings, and transactions.
All financial companies need to share their clients’ personal information to perform their operations, such as to process your transactions and maintain your account. When we share your information with third-parties as necessary for the management of your account, we require strict confidentiality in handling your information.
We may also be required to share your information with other third parties to comply with legal requirements, such as subpoenas or court orders; to respond to regulatory examinations; to address fraud, security, or technical issues; or otherwise to protect your rights, property or security.
We may share anonymous or aggregated information with third parties to help deliver products, market our services, and provide research content.
Federal law gives you the right to limit only the sharing of your information with affiliates or third-parties for marketing purposes. We do not share your information for this purpose.
To protect your personal information, we have established an information security program which includes policies addressing acceptable use and access to confidential business information and personal information which may be contained in our information systems. We maintain physical, electronic, and procedural safeguards reasonably designed to guard personal information from loss, misuse, or unauthorized access, disclosure, alteration, or destruction of the information that has been provided to us.
We take commercially reasonable measures that comply with applicable laws and industry standards to secure and protect information transmitted via or stored through our information systems. These measures include computer safeguards and secured files and buildings. Nevertheless, no security system is impenetrable. If you become aware of any breach of our security system, please notify us immediately.
Federal securities regulations require us to maintain certain information regarding you and your account for a period of time after you terminate your participation in the Program. We will continue to maintain and protect your information for the required retention period.
The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to know, access, delete, and limit sharing of Personal Information. For purposes of this section, “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA. Due to the nature of our Program, much of the information we collect is exempt from the CCPA because it is covered by federal or state financial and/or data privacy laws.
To the extent that we collect Personal Information that is subject to the CCPA, your rights as California resident to request access and deletion of that information are as described below.
As a California resident, you have the following rights listed below. However, these rights are not absolute, and in certain cases we may decline your request or comply with it in a more limited way than you anticipated, as permitted by law.
You may request the following information about how we have collected and used your Personal Information during the past 12 months:
- Categories of Personal Information we have collected;
- Categories of sources from which we collected Personal Information;
- The business or commercial purposes for collecting and/or selling Personal Information;
- Categories of third parties with whom we share Personal Information;
- Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third-party recipient; or
- Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third-party recipient.
- You may request a copy of the Personal Information that we have collected about you during the past 12 months.
- You may request in certain circumstances that we delete Personal Information that we have collected directly from you.
- If we sell your Personal Information, you may opt-out.
- You are entitled to exercise the rights described above free from discrimination.
In order to process a request to know about or delete Personal Information we collect, disclose, or sell, we must verify your request. We reserve the right to confirm your California residency to process your requests and will need to verify your identity to process your requests. from unauthorized access and use, we use security measures, including cybersecurity measures, that comply with federal law.
Please contact us at (844) 340-1898 if you have any questions or concerns about our privacy policies.