DATE APPROVED: June 26, 2017
1. USER GENERATED CONTENT
What information do we collect?
- Information relevant to your computer or mobile device, such as the type of device you from which are logging in, the server from which you login, the IP address from which you log-in, and other types of anonymous information when you visit the Website and become a Client.
- Personal and financial information provided or accessed when you register and become a client.
Why do we collect it?
- We are not only a technology provider, but also a registered investment advisor for our clients. We are required by law to collect and maintain certain information pursuant to U.S. law.
- We collect your personal information to maintain your Website account, and to provide and enhance our customer service service and experience.
- To improve your experience, we aggregate your personal information and perform certain analysis and reporting. This analysis could include identifying trends including those of tribal identities and investment for both internal and external purposes. When we aggregate this information, we ensure that the information is not identifiable to any single client.
Anonymized- to make anonymous. In other words, no one can figure out who you are with the information provided.
Aggregated- combining several elements to form a whole. Basically, we combine all of the content to form a whole bunch of data that cannot be traced back to any single individual.
Using your data:
- We use your data to operate and maintain your account in conformance with with US law and regulations;
- We perform analytics and investigate and understand how the Website is used;
- We use your data to monitor and protect the security and integrity of the Website;
- We use the analytics performed on the Website to better serve you and to market products and service;
- If required by law, such as a court order, subpoenas, or summons, we may disclose personal information;
- We will use User Information and Content to provide you with information and services, to customize your experience on the Website and to inform you about other products and services; and
- We also aggregate and use User Information and Content, without any identifying information, to understand how our products and services are used, to deliver our products and services and to help us develop and innovate.
- We do not sell, rent, or trade your personal information with any third- parties unless required by law;
- We may share your personal information with identification verification services, e-signature providers and account aggregation services, all to serve you as a customer;
- We may use third parties service providers to perform analytics and marketing services on your behalf; and
- If this is the case, we may disclose some personal information, aggregated and anonymized.
All of these above-referenced firms have entered into agreements that require that third parties to keep this personal information anonymized and confidential.
What if we close or are sold?
Information about our users, including personal information, may be disclosed or transferred to entities now or in the future affiliated with us or as part of any merger, acquisition, change of control, debt financing, insolvency, bankruptcy or sale of our assets. Such information may be used in the businesses of any entity so receiving it. We may disclose personal information in specific other cases with your consent.
We reserve the right to use analytics services, such as Google Analytics, to collect information about the usage of this Website. This analytics service collects information relevant to your computer, such as what type of device you are logging in from, the server from which you login, the IP address from which you log-in, and other types of anonymous information when you visit the Website and become a client. We only use the information we get from these analytics services to improve this Website and the services we provide to you through the Website.
You can prevent analytics from recognizing you on return visits to this Website by disabling cookies on your browser. You can opt out of analytics by installing the Google Analytics Opt-out Browser Add-on or similar opt-out functionality.
2. HOW YOU ACCEPT THIS POLICY
3. CHANGES TO YOUR PERSONALLY IDENTIFIABLE INFORMATION
Once you have registered with the Website, you can access your profile, review the information that is stored and revise some of that information. If you have problems, you can always contact firstname.lastname@example.org. Due to U.S. regulatory requirements, we do not delete residual copies of outdated information and must preserve all consumer data for a minimum of three (3) years.
If you wish to access or change the personal information that you have submitted to us or to request the correction of any inaccurate information you have submitted to us, you may correct certain information via the Website. Alternatively as a Website account holder, to request any corrections to your personal information, you can send an email that includes your contact information to email@example.com
4. DELETING YOUR INFORMATION
We believe that your data belongs to you, and therefore, you may request deletion of your personal information at any time that you choose. To request that your account be deleted, please contact us at firstname.lastname@example.org. We will remove your information as soon as reasonably practical, however we may retain and archive such account information as required by applicable laws or regulations. Despite such removal, portions of your data may remain on our production and backup servers indefinitely.
5. AS A VISITOR
We collect various types of anonymous information about visitors to the Website, such as device-related information (browser type, IP address) and server log information (date and time you visited). We collect information that you input into our website and use this information to better understand our visitors and business, all to bolster the Website Service.
7. EMAIL OPT OUT
Our Website complies with the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (CAN-SPAM). We may provide users with periodic website related notifications, marketing offers, or other information via email. You may elect to stop receiving such messages at your discretion by updating your account preferences on the website or through your Website account. You may also follow the unsubscribe instructions included in each promotional email. Please note that certain email messages we send users are necessary for the proper functioning and use of services available through our website, and users who participate in such services do not have the ability to opt-out of such email messages.
8. CHILDREN'S ONLINE POLICY
The features, services, and other aspects of the Website requiring the submission of personally identifiable information are not intended for anyone under 18 years of age. We do not knowingly collect personally identifiable information from children under the age of 13 without parental consent. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personally identifiable information to us please contact us at email@example.com
9. SOCIAL MEDIA
10. QUESTIONS AND CONCERNS
For more general information regarding privacy you can visit the Federal Trade Commission which offers an overview of privacy protection.