We understand that protecting the privacy and security of the personal information we obtain about our customers is an important responsibility. We want you to know what information we collect, and how we use and safeguard that information.
We collect certain non-public information about you ("Customer Information"). The essential purpose for collecting Customer Information is to allow us to provide advisory services to you. Customer Information we collect may include:
We restrict access to your non-public personal information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your non-public personal information.
We do not disclose the non-public personal information we collect about our customers to anyone except: (i) to persons necessary to effect transactions and provide the authorized services (such as broker-dealers, custodians, independent managers etc.); (ii) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, consultants, etc.); (iii) our attorneys, accountants, and auditors; or (iv) as otherwise provided by law. We have retained the services of a third-party account aggregation service provider (“Aggregator”) to provide us information about client accounts that have been linked through our platform. Aggregator collects Customer Information from third party data sources in connection with the operation of our advisory services. If you link accounts through our platform by inputting your login credentials, Aggregator can (a) use your account information, account access information, and registration information internally to provide and improve Aggregator’s services (but not directly for the benefit of any third party); (b) to the extent permitted by law, use, sell, license, distribute and disclose Customer Information and usage information that has been stripped of all personally identifiable information ("Anonymized Data"); and (c) to perform fraud screening, verify identities, and verify the information contained in your accounts for use across the Aggregator network. Aggregator will not disclose your Customer Information to any third-party other than as Anonymized Data, or use your Customer Information to directly solicit you or other customers.
We have partnered with The Financial Innovations Center, Inc., d/b/a Center for Financial Services Innovation (“CFSI”). CFSI is a non-profit organization founded to support innovation in the financial services industry. We share Anonymized Data with CFSI to allow them to analyze and potentially publish statistics about the impact of their investments on Americans’ financial health. You may opt out of providing your Anonymized Data to CFSI by sending an email to email@example.com.
We are permitted by law to disclose the non-public personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on our behalf or for joint marketing programs). These third parties are prohibited to use or share the information for any other purpose.
If you decide to close your account(s) or become an inactive customer, we will adhere to our privacy policies, which may be amended from time to time.
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