We respect your concerns about privacy. This Online Privacy Notice applies to personal information we may obtain on this website and related websites where this Online Privacy Notice is posted (collectively, the “Sites”).
This Online Privacy Notice describes the types of personal information we may obtain through the Sites, how we may use the information, with whom we may share the information and the choices you may have regarding our use of the information. We also describe the measures we take to safeguard the information and tell you how to contact us about our privacy practices.
Information We Obtain
We may obtain certain personal information when you choose to provide it through our Sites. The types of personal information we may obtain include:
- contact information, such as your name, postal address, email address and telephone number;
- username and password;
- account number;
- financial goals;
- capital contributions;
- source of funds; and
- other personal information or content you provide on our Sites.
In addition, when you visit our Sites, we may obtain certain information by automated means, such as cookies. The information we obtain in this manner includes IP address, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our Sites, and dates and times of website visits. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Through these automated collection methods, we obtain “clickstream data,” which is a log of content on which a visitor clicks while browsing a website. As the visitor clicks through the website, a record of the action may be collected and stored. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Sites.
How We Use the Information We Obtain
We may use the information we obtain through the Sites to:
- create and manage your account;
- offer and provide products and services to you;
- display content on our Sites;
- respond to and communicate with you about your requests, questions and comments;
- process claims we receive in connection with our products and services;
- operate, evaluate and improve our business (including developing new products and services; managing our communications; determining the effectiveness of our sales, marketing and advertising; analyzing and enhancing our products, services and Sites; and performing accounting, auditing, billing, reconciliation and collection activities);
- perform data analyses and other processing (including market and consumer research, trend analysis, financial analysis, anonymization, encryption and tokenization of personal information);
- protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
- comply with and enforce applicable legal requirements, relevant industry standards and our policies.
In addition, we may use information collected online through cookies and other automated means for purposes such as (i) customizing our users’ visits to our Sites, (ii) managing our business, and (iii) recording users’ website preferences. We also may use this information to help diagnose technical and service problems, administer our Sites, and identify users of our Sites. We use clickstream data to determine how much time users spend on web pages of our Sites, how users navigate through our Sites, and how we may tailor our Sites to better meet the needs of our users.
We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
We may use third-party web analytics services on our Sites, such as those of Google Analytics. The analytics providers that administer these services use technologies such as cookies and web server logs to help us analyze how visitors use the Sites. The information collected through these means (including IP address) is disclosed to these analytics providers, who use the information to evaluate use of the Sites. To learn more about Google Analytics and how to opt out, please visit www.google.com/analytics/learn/privacy.html. We may combine information we collect from you with information we receive from third parties and use it for the purposes described in this Privacy Notice. We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
Our Sites are not designed to respond to “do not track” signals received from browsers.
Information We Share
We do not sell or otherwise share personal information about you, except as described in this Online Privacy Notice. We may share personal information with third parties who perform services on our behalf. These third parties are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. We may also share the personal information we obtain with our affiliates, subsidiaries and strategic partners.
We also may disclose information about you (i) if we are required to do so by law, regulation or legal process (such as a court order or subpoena), (ii) in response to requests by government agencies, such as law enforcement authorities, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).
We offer you certain choices about how we communicate with you and what information we collect from you. To update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as indicated in the How to Contact Us section of this Online Privacy Notice.
Links to Other Websites
Our Sites may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with us. Linked websites may have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of any websites that are not affiliated with us, any use of those websites, or the privacy practices of those websites.
How We Protect Personal Information
We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Updates to Our Online Privacy Notice
This Online Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our Sites to notify you of any significant changes to our Online Privacy Notice and indicate at the top of the notice when it was most recently updated.
How to Contact Us
If you have any questions about this Online Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us by e-mail at email@example.com or post at:
Attn: General Counsel
777 Third Avenue, 28th Floor
New York, NY 10017