We have adopted general policies and procedures concerning confidentiality, proprietary data and privacy of customer personal information, and the information we gather over the Site is protected by those policies and procedures. Generally, we seek to restrict our collection of non-public personal information about our clients and investors to only the following sources:
Our policy is that:
In general, you can browse the non-password-protected sections of the Site without telling us who you are or revealing any personal information about yourself. We automatically track certain information that your browser makes available whenever you visit a website. This information includes your Internet Protocol address, browser type, browser language and one or more files that may uniquely identify your browser. We may use this information to do internal research on our users' demographics, interests and behavior to better understand, protect and serve you and our clients. This information may include the URL from which you just came (whether this URL is on the Site or not), to which URL you next go (whether this URL is on the Site or not), your computer browser information and your IP address. We use this information to operate, develop and improve our services.
If you apply for a password to access password-restricted areas on this Site, you must provide to us your name, mailing address, email address, phone number, personal financial data, investment portfolio and other investment information.
We share the information you provide to us to apply for a password with us, or Northern Trust (the "Administrator), which administers the Site and provides certain other services to us. Sharing this information is necessary to administer the Site. Our contract with the Administrator requires, among other things, that it will not disclose or use your personal information other than to perform these services for us. We may use your information to send correspondence and perform services on your behalf in connection with investment-related activities.
You agree that we may use personal information about you to analyze Site usage, improve our content and product offerings and customize the Site's content, layout, and services. These uses improve the Site and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Site.
We may also share information about you if we believe that disclosure is required under law. For example, we may need to disclose information in response to a subpoena or to cooperate with regulatory or law enforcement authorities.
You are responsible for all actions taken with your user name and password. Therefore, we recommend that you do not disclose your password to any third parties. You may not allow others to use your user name or password to access or use any part of this Site. If your password has been compromised for any reason, you should contact us immediately for a new password.
You can review and change the information you submit to us by contacting us or the Administrator. You can change your User ID, email address, contact information, financial information, other personal information and user preferences. You must promptly update your personal information if it changes or is inaccurate.
On your request, we will deactivate your password and remove your contact information and financial information from our active databases. To make this request, email email@example.com. Your password will be deactivated promptly based on your account activity and in accordance with our deactivation policy and applicable law.
Your information is stored on our servers located in the United States. We use procedural and technical safeguards to protect your personal information against loss or theft as well as unauthorized access and disclosure to protect your privacy, which may include encryption, "firewalls" and Secure Socket Layers. We treat data as an asset that must be protected against loss and unauthorized access. We employ security techniques to protect such data from unauthorized access by users inside and outside the company. However, "perfect security" does not exist on the Internet.
If you have any additional questions, please feel free to contact us any time at firstname.lastname@example.org.