Last Modified: 10/28/2019
Investment advisers are required by law to inform their clients of their policies regarding privacy of client information. We are bound by professional standards of confidentiality that are even more stringent than those required by law.
Federal law gives the customer the right to limit some but not all sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information.
This policy describes the types of personally identifiable information (“PII”) and non-personally identifiable information (“Non-PII”) we may collect from you or that you may provide when you visit our website and our practices for collecting, using, maintaining, protecting, and disclosing that information. PII includes information such as your name, address, phone number, zip code, email address, and similar information. Non-PII is non-personally identifiable information, and may include, for example, your IP address, browser type, domain names, access dates and similar information.
Type of Nonpublic Personal Information We Collect and How We Collect It
We collect nonpublic personal information about you that is either provided to us by you or obtained by us with your authorization. This can include but is not limited to your Social Security Number, Date of Birth, Banking Information, Financial Account Numbers and/or Balances, and Sources of Income. When you are no longer our customer, we may continue to share your information only as described in this notice as required by state and Federal as pertains to record keeping.
Parties to whom we disclose information
We may use information that we collect about you or that you provide to us, including any personal information, for any purpose including but not limited to:
- To provide you with materials you have requested;
- Contact you for the potential purchase of insurance or other financial products;
- Personalize our contact with you;
- Operate, provide, improve, and maintain our website;
- Develop new products and services;
- Prevent abusive and fraudulent use of our website;
- Send you administrative messages, content, and other services and features in which we believe you may be interested; and
- For any other administrative and internal business purposes permitted by law.
Protection of Your Information
We maintain a variety of security measures to protect against the loss, misuse, and alteration of information under our control. Although we make good faith efforts to maintain the security of such information, we cannot guarantee that it will remain free from unauthorized access, use, disclosure, or alteration. Further, we cannot guarantee that our security measures will prevent unauthorized persons from accessing or obtaining this information. We assume no liability to you or any other party in relation to the unauthorized access, use, or alteration of any information provided to us.
Notification in the Event of Data Breach
As previously stated, although we make good faith efforts to maintain the security of your information, we cannot guarantee that it will remain free from unauthorized access, use, disclosure, or alteration. In the event your personally identifiable information is breached by an unauthorized party, we will comply with your applicable state law in notifying you of the breach.
Accessing or Correcting Your Information
You may access the data collected by us about you by sending a request to the address listed below. If you believe that an error has been made in the accuracy of the information collected from you, we will correct such error upon adequate verification of the error and the identity of the person seeking the correction.
1295 East Dunne Avenue, Suite 215, Morgan Hill, CA 95037
Please understand that to protect your privacy and security, we may also need to take reasonable steps to verify your identity before granting access or making corrections.
Sharing Information and Consumer Choice
When you provide information to us, we may share your information, to the extent provided by applicable law, with our affiliated companies and third parties for the purpose of fulfilling your requests as well as offering you other services that may be of interest to you. It is not shared with any third party, unless requested by you or permitted by law. Under no circumstance will we sell your information or transfer your information to any ad network, ad exchange, data broker or other advertising or monetization related service. We may also aggregate statistics that we gather about our customers, sales, traffic patterns, and services and provide these statistics to third parties; however, when we do, these statistics will not include any personal information that identifies individuals.
Cookies are small pieces of data stored by your internet browser on your computer's hard drive. They cannot be used to collect data from your hard drive, obtain your e-mail address or personal identifying information about you. You may set your browser to notify you when you receive a cookie or to prevent cookies from being sent. Please note, however, that by not accepting cookies, you will limit the functionality we can provide you when you visit our site.
Handling of ‘Do Not Track’ Signals
The California Online Privacy Protection Act provides that a website operator must:
“Disclose how the operator responds to Web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer's online activities over time and across third-party Web sites or online services, if the operator engages in that collection.”
It is important for you to know that we do not engage in the type of collection referenced in the California law.
Federal Law gives you the Right to Limit Sharing - Opting Out
Federal law allows you the right to limit the sharing of your NPI by “opting-out” of the following: sharing for non-affiliates’ everyday business purposes – information about your creditworthiness; or sharing with affiliates or non-affiliates who use your information to market to you. State laws and individual companies may give you additional rights to limit sharing. Please notify us immediately if you choose to opt out of these types of sharing.
DEFINITIONS: Affiliates – companies related by common ownership or control. They can be financial and non-financial companies; Non-affiliates – companies not related by common ownership or control. They can be financial and non-financial companies; Joint marketing – a formal agreement between non-affiliated financial companies that together market financial products or services to you.