California Privacy Notice
Last Updated: March 2021
For residents of California: If you are a resident of California, this notice applies to you and supplements the Advisor360° Privacy Notice. This notice is intended to provide certain information to you as required by the California Consumer Privacy Act of 2018 (“CCPA”).
This notice applies to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household such as your real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers (“personal information”). Personal information as used in this notice does not include de-identified, aggregated, or anonymized information, publicly-available information, and certain other information that is regulated by other applicable laws.
We do not sell personal information and do not discriminate in response to privacy rights requests.
Information we collect
We have collected the following categories of personal information from consumers in the last twelve (12) months:
|Categories of Personal Information We Collect||Examples|
|Identifiers||Name, address, email address, telephone number, Social Security number, signature, driver’s license or state identification card number, and passport number|
|Financial Information||Net worth, assets, account balances, and income|
|Protected Class Information||Age, sex, gender, national origin, citizenship, race, ethnicity, marital status, disability status|
|Commercial Information||Transactions and credit relationship information, trading history, and payment history|
|Internet or Similar Network Activity||Browsing history, search history, clickstream data, session information, navigation paths, and other information about how you interact with our websites and mobile applications|
|Geolocation Data||Physical location, IP address|
|Sensory Data||Audio and video recordings, fingerprints|
|Professional- or Employment-Related Information||Professional and employment status and history|
|Education Information||Educational records, such as grades, transcripts, and student financial information, or student disciplinary information|
|Inferences||Profiles based on preferences, characteristics, attitudes, intelligence, and behavior|
We collect information from the following sources:
Our sources of personal information are detailed in the “What information we collect” section in our main Privacy Notice. In general, our sources include the following:
- Information you provide to your broker-dealer, investment advisor, or other financial institution (“investment professional”) on applications and related forms, through conversations with your advisor or customer service staff, or on our website
- Information from third-party data services or feeds from other financial institutions regarding your transaction history
- Information from you when you interact with us or with our website
- Other sources with your consent or the consent of your investment professional
Our business purposes for collecting this information:
Our business purposes for collecting personal information are detailed in the “How we use information” section in our main Privacy Notice. In general, we collect personal information from you for the following purposes:
- To provide our services to you or your investment professional
- To respond to requests and communicate with you
- To provide our website and services
- To send you updates about our company
- To inform you about our products and services, and to gather feedback from you
Third parties we share this information with:
We share personal information with third parties as detailed in the “How we share information” section in our main Privacy Notice. In general, we share personal information with:
- You or your investment professional to maintain and service your account, process transactions, and fulfill legal requirements
- Our contracted service providers (for example, printing and mailing companies, financial institutions, our technology vendors and hosting providers, and other entities that provide services to us)
- Our auditors, consultants, accountants, attorneys, and others providing professional advice to us
- Government agencies, regulators, law enforcement officials, and third parties in the event of a sale or merger of our company
- Other parties with your consent or at your direction, or as permitted or required by law
Right to know
You have the right to request that we disclose certain information to you about our collection of your personal information. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:
- The categories of personal information we have collected about you
- The categories of sources from which we have collected your personal information
- Our business or commercial purpose(s) for collecting your personal information
- The categories of third parties with whom we have shared your personal information
- The specific pieces of personal information we have collected about you
You have the right to request that we disclose certain information to you about our disclosures of your personal information. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:
- The categories of personal information we have collected from you
- The categories of personal information that we disclosed about you for a business purpose
Right to delete
You have the right at any time to request that we delete your personal information; however, in some cases, we cannot delete all or some of your personal information as required or permitted by applicable laws, or other applicable exemptions.
Right to non-discrimination
We will not discriminate against you for exercising your rights under the CCPA, such as denying you products and services, charging you different rates or prices including use of discounts or penalties, or suggesting or providing a different level of service or quality of products to you. We may, however, charge a different price or provide a different level or quality of products and services only if the price or difference is directly related to the value provided to you by your personal information. Whenever we do so, we will provide additional information to you. We may offer you financial incentives, including payments to you as compensation, for collecting, selling, or deleting your personal information. We also may offer a different price, rate, level, or quality of goods or services to the consumer if that price or difference is directly related to the value provided to you by your personal information.
If you have a direct relationship with Advisor360°:
To submit a request to exercise any of your rights provided in this notice, please email us at email@example.com, or submit your request by phone by calling us at 877.360.3601. If you use the email option, please include “CCPA Request” in the subject line of your email. We will evaluate the request and take action where required to do so.
Depending on the nature of your request, we may have to verify your identity when you contact us. We may do this by asking you to confirm information that we already have about you.
We will confirm receipt of your request within 10 business days and will provide information about how we will process your request. We endeavor to respond to your request as soon as we can. If we are not able to respond to your request within 45 days, we will let you know that we may require additional time (up to 90 total days).
You may also use an authorized agent to exercise your rights on your behalf. If you wish to use an authorized agent, we may 1) require that your authorized agent provides proof to us that you gave the agent signed permission to submit the request on your behalf (and we may also require your authorized agent to verify his or her own identity); 2) require you to verify your own identity directly with us; and 3) require that you directly confirm with us that you provided the authorized agent with permission to submit the request. To appoint an authorized agent, please contact us at firstname.lastname@example.org, or submit your request by phone by calling us at 877.360.3601
If you use Advisor360° through your investment professional:
If your use of our software is pursuant to your direct relationship with your investment professional, please contact your investment professional to exercise any rights you may have under the CCPA, where applicable.