What information do we collect about you?
We collect limited types of personal information through the Website. The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this Website over the last twelve (12) months include the following:
|A. Identifiers||Name, contact details, account name, social security number, driver’s license number, passport number and address (including physical address, email address and Internet Protocol address) or similar identifiers||YES|
|B. Other Customer Records||Telephone number and personal information provided in connection with obtaining account access||NO|
|C. Protected classification characteristics under California or federal law||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO|
|D. Commercial information||Account data, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||NO|
|E. Biometric information||Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information;||NO|
|F. Internet or other similar network activity||Information regarding your use of our Website (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries||YES|
|G. Geolocation data||Physical location or movements.||YES|
|H. Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information||Current or past job history or performance evaluations.||YES|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
We do not collect or use sensitive personal information other than:
- To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services.
- As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information.
- As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions.
- As reasonably necessary and proportionate to ensure the physical safety of natural persons.
- For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us).
- To perform services on behalf of the our business.
- To verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, or to improve, upgrade, or enhance such service or device.
How do we obtain your personal information?
In connection with forming and operating our Website, we collect and maintain your nonpublic personal information from the following sources:
- Information from your communications with us in connection with this Website, including any update notices provided by you.
- Information captured on our Website, including registration information, information provided through online forms and any information captured via cookies.
We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.
How do we use your personal information?
We will use your personal information for one or more of the following business purposes:
- To perform services for you.
- To create, maintain, customize, and secure your account with us.
- To provide, support, personalize, develop and improve our Website and the products and services that we offer and notify you about changes to our products and services.
- To provide you with support and to communicate with you, including responding to requests for information submitted by you through our Website.
- To provide advertising and marketing services.
- To keep a record of your relationship with us.
- Ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
- To audit and verify the quality and effectiveness of our services and compliance.
- To maintain the safety, security and integrity of our Website, products and services, databases, technology assets and business, including to detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
- As needed to comply with U.S., state, local and non-U.S. laws, rules and regulations, including responding to law enforcement requests and as required by applicable law, court order or government regulations.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
Additionally, we may use your personal information to keep you informed of our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested. You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails.
We retain the categories of personal information set forth above in “What information do we collect about you?” only as long as is reasonably necessary for those purposes set forth above in “How do we use your personal information?”, except as may be required under applicable law, court order or government regulations.
Who do we disclose your personal information to?
We do not share (i.e., disclose for the purposes of cross-context behavioral advertising) or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties. In the preceding twelve (12) months, we have not sold or shared any of the personal information we collect about you to third parties.
We do not disclose any nonpublic personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers. Within the last twelve (12) months, we have disclosed personal information collected in connection with this Website for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.
|Personal Information Category||Category of Third-Party Recipients|
|A. Identifiers||Our affiliates, vendors, broker-dealers, advisors, lenders, banks, consultants, self-regulatory organizations, service providers, auditors and law firms.|
|B. Other Customer Record||N/A|
|C. Protected classification characteristics under California or federal law||N/A|
|D. Commercial information||N/A|
|E. Biometric information||N/A|
|F. Internet or other similar network activity||Our affiliates, vendors, broker-dealers, advisors, lenders, banks, consultants, self-regulatory organizations, service providers, auditors and law firms.|
|G. Geolocation data||Our affiliates, vendors, broker-dealers, advisors, lenders, banks, consultants, self-regulatory organizations, service providers, auditors and law firms.|
|H. Sensory data||N/A|
|I. Professional or employment-related information|
|J. Non-public education information||N/A|
|K. Inferences drawn from other personal information||N/A|
How do we keep your personal information secure?
We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.
Your rights under the CCPA
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:
- the categories of personal information we collected about you;
- the categories of sources from which the personal information is collected;
- our business or commercial purpose for collecting such personal information;
- the categories of third parties with whom we disclose the personal information;
- the specific pieces of personal information we have collected about you; and
- whether we disclosed your personal information to a third party, and, if so, the categories of personal information that each recipient obtained.
Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.
For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.
Call us using the following toll-free number (212) 970-9850 or email us through the Online Form.
Within 10 business days, we will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.