Effective: October 1, 2019
Notice Last Updated: November 1, 2021
Please read this Policy carefully. The practices described herein are subject to the laws in the places in which we operate.
BY ACCESSING AND/OR USING OUR SITES, SERVICES, AND/OR BY COMMUNICATING WITH US IN ANY MANNER, YOU REPRESENT THAT YOU HAVE READ AND UNDERSTOOD THIS POLICY.
Depending upon how you interact with our Sites, Services, the nature of your Communications, and our interactions with Third Parties, we may collect the following categories of information from and about you:
· Direct identifiers, including but not limited to your name, alias, social media handle, unique online identifier, IP address, username and password, postal and/or e-mail address, account name and/or account number.
· Indirect identifiers, such as your photograph, and links to your profile on other social media sites or company website biographies.
· Physical characteristics, such as your age, marital status, sex, veteran or military status.
· Commercial information, including records of products or services purchased, obtained, or considered, location of investment interest, or other purchasing and consuming histories and tendencies.
· Internet or other electronic network activity information, including your interactivity with our Sites, Services, Communications, and advertisements, including browser type and version, browser settings, operating systems and platform, device type, operating information, mobile carrier, and page response time and download errors.
· Professional or employment-related information, such as your current or past job history.
· Inferences drawn from other information, such as profiles created about you that reflect on your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and/or aptitude.
We collect your information in three ways:
Directly from you when you access or use our Sites, Services, and during your Communications, including but not limited to:
· Information you provide when you sign up for our Services, including your name, email address, company name, password, profile information (such as photograph, personal biography, list of interests, phone number, physical address, email address, links to your profiles on other social media);
· Information you provide when you use our Services, fill out forms, post or comment through the Services, upload or submit any material through the Services;
· Information you provide when you Communicate with us.
· Information you provide when you report a problem with our Sites; and
· Your responses to surveys that we might ask you to complete.
Automatically when you access or use our Sites and Services, or through our Communications, including but not limited to:
· Details of your visits to the Sites, including traffic data, location data, logs and other communication data;
· Information about your computer and mobile device, and internet connection, including your IP address, operating system, and browser type; and
· Interactivity with an e-mail, including opening, navigating, and click-through information.
From Third Parties, including but not limited to:
· Technical service providers, including those relating to payment partners, website hosting, marketing, website usage analytics, advertising, and monitoring and maintaining the Services.
· Confirmation partners to confirm certain information you have provided when you use the Services. For example, Level 3 and Level 4 may require users to submit information regarding financial status and net worth, and we may ask a confirmation partner to confirm, to the extent possible, the information you have provided.
· Real estate and property ownership data providers, including those that deliver comprehensive real estate and property ownership information. This information is typically collected from publicly available sources, such as county property and tax records. However, it may also be drawn from multiple listing services (MLS), which may also be used to identify properties that can be purchased as deep discounts as part of the PinPoint Profits (PiN) program offered by Connected Investors.
· Publicly available sources, such as county property and tax record databases.
· Social media networks for the purpose of collecting certain of your social media profile information and activity, including your screen names, profile picture, contact information, contact list, and the profile pictures of your contacts, through the social media platform; and
· Advertising partners for the purpose of tailoring our advertising and marketing to you.
We use the information outlined in What Type of Information Do We Collect About You for a variety of business and commercial purposes, including but not limited to:
· Provide the Sites and Services to you;
· Create and manage your account and online profile;
· Operate the Sites and Services, including access management, payment processing, administration, internal operations, troubleshooting, data analysis, testing, research, and statistical analysis;
· Respond to your requests, feedback, or inquiries;
· Comply with laws, regulations, and other legal requirements;
· Comply with relevant industry standards and our policies;
· Protect and enforce your rights and the rights of other users against unlawful
· activity, including identity theft and fraud;
· Protect the rights arising under any agreements entered into between Connected Investors and you or any other Third Party;
· Protect the integrity and maintain security of our Sites and Services;
· Operate, evaluate, and improve our business;
· Provide you with information and advertisements about products, services, and promotions, from us or third parties, that may interest you;
· Present content in a manner that is optimized for your device; and
· Measure and analyze the effectiveness of the Sites and Services.
We may disclose or share the information referenced in What Type of Information Do We Collect About You with Third Parties for a variety of business and commercial purposes, including:
· In a business transfer. We may disclose or share your information as part of a corporate business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets, or in the unlikely event of insolvency, bankruptcy, or receivership, in which such information could be transferred to Third Parties as a business asset in the transaction.
· To non-affiliated Third Parties. We may disclose or share your information with certain Third Parties to facilitate your access and use of our Sites and Services, including but not limited to internet service providers, advertising networks, data analytics providers, governmental entities, operating systems and platforms, social medial networks, and service providers who provide us a service (e.g., credit / debit card processing, billing, shipping, repair, customer service, auditing, marketing, debugging to identify and repair errors that impair existing intended functionality on our Sites or Services, and/or protecting against malicious, deceptive, fraudulent, or illegal activity).
· To subsidiaries and affiliates. We may disclose or share your information with our subsidiaries and affiliates to further facilitate your use of our Sites and Services, and to ensure the smooth and consistent operations of Connected Advisors by identifying and repairing errors that impede intended functionality and to protect against malicious, deceptive, fraudulent, or illegal activity.
· For legal process and protection. We may disclose or share your information to satisfy any law, regulation, legal process, governmental request, or where we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to:
o Enforce or apply agreements, or initiate, render, bill, and collect for Services rendered;
o Protect our rights or interests, property or safety or that of others;
o In connection with claims, disputes, or litigation – in court or elsewhere;
o Protect users of our Sites and Services, and other carriers or providers from fraudulent, abusive, or unlawful use of, or subscription to, such services;
o Facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government; or
LINKS TO THIRD PARTY SITES
Our Sites and Services may contain links to Third Party websites and services. Please note that these links are provided for your convenience and information, and the websites and services may operate independently from us and have their own privacy policies or notices, which we strongly suggest you review. This Privacy Notice applies to our Sites and Services only, and we do not accept any responsibility or liability for the policies or practices of any Third Parties.
THIRD PARTY TRACKING / DO NOT TRACK
Our Sites may, from time to time, collect information about your online activities, over time and across our different Sites. When you use our Sites, Third Parties may also collect information about your online activities, over time and across different internet websites, online or cloud computing services, online applications, or mobile applications. Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Our Sites do not currently change the way they operate based upon detection of a “Do Not Track” or similar signal.
SOCIAL MEDIA INTEGRATION
Our Sites may, from time to time, contain links to and from social media platforms. You may choose to connect to us through a social media platform, such as Facebook or Twitter. When you do, we may collect additional information from or about you, such as your screen names, profile picture, contact information, contact list, and the profile pictures of your contacts, through the social media platform. Please be advised that social media platforms may also collect information from you. We do not have control over the collection, use and sharing practices of social media platforms. We therefore encourage you to review their usage and disclosure policies and practices, including their data security practices, before using the social media platforms.
HOW DO WE STORE AND PROTECT YOUR INFORMATION?
Although no system can guarantee the complete security of your information, we take all commercially reasonable steps to ensure your information is protected in alignment with all applicable laws and regulations, as appropriate to the sensitivity of your information.
We keep your information for as long as necessary in accordance with the purpose for which it was collected, our business needs, and our legal and regulatory obligations. If we dispose of your information, we will do so in a way that is secure and appropriate to nature of the information subject to disposal.
We may use browser cookies, beacons, pixel tags, scripts, and other similar technologies from time to time to support the functionality of our Sites and Services.
A cookie is a piece of information contained in a very small text file that is stored in your Internet browser or elsewhere on your hard drive. Cookies are transferred from our Sites to your computer, phone or tablet, and allow us to identify your device whenever you return to our Sites. These technologies provide a better experience when you use our Sites, and allow us to improve our services. We may also use analytic software, such as Google Analytics and others, to help better understand how our Sites function on your device(s) and for other analytical purposes. To learn more about how Google uses data when you use our Sites, see How Google uses data when you use our partners’ sites or apps. You can opt-out of Google Analytics by installing Google’s opt-out browser add-on here https://tools.google.com/dlpage/gaoptout.
Below is an overview of the types of cookies and related technology we deploy, and your choices.
Beacons. Our Websites and e-mails may contain small electronic files known as beacons (also referred to as web beacons, clear GIFs, pixel tags and single-pixel GIFs) that permit us to, for example, to count users who have visited those pages or opened an e-mail and for other website-related statistics. Beacons in e-mail marketing campaigns allow us to track your responses and your interests in our content, offerings and web pages. You may use the tools in your device to disable these technologies as well.
We provide you the ability to exercise certain controls and choices regarding our collection, use, storage, and sharing of your information. Please note that for some of these rights, such as the Right to Know and Right to Delete, we will verify your identity before we respond to your request. To verify your identity, we will generally match the identifying information provided in your request with the information we have on file about you. Depending on the sensitivity of the personal information requested to be deleted, we may also utilize more stringent verification methods to verify your identity, including but not limited to requesting additional information from you and/or requiring you to sign a declaration under penalty of perjury.
· Right of Correction. Regardless of where you live, you may submit a request that we correct or update the information we have about you. To submit this request, please Contact Us.
· Right to Know. If you are a California resident, you have a right to ask that we disclose to you the categories and specific pieces of personal information we have collected about you in the 12 months preceding the date of your request, including a description of the categories of sources from which we have collected that information, the business or commercial purpose for collecting or sharing that information, and the categories of third parties with whom we have shared that information. To submit such a request, click https://connectedinvestors.com/consumer-protection, call us at 888-204-7501 ext. 144 (CCPA Support), email us at email@example.com, or chat with us via the Site.
· Right to Delete. If you are a California resident, you have a right to ask that delete your personal information, subject to appropriate exceptions. To submit this request, you may click https://connectedinvestors.com/consumer-protection, call us at 888-204-7501 ext. 144 (CCPA Support), email us at firstname.lastname@example.org, or chat with us via the Site.
· Right to Opt-Out of the Sale of Information. If you are a California resident, you have a right to opt-out of the “sale” of your information. Although we do not “sell” your information in the traditional sense, the definition of “sale” is so broad under California law that some transfers of your information to third parties may be considered a “sale.” To exercise this right, you may access our “Do Not Sell My Personal Information” page at https://connectedinvestors.com/content/do-not-sell. You may also submit a request at email@example.com.
· Right to Change Preferences. Regardless of where you live, you may change your choices for subscriptions, newsletters, and alerts. To submit this request, you may email us at firstname.lastname@example.org.
· Right to Opt-Out of Our Communications. Regardless of where you live, you may choose whether you want to receive offers and promotions from us. To submit this request, you may email us at email@example.com.
· Right to Control Advertising and Online Tracking. Regardless of where you live, you have a right to control how your information is tracked online. To learn more about these rights, see Cookies and Related Technologies.
Right of Non-Discrimination. You have a right to exercise your rights under this section free of discrimination. We will not discriminate against you in any way if you choose to exercise your rights under this section.
YOUR CALIFORNIA RIGHTS
California Consumer Privacy Act (CCPA). All terms and phrases used hereunder shall have the same meaning as those terms are defined under the California Consumer Privacy Act of 2018 and related regulations (“CCPA”).
· Rights. Under the California Consumer Privacy Act of 2018 and its implementing regulations, you have a Right to Know, Right to Delete, and Right to Non-Discrimination. To learn more about these rights, see Your Choices.
· Notice of Sale. To learn more about the categories of personal information we may have “sold” about California residents over the last 12 months, see What Information Do We Collect About You. To learn about the categories of third parties with whom we have sold that information, please see. We have no actual knowledge of selling the personal information of minors under the age of 16.
· Notice of Collection. To learn more about the categories of personal information we have collected about California residents over the last 12 months, see What Information Do We Collect About You. To learn about the sources from which we have collected that information, the business and commercial purpose for its collection, and the categories of third parties with whom we have shared that information, please see How Do We Collect Your Information, How Do We Use Your Information, and How Do We Share Your Information.
· Notice of Disclosure. To learn more about the categories of personal information we have disclosed for a business purpose about California residents over the last 12 months, including the categories of third parties with whom we have shared that information, please see How Do We Share Your Information.
California Minors. If you are a California resident under the age of 18, California Business and Professions Code § 22581 permits you to request and obtain removal of content or information you have publicly posted on any of our Applications or Websites. To make such a request, please send an email with a detailed description of the specific content or information to firstname.lastname@example.org. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and there may be circumstances in which the law does not require or allow removal even if requested.
Shine the Light. If you are a California resident, you are permitted to request information regarding the disclosure of your information to Third Parties for their direct marketing purposes. To make such a request, please send an email to email@example.com or otherwise Contact Us.
Our Sites and Services are not intended for children under the age of 18. This includes any links to other websites that we provide for our convenience. We don’t knowingly collect the information of children for any reason.
Our Sites and Services are hosted and offered in the United States of America (US), and are subject to US federal, state, and local law. If you are accessing the Sites and Services from another country, please be advised that you may be transferring your information to us in the US.
YOUR CONTINUED USE, ACCESS, OR INTERACTION WITH THE SITES, SERVICES, OR YOUR CONTINUED COMMUNICATIONS WITH US AFTER THE UPDATED POLICY HAS BEEN POSTED WILL REPRESENT THAT YOU HAVE READ AND UNDERSTOOD THIS POLICY.
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