YOUR PRIVACY IS IMPORTANT TO US
Information We Collect
We collect personal information about you from a variety of sources to help us serve your financial needs, offer products and services, and satisfy our legal and regulatory requirements. Personal information includes information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or device. Personal information does not include information that is lawfully made publicly available from federal, state, or local government records. We collect nonpublic personal information from the following sources:
- Information we receive from you on applications and other forms and through personal discussions with our registered representatives or financial professionals (for example, your name, address, social security number, assets, income, employment, health, and other financial information);
- Information about your accounts and transactions from us, our affiliates, or nonaffiliated third parties such as our clearing firm, mutual fund companies, insurance companies, money managers, and/or your prior brokerage firm (in the case of an account transfer)(for example, your account and transaction history, products purchased and services received, and balances and payment history);,
- Information obtained when verifying the information you provide on an application or other form (this may be obtained from other institutions where you conduct financial transactions or employers); and
- In some cases, we may collect information about your creditworthiness from consumer reporting agencies.
We have procedures to ensure that your information is maintained in a commercially reasonable manner so that it is accurate, current, and complete. Keeping your information secure is one of our most important responsibilities. We restrict access to nonpublic personal information about you to those employees and financial professionals who need to know the information in order to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your non-public personal information. We also have procedures to ensure that requests to correct inaccurate or incomplete information are acted upon in a timely manner. Within the last twelve months we have collected the following types of personal information from consumers and shared certain types of personal information with third parties for a business purpose:
|Category||Types of Personal Information Collected||Sources from which information is collected||Business or commercial purpose for which information is collected||Categories of third parties with whom we share information|
|A. Identifiers||Your real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver's license number, passport number, and other similar identifiers.||Account opening documents, subscription documents, transaction disclosure documents, discussions with financial professionals, employment application, employment interview, authorization for background check||To offer you products and services you request, maintain and service your accounts, process or fulfill orders and transactions, verify customer information, process payments, or provide similar services to you||Our clearing firm, custodians of account assets, third-party investments advisers, mutual funds, insurance companies, plan sponsors, product sponsors, legal counsel, and regulatory agencies|
|B. Personal information described in Section 1798.80(e) of the California Civil Code||Your signature, telephone number, passport number, state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, any other financial information, medical information, and certain health insurance information.|
|C. Protected classification characteristics under California or federal law||Age (40 years or older), race, color, national origin, citizenship, marital status, medical condition, physical or mental disability, sex, pregnancy or childbirth, and related medical conditions), military or veteran status.|
|D. Commercial information||Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Account statements, confirmations, account activities and history||To maintain and service your accounts, process or fulfill orders and transactions, verify customer information, or provide similar services to you|
|E. Biometric information||Fingerprints (applicable to employees, associated persons, and registered representatives only.)||Employment application||Required for all employees and associated persons for security purposes||Regulatory agencies|
|F. Internet or other electronic network activity||Browsing history, search history, and information on a consumer's interaction with a website, application, or advertisement.||When you access our website or send us an email||Supervisory control procedures, data security, and protection of data from unauthorized access||Service providers|
|I. Professional or employment-related information||Job application, resume, employment contract, performance review, photo for identification, information for payroll processing and benefits administration, and contact information||Employment application, employment or independent contractor agreement, payroll and benefits records, interview||To verify employee information and pay and provide benefits to our employees and independent contractors||Professional employer organization, legal counsel, regulatory agencies|
We did not sell any personal information in the preceding twelve months.
Why We Collect Personal Information
All financial companies need to collect and share customers’ personal information to run their everyday business. We use and disclose or share the personal information we collect for one or more of the following operational and business purposes:
- To perform services on behalf of our business, including maintaining and servicing accounts, providing customer service, processing or fulfilling orders and transactions, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of our business.
- To provide you with information, products, or services that you request from us.
- To verify your identity or determine your creditworthiness.
- To provide you with email alerts, event registrations, and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
- For testing, research, analysis, and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our customers, or others.
- To respond to law enforcement requests, court orders, legal investigations, or governmental regulations.
- As described to you when collecting your personal information.
Sharing Personal Information
We disclose personal information to service providers, unaffiliated third parties for business purposes including your credit union pursuant to a Joint Marketing Agreement and to government agencies and regulatory authorities. When we disclose personal information to a service provider or third party for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the services required. We disclose personal information for business purposes to the following categories of third parties:
- Our affiliates,
- Service providers, such as our clearing firm, mutual fund companies, insurance companies, and money managers, and our legal counsel and accountants,
- Governmental agencies and regulatory authorities, and
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you, including your credit union or if your independent representative moves to a new firm we may disclose your personal information to the new firm.
There are laws in some states in which we do business that restrict us from disclosing personal information in one or more of the situations described above without your approval, otherwise known as a right to opt-out or a requirement to opt-in. We follow the state requirements as they may apply to our affected customers. We generally do not sell personal information and did not sell any personal information in the previous twelve months. We do not sell the personal information of minors under 16 years of age without affirmative authorization.
We maintain physical, electronic, and procedural safeguards that comply with federal standards to safeguard your personal information. We protect your account information by placing it on the secure portion of our website. Our servers have been enabled with Secure Sockets Layer (SSL) technology to prevent unauthorized parties from viewing your personal information. In addition, we employ [GeoTrust] digital certificate services to authenticate that you are connecting to our server(s). Access to your personal information is limited to those employees, registered representatives, and agents who may need to know that information to provide products or services to you. They are required to maintain the confidentiality of all customer information.
Consumer Privacy Notice
Regulation S-P promulgated by the U.S. Securities and Exchange Commission:
- Requires a registered broker dealer or investment adviser to provide notice to its customers about its privacy policies and practices;
- Describes the conditions under which a broker dealer or investment adviser may disclose nonpublic personal information about a consumer to nonaffiliated third parties; and
- Provides a method for consumers to prevent a broker dealer or investment adviser from disclosing personal information to most unaffiliated third parties by “opting out” of that disclosure, subject to certain exceptions.
California Consumer Privacy Act
The California Consumer Privacy Act of 2018 (“CCPA”) gives certain individuals (natural persons) who reside in the State of California certain rights to know what personal information we collect about them and how we collect, share, and protect their personal information. This information is set forth in “Information we Collect” and “Sharing Personal Information.” The CCPA also provides individual California residents with a right to opt-out of the sale of personal information, a right to request that a business disclose what personal information it holds about a consumer, and a right to request that a business delete their personal information. Certain individuals are and personal information is excluded from the coverage of the CCPA.
Consumers and Personal Information Excluded from the CCPA
Customer Personal Information. The CCPA does not apply to any personal information we collect or obtain from or about our current and former individual customers who obtain or have obtained a financial product or service from us that is used primarily for personal, family, or household purposes. Employee Personal Information. The CCPA does not apply to personal information that: (a) we collect about a natural person in the course of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of our business to the extent that the natural person’s personal information is collected and used by us solely within the context of the natural person’s role or former role as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or a contractor of our business, (b) we collect that is emergency contact information of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of our business to the extent that the personal information is collected and used solely within the context of having an emergency contact on file, and (c) is necessary for us to retain to administer benefits for another natural person relating to the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of our business to the extent that the personal information is collected and used solely within the context of administering those benefits.
Right to Know About Personal Information Collected, Disclosed, or Sold
If you are a California resident and not an individual customer or employee of CFS/SPF, you have the right to request that we disclose certain information to you about our collection, use, and disclosure or sharing of your personal information. Once we receive and confirm your request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting, sharing, or selling your personal information.
- The categories of third parties with whom we share your personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold your personal information, the categories of personal information sold and the categories of third parties to whom personal information was sold.
- If we disclosed your personal information for a business purpose, the categories of personal information disclosed.
We will not provide you with specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of the personal information, your account with us, or the security of our systems or networks.
Right to Request Deletion
If you are a resident of California and are not an individual customer of employee of CFS/SPF, you have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and verify a consumer request, we will erase your personal information from our records, unless an exception applies, or de-identify or aggregate the personal information. Your right to request that we delete your personal information is not absolute and is subject to a number of exceptions. There are instances where applicable law and regulatory requirements allow or require us to retain personal information. We may deny a deletion request if it is necessary for us or our service providers to maintain your personal information for any of the reasons sets forth in Section 1798.105(d) of the CCPA.
Exercising Your Right to Know or Request Deletion of Your Personal Information
If you are a resident of California and are not an individual customer of employee of CFS/SPF, you may exercise your right to know or request deletion of your personal information by submitting a request to us by either:
- Calling us at the toll-free number (833) 995-1944
- Visiting www.cusonet.com/personal-information-request/
- Emailing us at firstname.lastname@example.org
Only an individual who is not a customer or employee of CFS/SPF (or a person registered with the California Secretary of State that an individual authorizes to act on his or her behalf), may make a request related to his or her personal information. You may only make a request to know what personal information we collect, use, or disclose about you twice within a 12-month period.
How We Verify Requests
We are required to verify that an individual making a request to know or delete personal information is the person about whom we have collected information.
- To verify a request, we may request that you: Provide answers to questions that match personal information about you that we maintain;
- Provide us with sufficient information that allows us to verify that you are the person whose personal information is the subject of the request
- Require that you sign a declaration under penalty of perjury that you are the person whose personal information is the subject of the request;
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We may use a third-party verification service to verify the identity of a consumer making a request to know or delete personal information. We will decline a request to know or delete personal information if we cannot reasonably verify that you are the person (or a person authorized to act for the person) whose personal information is the subject of a request.
Response Timing and Format
We will confirm receipt of a request a request to know or delete personal information within 10 days and provide information about how we will process the request, our verification process, and when you should expect a response. If we cannot respond to a request within 45 days, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Our response will explain the reasons we cannot comply with a request, if applicable. We will not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
A California resident may authorize another person or a business entity registered with the California Secretary of State to act on their behalf to submit a request to know or delete personal information subject to the requirements set forth in Section 999.326 of the California Civil Code.