Effective Date: March 18, 2021
This Privacy Policy is in effect for Trade-PMR, Inc. and its affiliates, including Portfolio Management and Research (collectively TradePMR)
California Consumer Privacy Act of 2018 (CCPA)
Do we sell your information? NO
If you are a California resident, you have the right to opt out of the sale of your personal information. TradePMR does not sell your personal information, therefore, there is no need for you to elect to “opt out.”
Under the CCPA, California residents have the right to opt out of the sale of their personal information. The CCPA defines the term “sale” broadly to include the selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating of your personal information to another business or third party for monetary or other valuable consideration.
TradePMR will only share your information solely for the purpose of delivering you services for which you subscribe or request. If necessary, TradePMR will seek you or your advisor/agent’s affirmative, written permission.
Please see TradePMR’s Privacy Policy below. If you have any questions or concerns, please feel free to contact our Compliance Department at compliance@tradepmr.com.
Privacy Policy
TradePMR is committed to protecting the privacy and confidentially of your Nonpublic Personal Information. In this notice, the words "you" and "customer" are used to mean any individual who obtains or has obtained a financial product or service (Services) from TradePMR as a provider of Services that involve compiling personal and sometimes sensitive information. Protecting the confidentiality of that information continues to be a top priority for TradePMR. Whether you are a current, former, or potential customer, we believe that you should know about the information we collect, the measures we take to safeguard it, and the limited circumstances in which we may share your information.
1. We collect only the customer information necessary to consistently deliver our Services to you. The information we collect and the extent to which we use it will vary depending on the Services for which you subscribe or purchase. TradePMR collects information that helps us serve your financial needs, allowing us to provide a high level of customer service; develop and offer new Services for our customers and potential customers; and allowing us to fulfill any legal and/or regulatory requirements imposed on us. The information collected generally varies depending on the Services you subscribe to or purchase and may include, but are not limited to:
- Information provided on applications and related forms (i.e., your name, date of birth, home address, Social Security Number, account number, annual income and other Nonpublic Personal Information).
- Information obtained from other associations regarding any Service we may provide to you. (i.e., your name, date of birth, home address, Social Security Number, and other Nonpublic Personal Information).
- Third-party reports, such as consumer credit history, motor vehicle records, demographic and/or medical information, if relevant to your Service.
- Information about your relationship with us, such as Services purchased, and/or account numbers, transaction information and balances.
2. We maintain safeguards to protect your privacy and information security. We have implemented security standards and processes including physical, electronic and procedural safeguards. We limit access to customer information to employees and your Advisor or agent, and their successors and assigns, who may need it in order to fulfill their obligation to you for the Services for which you have subscribed or purchased, or to comply with federal or state laws, statutes or regulations. Employees of TradePMR are trained to respect the confidentiality of your personal information and understand their duty to safeguard it.
3. We restrict the sharing of customer information for use in marketing. First and foremost, we do not sell or share customer information with outside parties who want to market their products or services to you. We may disclose your Nonpublic Personal Information to companies with which we share common ownership and with third-party institutions with which we have joint marketing agreements. We have confidentiality agreements in place with such third-party institutions.
As a provider of a wide variety of Services, we may identify opportunities to enhance customer service or to offer you additional Services offered by TradePMR. However, we will not share information about you with others that could be used to make insurance underwriting or lending decisions about you, unless you direct us to or unless we notify you first and give you a chance to opt-out. In addition, we will not use certain Nonpublic Personal Information (such as income, account history or credit history) received from any affiliate in order to market its products or services to you unless you direct us to, or unless we notify you first and give you a chance to opt-out. Similarly, we will not share Nonpublic Personal Information with third-party financial services entities, such as banks, credit unions, credit union service corporations, insurance companies, or securities broker/ dealers, for purposes of joint marketing unless you direct us to, or unless we notify you first and give you a chance to opt-out.
4. We share customer information as necessary for business, regulatory, and servicing purposes. We will share customer information to facilitate or service a transaction you have requested, but only in accordance with all applicable federal and/or state laws. For example:
- In some cases, your information (i.e., your name, home address, date of birth, Social Security Number, account number and other Nonpublic Personal Information) may be provided to other affiliates of Trade-PMR or to our clearing firm to process or service a transaction you have requested or to facilitate enhanced customer service.
- We may share or exchange information with companies engaged to work with us, such as our clearing firm, third-party administrators and vendors hired to effect, administer or enforce a transaction or service that you request or authorize; to develop or maintain software; to perform marketing research; or to provide us with demographic information to develop marketing plans. We require these companies to maintain the confidentiality of customer information and use it only for the purpose for which it was provided.
- We may provide information to reputable consumer reporting agencies in connection with your application or renewal of any Services subscribed or purchased.
- We may also share customer information in compliance with any federal or state law, statute or regulation (i.e., in response to a subpoena, to prevent fraud, and to comply with rules of, or inquiries from industry regulators or law enforcement).
- In some cases, your information (i.e., your name, date of birth, home address, Social Security Number, account number(s), annual income, Services purchased, transaction information, account balances, and/or other Nonpublic Personal Information) may be provided to your Advisor’s successors and assigns for business and regulatory purposes after the termination of your customer relationship.
- In addition, your Advisor with whom you work with to obtain Services may use the personal information about you in his or her own files or authorize us to share your information with third-parties your Advisor uses for its everyday business purposes to advise you of other products or to help you with your overall financial plans. Such services provided by your Advisor and/or its authorized third-parties are exclusive of services provided by TradePMR.
We will reaffirm this policy as required by law, as long as you maintain an ongoing relationship with TradePMR.
We recognize that your relationship with your Advisor is important. If you are a participant of an employer sponsored plan, your Advisor may be under an agreement that restricts the transfer of your personal information and/or your employer sponsored plan account to any new firm.
Internet Privacy and the Use of Cookies:
Unless a user has not otherwise consented to our use of cookies, we insert cookies in some of our correspondence with users. We use these to collect information about you and your visit like date and time visited, length of time on site(s), pages visited, and general information about the device.
We may use third parties to target relevant advertising on other sites based on your online activity and interests. For more information about interest-based advertising, please visit Digital Advertising Alliance or the Network Advertising Initiative.
You can opt-out of seeing personalized ads by using the DAA opt-out tool or the NAI opt-out tool. Please note you will still see ads even if you opt-out, but they will not be personalized.
Google Analytics - We use a tool called “Google Analytics” to collect information about use of our website and our products. We use the information we get from Google Analytics only to improve our site and our products. We do not combine the information collected using Google Analytics with personally identifiable information. For more information on how Google uses data when we use their partners’ websites or apps, visit https://policies.google.com/technologies/partner-sites.
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