In this policy, the word "customer" is used to mean any individual who obtains or has obtained a financial product or service from TradePMR as a provider of Services that involve compiling personal and sometimes sensitive information.
Categories of Personal Data We Collect
The following lists the categories of Personal Data that we collect and have collected over the past 12 months:
- Identifiers (e.g., name, mailing address, email address, phone number)
- Characteristics of protected classifications (e.g., gender, age)
- Commercial information (e.g., purchases, marketing collateral requested, webinar registrations)
- Professional or employment-related information (e.g., employment status, employer)
- Internet or other electronic network activity (e.g., browse or search history, interaction with a website, application, or advertisement)
- Geolocation data (e.g., latitude or longitude)
- Inferences drawn from other data collected or from the above (e.g., preferences or characteristics)
Categories of Sources of Personal Data
We collect personal information about you from the following categories of sources:
When You Provide Such Information Directly to Us
- When you provide information in applications and related forms to obtain a financial product or service.
- When you provide information in free-form text boxes or respond to surveys.
- When you contact us.
When You Use our Services and Such Information Is Collected Automatically
- Through Cookies (see “Tracking Tools ” below).
- If you use a location-enabled browser, we may receive information about your location and device.
- If you access certain applications and software we make available, we may receive and collect information transmitted from your device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
Public Records or Sources
Information from the media, and other records and information that are made available by federal, state, or local government entities
- Information obtained from other associations regarding any Service we may provide to you.
- Third-party reports, such as demographic and/or other information, if relevant to your Service.
- Information about your relationship with us, such as Services purchased, and/or account numbers, transaction information and balances.
- Analytics providers to analyze how you engage with the Services.
- Information to generate leads and create user profiles.
- Information to assist us with marketing or promotional services including how you interact with our websites, applications, products, Services, advertisements, or communications.
Our Commercial or Business Purposes for Collecting Personal Data
Providing, Customizing and Improving our Services
- Creating and managing your account or other user profiles.
- Processing orders or other transactions.
- Providing you with the products, services, or information you request, including support and assistance for the Services.
- Improving the Services, including testing, research, internal analytics, and product development.
- Personalizing the Services, website, and communications based on your preferences.
- Performing fraud protection, security and debugging.
- Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).
Marketing our Services
- Marketing and selling the Services.
- Showing you advertisements, including interest-based or online behavioral advertising.
Corresponding with You
- Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about TradePMR or our Services.
- Sending emails and other communications according to your preferences or that display content that we think will interest you.
Meeting Legal Requirements and Enforcing Legal Terms
- Fulfilling our legal obligations, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities.
- Protecting the rights, property, or safety of you, TradePMR or another party.
- Enforcing agreements with you and resolving disputes.
- Responding to claims that any posting or other content violates third-party rights.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.
How We Share Your Personal Data
We disclose your Personal Data to the categories of service providers listed in this section.
Service Providers who help us provide the Services or perform business functions:
- 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 facilitate enhanced customer service; to develop or maintain software; to perform marketing research; or to provide us with demographic information to develop marketing plans.
- Consumer reporting agencies in connection with your application or renewal of any Services subscribed or purchased.
- Analytics providers.
- Payment processors.
- We require these companies to maintain the confidentiality of your information and use it only for the purpose for which it was provided.
Your Advisor with whom you work with to obtain Services.
Your Advisor’s successors and assigns for business and regulatory purposes after the termination of your customer relationship.
Business Partners with which we share common ownership or who partner with us in offering various services, joint promotional offers, or opportunities.
Advertising Partners who help us market our services:
- Marketing providers.
- Ad networks.
Law enforcement and regulatory authorities to comply with 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).
As a provider of a wide variety of Services, we may identify opportunities to enhance customer service or to offer our customers additional Services offered by TradePMR. However, we will not share information about our customers with others that could be used to make insurance underwriting or lending decisions about the customer, unless the customer directs us to or unless we notify the customer first and give the customer a chance to opt-out. In addition, we will not use certain Non-public Personal Information (such as income or account history) received from any affiliate to market its products or services to our customers unless directed to by the customer, or unless we notify the customer first and give the customer a chance to opt-out. Similarly, we will not share Non-public 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 the customer direct us to, or unless we notify the customer first and give the customer a chance to opt-out.
We recognize that our customers’ relationship with their Advisor is important. If the customer is a participant of an employer sponsored plan, the customer’s Advisor may be under an agreement that restricts the transfer of the customer’s personal information and/or the customer’s employer sponsored plan account to any new firm.
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 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 are trained to understand their duty to safeguard it.
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.
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.
Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/privacy-laws and see the Privacy Notice for California Residents section of this Policy.
Notice to European Users
If you have any questions or concerns, please feel free to contact our Compliance Department at firstname.lastname@example.org.
Privacy Notice for California Residents
Your Rights and Choices
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you (to the extent required by law):
- 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 or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
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 confirm your verifiable consumer request, we will delete your personal information from our records, unless an exception applies.
Personal Data Sales Opt-Out and Opt-In
The CCPA defines a “sale” as the disclosure of Personal Data for monetary or other valuable consideration. TradePMR does not offer an opt out from the sale of Personal Data because we do not and have not within at least the last 12 months sold Personal Data that is subject to the CCPA’s sale limitation.
TradePMR does not offer an opt out from the sale of Personal Data because we do not and have not within at least the last 12 months sold Personal Data that is subject to the CCPA’s sale limitation.
Exercising Access and Deletion Rights
To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request via email to our Compliance Department at email@example.com.
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
Responding to Requests
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Privacy and data protection laws, other than the CCPA, apply to much of the Personal Data that we collect, use, and disclose. When these laws apply, Personal Data may be exempt from, or outside the scope of, Access Requests and Deletion Requests. For example, information subject to certain federal privacy laws, such as the Gramm-Leach-Bliley Act or the Health Insurance Portability and Accountability, is exempt from CCPA Requests. As a result, in some instances, we may decline all or part of an Access Request or Deletion Request related to Personal Data exempt from CCPA Requests. This means that we may not provide some or all of this Personal Data when you make an Access Request. Also, we may not delete some or all of this Personal Data when you make a Deletion Request.
We will not discriminate against you for exercising any of your CCPA rights. We will not:
- Deny you goods or services.
- Charge you different prices or rates for our Services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of service.
- Suggest that you may receive a different price or rate for our Services or a different level or quality.
TradePMR does not sell your personal information; therefore, CCPA-permitted financial incentives are not applicable.
Changes to Our Privacy Notice for California Residents
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.