EFFECTIVE DATE: JANUARY 1, 2019
REVIEW CYCLE: ANNUAL (BY DECEMBER 31)
1. User generated content
What information do we collect?
Information relevant to your computer, including the type of device from which you are logging in, the server(s) from which you log in, the IP address from which you log-in, and other types of information available when you visit the Site or provide us information; and
Personal and financial information provided when you register with, and/or become a Client of, Marstone.
Why we collect Your Information?
Marstone is not only a technology provider, but also a registered investment advisor for our clients. Our engagement with you will depend upon the services we are contracted to provide.
We are required by law to collect and maintain certain information under federal and state laws dependent upon that relationship.
We also collect your personal information to maintain your Marstone account, enhance customer service, and bolster to your customer experience.
To improve your experience, we aggregate your personal information and perform certain analyses and reports. These analyses may include, both, identifying user trends and investment trends for internal and external purposes. When we aggregate your information, we use our best efforts to ensure that the information is not identifiable to any single Marstone client. We may also share your information with our various vendor partners as necessary to delivery services under our agreements, to optimize services and improve investment options to related platforms.
Anonymized: to make anonymous. In other words, no one can figure out who you are with the information provided.
Aggregated: combining several elements to form a whole. Basically, by aggregating information, we combine all of the content to form a whole bunch of data that cannot be traced back to any single individual.
Subadvisor: acting as a provider of investment advice to another institution which has the contractual relationship to serve as investment advisor to the Client.
Using your data
We may use your data:
To operate and maintain your accounts in accordance with requirements under U.S. and, where applicable, EU laws;
To monitor and protect the security and integrity of Marstone;
To perform analytics in order to better serve you, and to market our products and services;
To share your information as required by law, court order, subpoena, regulatory request or summons requiring disclosure of personal information;
To provide you with information and services, to customize your experience on the Site, and to inform you about other useful products, services, or information;
To aggregate information and content in a manner to avoid providing identifying customer information, to analyze and understand how our products and services are used, to deliver our products and services, and to help us develop and innovate; and
We do not sell, or rent your personally identifiable information with any undisclosed third parties. We may share your personal information with identification verification services, e- signature providers, account aggregation services, or other Marstone partners.
We may use third-party service providers to perform analytics and market services on your behalf.
We may disclose some personal information to non-affiliated companies as required by contract.
All impacted third parties have entered into agreements that require that them keep this personal information anonymized and/or confidential under strict cybersecurity protocol.
We take significant precautions to protect your information. When you submit sensitive information via the Site, your information is protected both online and offline.
Wherever we collect sensitive information, that information is encrypted and transmitted in a secure way. You can verify this by looking for a lock icon in the address bar or looking for "https" at the beginning of the address of the Web page.
While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment, and monitored for intrusion.
Information about our Users, including personal information, may be disclosed or transferred to now existing, or future, entities affiliated with Marstone or those engaged as part of any merger, acquisition, change of control, financing, insolvency, bankruptcy or sale of our assets. Such information may be used in the businesses of any such entity receiving it. We may disclose personal information in specific other cases with your consent.
We use Google Analytics to collect information about the usage of this site. This analytics service collects information relevant to your computer, such as what type of device you are logging in from, the server from which you log-in, the IP address from which you log-in, and other types of anonymous information when you visit Marstone, seek additional information from Marstone, and/or become a Client. We use the information we get from these Analytics Services to improve our site and the services we provide to you through this Site.
You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser. You can also opt out of Google Analytics by installing the Analytics Opt-out Browser.
2. How you accept this policy
3. Changes to your personally identifiable information
Once you have registered with Marstone, you can access your profile, review the information that is stored and revise some of that information. If you have technical problems, you can always contact us at firstname.lastname@example.org. Due to US regulatory requirements, we do not delete residual copies of outdated information, and must preserve all consumer data for a minimum of three years, unless otherwise required by law.
If you wish to access or change the personal information that you have submitted to us or to request the correction of any inaccurate information you have submitted to us, you may do so via the website relating to your Marstone account. Alternatively, a Marstone Account Holder can request corrections to personal information by sending an email that includes your contact information to email@example.com. Subject to certain regulatory limitations, if you are a qualified resident of the European Union, you may request that Marstone provide you information about your account usage, or request that we delete certain historical information concerning your account.
4. Deleting your information
We believe that your data belongs to you, and therefore, you may request deletion of any personal information we are not required to maintain at any time that you choose. To request that your account be deleted, please contact us at firstname.lastname@example.org. We will remove such information as soon as reasonably practical, however we may need to retain and archive certain account information as required by applicable laws or regulations. Despite such removal, portions of your data may remain on our production and back-up servers indefinitely.
5. As a visitor
We collect various types of anonymous information about visitors to Marstone, such as device- related information (browser type, IP address) and server log information (i.e. date and time you visited). We collect information that you input into our website and use this information to better understand our visitors and business, all to bolster the Marstone experience.
7. Email opt out
Marstone complies with the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (CAN-SPAM). We may provide users with periodic website related notifications, marketing offers, or other information via email. You may elect to stop receiving such messages at your discretion by updating your account preferences on the website or through your Marstone account. You may also follow the unsubscribe instructions included in promotional emails. Please note that certain email messages we send users are necessary for the proper functioning and use of services available through our website, and users who participate in such services do not have the ability to opt-out of such email messages.
8. Children’s online policy
The features, services, and other aspects of www.marstone.com requiring the submission of personally identifiable information are not intended for anyone under 18 years of age. We do not, knowingly, collect personally identifiable information from children under the age of 13 without parental consent. If you are a parent or guardian of a child under the age of 13 and believe that personally identifiable information has been disclosed to us, please contact us at email@example.com.
10. Social/third party media
11. Questions and concerns
For more general information regarding privacy you can visit the Federal Trade Commission which offers an overview of general privacy protection, or the Securities and Exchange Commission website for addition guidance issued by them.
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