Last Updated: January 1, 2023
We appreciate your trust in providing us with your information. Protection of that information is our top priority because we want to keep your trust.
We design all of our products and services with data protection in mind. We have dedicated teams who work hard to keep your information safe and secure. We constantly update our security practices and invest in our security efforts to enhance your privacy.
- Our services are not intended for children under 13. We do not knowingly collect personal data from children under 13.
- To the extent you are deemed under applicable law to have an individual consumer financial product or service with us, we will use and share personal data that we collect from or about you in accordance with our SRS Acquiom Consumer Privacy Notice provided at the end of this policy.
- If you reside outside the United States, you understand that your personal data may be processed in countries (including the United States) where laws regarding processing of personal data may be less stringent than the laws in your country.
- If you have questions after reviewing this policy, please call us at 1-800-331-5841 or email us at [email protected].
- Who we are
- Information We Collect
- How We Use Information
The types of personal data we collect depends on the product or service you use. Some information may be provided by you directly, while other information may be provided to us by third parties involved in a transaction in which you have an interest and that utilizes one or more of our products or services.
The personal data we may process could include but is not limited to your name, email address, mailing address, telephone number(s), investment information, employment information, security holdings, and tax information. We may also collect bank account information, social security numbers, employer identification numbers, and driver’s license or passport information (or comparable) where we believe it is reasonably required for ordinary business purposes.
If you give us permission through your device’s operating system settings, we may also collect your approximate location through your mobile network service provider. The collection of your approximate geolocation may occur in the background even when you aren’t using our services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it.
Virtual Data Room Service & Private Client Portal: Workspace Content
One of the core aspects of the SRS Acquiom Virtual Data Room and Private Client Portal services (each, a “File Sharing Solution”) is that you can upload any information, data, content or material (“Workspace Content”). You (and anyone who can interact with your use of the applicable File Sharing Solution) ultimately control(s) the nature of the Workspace Content, and our collection, use, and disclosure practices with respect to Workspace Content are separate from those with respect to other sorts of information we collect. As explained in detail below, we may also upload Workspace Content automatically with your authorization from third-party service providers (such as from your Google Drive).
Usage and Other Information
When you visit our websites or use our online services, we may collect and aggregate usage information to help us understand how people view the website so that we can improve its usefulness and value over time. When you use our online services, we may collect information to better provide the services to you and optimize your user experience. We may also collect data that helps us monitor network traffic and identify unauthorized or unusual activity.
The specific information we may collect includes: the name of the domain and host used to access the Internet (e.g., gmail.com); internet protocol (IP) address of the host server; referring page; name and version of the Web browser; date, time and country of site access; internet address of any site viewer used to link to our site; page views and length of time on each page.
If you request materials or send an inquiry, we may collect your name, email address, company name and title, and any other information that you send to us in such communication.
Additional Sources of Information
We may also collect information about you from additional sources, including without limitation, third party sources such as our business clients, government agencies, consumer reporting agencies, and other commercially available suppliers of information. We may combine this information with the personal and other information we have collected about you. When the combined information directly or indirectly identifies an individual, we treat it as personal data.
We use the information we collect in a number of ways, depending on what we collect and what services you use (or features of such services). These purposes may include:
- Processing and servicing accounts and transactions;
- Verifying your identity;
- Preventing fraud and enhancing the security of your account or our online services;
- Responding to your requests and communicating with you;
- Managing your preferences;
- Performing analytics concerning your use of our online services, including your responses to our emails and the pages you view;
- Providing you tailored content and marketing messages, including information about our affiliates’ products based on criteria provided by our affiliates (our marketing emails tell you how to “opt-out”; if you opt out, we may still send you non-marketing emails, such as emails about your accounts and our business dealings with you);
- Operating, evaluating and improving our business: including developing new products and services; improving existing products and services; performing data analytics; and performing accounting, auditing and other internal functions;
- Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies;
- For any other purposes that we may specifically disclose at the time you provide, or we collect your information; and
- For any other purpose with your consent.
We may also use data that we collect on an aggregate basis, such that it does not identify any individual customers, for various business purposes at our discretion.
If you provide feedback to us, we may use and disclose such feedback for any purpose, provided we do not associate such feedback with your personal data.
- Legitimate interests: We may use your information where we have legitimate interests to do so. For example, we analyze our users’ behavior to improve the services, to prevent and detect fraud and misuse, and to market new products and services that we think will interest you
- Performance of a contract: We may use your information in order to perform services for you.
- Consent: From time to time, we may ask for your consent to use your information. Subject to applicable law, you may withdraw your consent at any time by contacting us at [email protected]. With respect to the placement of cookies for which your consent is the legal basis for processing, you may withdraw your consent by modifying your Cookie preferences.
- Processing is necessary for compliance with any legal obligation to which the controller is subject.
We may share the information we collect from and about you with our related affiliates and other third parties. For example, we may share your information with:
- Our third-party service providers;
- Our affiliated businesses in an effort to bring you improved service and offerings across our family of products and services, when permissible under relevant laws and regulations;
- Other companies to bring you co-branded services, products or programs, or the offerings of such other companies that may be of interest to you, when permissible under relevant laws and regulations; and
- Third parties or affiliates in connection with a corporate transaction, such as a sale, consolidation or merger of our businesses, and
- If you are a user of one of our File Sharing Solutions, with other File Sharing Solution users, at your direction and in accordance with the permissioning designated within such File Sharing Solution website.
Applicable law may require SRS Acquiom to disclose your personal data if: (i) reasonably necessary to comply with legal process (such as a court order, subpoena or search warrant) or other legal requirements; (ii) necessary to protect legal rights of SRS Acquiom users, customers, business partners, or other interested parties; (iii) necessary for the prevention or detection of crime. For residents of the European Economic Area, SRS Acquiom will disclose personal data only when permitted to do so under applicable European and EU Member States’ national data protection laws and regulations.
Client-side storage comprises pieces of information stored directly on the computer you are using. We or our third-party service providers may place cookies, user data, or other objects on your hard drive for security purposes, to facilitate site navigation and to personalize your experience.
By using the services and tools provided through SRS Acquiom Clearinghouse®, SRS Acquiom ComPort® (Shareholder Representative Portal), SRS Acquiom MarketStandard®, SRS Acquiom Deal Dashboard, SRS Acquiom Workspaces, SRS Acquiom Virtual Data Room or SRS Acquiom Private Client Portal (including any white labelled version thereof used or accessed via a third party custom domain) you accept the cookies that are placed in connection with your use of such services and tools and are intentionally directing SRS Acquiom or its affiliates to make your cookie data available to our third party partners to optimize your experience and support the functionality of such services and tools, consistent with your expectations under applicable privacy and data protection laws. These cookies are critical to the performance and proper functioning of such services and tools and accordingly, are considered Necessary Cookies. As such, you cannot opt out of the placement of such cookies. You further acknowledge that we have a legitimate interest in placing such cookies in connection with your use of such services and tools.
Our Policy On “Do Not Track (‘DNT’)” Signals and Global Privacy Control Signals
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain personal data about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including SRS Acquiom Inc., do not respond to DNT signals. We do, however, recognize and honor Global Privacy Control (GPC) signals. For more information about GPC, please visit Global Privacy Control.
We use physical, technical and organizational measures designed to protect your information against unauthorized access, theft and loss. We restrict access to your information to those employees who need to know that information to perform their job functions.
Although we take precautions intended to help protect information that we process, no system or electronic data transmission is completely secure. We expect that you will use appropriate security measures to protect the personal data you transmit to us.
You are responsible for maintaining the security of your account and the information in your account. We may suspend your use of all or part of our services without notice if we suspect or detect any breach of security. You understand and agree that we may deliver electronic notifications about breaches of security to the email address on record on your account.
If you believe that your account or information is no longer secure, please notify us immediately at [email protected].
- The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using the services);
- In the case of Workspace Content, if you have directed the deletion thereof;
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations).
Device permissions. Mobile Device operating systems have permission systems for specific types of device data, such as location services, and so-called push notifications. You can change your settings on your Device to consent or decline the collection of data or the display of the notifications, but certain services may lose full functionality when you do. You also can stop all information collection by our mobile application by uninstalling it from your Device.
If you would like to review, correct, update, or delete personal data about you that you have previously provided to us or if you would like to restrict our processing of your personal data or receive an electronic copy of your personal data for purposes of transmitting it to another company (if these rights to restrict processing and data portability are provided to you by law), please contact us using the contact information below.
In your request, please make it clear the personal data to which your request relates and the actions you would like us to take. For your protection, we will verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we often need to retain certain data for recordkeeping purposes and our databases and other records may have residual data that we will not remove. We also may not allow you to review or delete certain data for legal, security or other reasons.
If you are an EEA resident, you have the right to lodge a complaint with a data protection authority about how we process your personal data.
If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request to [email protected]. Please allow up to 30 days for a response.
California Privacy Rights Act
The California Privacy Rights Act (“CPRA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to know/access, delete, and limit sharing of Personal Information. The CPRA defines “Personal Information” as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the CPRA will vary based on our relationship or interaction with that individual. Certain information we collect may be exempt from the CPRA because it covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act or because the SRS Acquiom entity collecting it does not meet the definition of a “business” under the CPRA. For example, this California Privacy Rights Act disclosure does not apply with respect to information that we collect about California residents who apply for or obtain our financial products and services for personal, family, or household purposes. For more information about how we collect, disclose, and secure information relating to these customers, please refer to the section below entitled SRS Acquiom Privacy Notice.
To the extent that we collect Personal Information that is subject to the CPRA, that information, our practices, and your rights are described below.
Personal Information We Collect
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 PI we collect||Source of Information||Purpose for which information is collected or used||Category of third parties to whom we have disclosed information||Sensitive Personal Information (Y/N)|
|Identifiers||Real name, alias, postal or contact address, country of residency, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name.||Provided by you directly, or provided to us by third parties involved in a transaction in which you have an interest and that utilizes one or more of our products or services||For our everyday business purposes and for marketing purposes, such as, to offer you products and services you request, maintain and service your accounts, verify your information, process payments, provide similar services to you, and answer your questions.||Vendors/ Service Providers that assist us in providing our Services and running our internal business operations (“Service Providers”); Affiliates||N|
|Social security number||N/A||Provided by you directly.
|To verify your information, process payments and complete applicable tax reporting.
|Service providers; Affiliates
Benefit providers; Service providers.
|Driver’s license, state identification card number or passport number.||N/A||Provided by you directly.||To verify your information and process payments (if applicable).||Service providers; Affiliates||Y||PI (including Personal information listed in § 1798.80 of the California Customer Records statute)||Items listed as identifiers and your signature, telephone number(s), insurance policy number, bank account number.||Provided by you directly, or provided to us by third parties involved in a transaction in which you have an interest and that utilizes one or more of our products or services||For our everyday business purposes and for marketing purposes, such as, to offer you products and services you request, maintain and service your accounts, verify your information, process payments, provide similar services to you, and answer your questions.||Service Providers; Affiliates||N|
|Protected Classifications||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.||Career applicants and employees||Recruitment and employee benefits||Benefit providers; Service Providers||N|
|Racial origin||N/A||Career applicants and employees||Recruitment and employee benefits||Benefit providers;
|Commercial Information||Records of products or services utilized or considered, or other consuming histories or tendencies through our marketing website.||Cookies and other tracking technologies from our website and applications.||When you engage in transactions with us, we do not create records of goods or services purchased or considered, nor of purchasing or consuming histories or tendencies.||Affiliates; Service Providers; Data aggregators||N|
|Biometric||Fingerprints (applies to employees, associated persons, and registered representatives only)||Associated persons and registered representatives employed by us||Required for all employees and associated persons for security purposes||Regulatory Agencies||Y|
|Internet/ Electronic Network Activity||We collect information about your browsing history, search history, information regarding your interaction with websites, applications, communications, or advertisements automatically when you utilize our Services.||Cookies and other tracking technologies from our website and applications.||We use this information to gauge online activity on our website, measure the effectiveness of our Services, and to provide you with relevant information, advertisements and offers based on your online activities and for data security and protection from unauthorized access.||Affiliates; Service Providers; Data aggregators||N|
|Geolocation Data||As described above, we collect your IP address automatically if you visit our website. We do not collect your precise location (e.g., your GPS coordinates).||Cookies and other tracking technologies from our website and applications.||We use this information to gauge online activity on our website, measure the effectiveness of our Services, and to provide you with relevant information, advertisements and offers based on your online activities and for data security and protection from unauthorized access.||Affiliates; Service Providers; Data aggregators||N|
|Audio, electronic, and similar information, such as call and video recordings||We do not collect your image or any thermal, olfactory, or similar information about you, however, Client Service calls may be recorded.||Provided by you directly||To improve our customer service||Affiliates||N|
|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||Career applicants, contractors, and employees||To verify employee information, pay and provide benefits to our employees and independent contractors||Affiliates; Benefit providers; Service Providers,||N|
We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected.
We do not use or disclose sensitive personal information for purposes other than those specified in California Civil Code section 1798.121.
All of the above categories of information about you or third parties (other than Internet/Electronic Network Activity and Geolocation Data) may be contained in Workspace Content that is uploaded by a user of a File Sharing Solution. Workspace Content is collected by us at the user’s behest. We will not use or access Workspace Content except in the following cases: for providing the applicable File Sharing Solution service to you; where you explicitly approve access (e.g., during a customer support inquiry); where compelled to do so in response to lawful requests by law enforcement or government regulators; where necessary to ensure the stability and security of the service and our systems (e.g., where we have reason to believe specific Workspace Content is degrading server stability); and where necessary to protect the rights, privacy, safety, or property of you, us, or others. We may also analyze metadata related to Workspace Content (such as total number of records, file size, access logs, etc.) to improve the service and enforce the terms of the associated SRS Acquiom service agreement. We may disclose such Workspace Content (including any Personal Information contained therein) to our affiliates and service providers in order to provide the applicable File Sharing Solution, and with other File Sharing Solution users, at your direction and in accordance with the permissioning designated within such File Sharing Solution website.
• The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using the services);
• In the case of Workspace Content, if you have directed the deletion thereof;
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations).
SRS Acquiom and its affiliates do not sell or share and have not in the preceding 12 months sold or shared Personal Information to which the CPRA applies, within the meaning of the CPRA.
You may request access to the Personal Information that we have collected and maintained about you (along with the categories of Personal Information, the categories of sources from which such information is collected, the business or commercial purpose for collecting such information and the specific pieces of Personal Information we have collected about you). You may only make such requests twice (2) per every twelve (12) months. Once your request is verified and we have determined that we are required to provide you with such information in accordance with applicable law, we will provide you with access to such information.
You have the right to request that we delete Personal Information collected and maintained about you, subject to certain exceptions. Once your request is verified and we have determined that we are required to delete that information in accordance with applicable law, we will delete your personal information accordingly. Your request to delete your Personal Information may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the CPRA. Please note that a record of your deletion request may be kept pursuant to our legal obligations.
You have the right to request that we correct Personal Information collected and maintained about you. Once your request is verified and we have determined that we are required to correct that information in accordance with applicable law, we will correct your Personal Information accordingly. Please note that a record of your correction request may be kept pursuant to our legal obligations.
To exercise the access and deletion rights described above, please submit a request to us by either:
- [email protected] or
- call us at 1-800-331-5842.
Only you, or a person that you authorize to act on your behalf, may make a request related to your Personal Information. You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf. In the case of access and deletion, your request must be verifiable before we can fulfill such request.
Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected Personal Information or a person authorized to act on your behalf (e.g., previous transactions of person to whom request relates).
We will only use the Personal Information that you have provided in a verifiable request in order to verify your request. As stated above, we cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority.
SRS Acquiom Consumer Privacy Notice
|Facts||What Does SRS Acquiom Do With Your Personal Information?|
|Why?||Companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.|
|What?||The types of personal information we collect and share depend on the product or service you have with us. This information can include, without limitation:
● Government identification numbers, such as driver’s license, passport, visa or Social Security number
● Name, email address, mailing address and telephone number(s)
● Account balances and transaction history
● Bank account information, payment instructions, security holdings and tax information
● Investment information and employment information
You consent to our collection, transfer and storage of information by computers or other transfer or storage devices in the United States and elsewhere when you supply information.
|When?||This Privacy Notice was last modified on October 22, 2020|
|How?||All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information, the reasons SRS Acquiom chooses to share, and whether you can limit this sharing.
SRS Acquiom does not sell personal information.
|Reasons We Can Share Your Personal Information||Does SRS Acquiom Share?||Can You Limit This Sharing?|
|For Our Everyday Business Purposes
Such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
|For Our Marketing Purposes
To offer our products and services to you
|For Joint Marketing With Other Financial Companies||Yes||No|
|For Our Affiliates’ Everyday Business Purposes
Information about your transactions and experiences
|For Our Affiliates’ Everyday Business Purposes
Information about your creditworthiness
|No||We Do Not Share|
|For Our Affiliates to Market to You
To offer their non-financial products, or financial products not involving personal credit or personal insurance
|For Our Affiliates to Market to You
To offer personal credit or personal insurance products to you
|For Non-Affiliates to Market to You||Yes||Yes|
|To Limit Our Sharing||If you prefer that we limit sharing with affiliates or nonaffiliated third parties as described above, you may opt out of those disclosures as follows: call 303-222-2080 OR email us at [email protected].
Please Note: If you are a new consumer or customer, we can begin sharing your information 30-days from the date we sent this notice. When you are no longer our consumer or customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.
|Questions?||Call 1-800-331-5842 or Email [email protected]|
|Who We Are|
|Who is Providing This Notice?||SRS Acquiom Inc. and the affiliated family of SRS Acquiom companies comprised of our U.S. legal entities with an SRS or Acquiom name.|
|What We Do|
|How does SRS Acquiom protect my personal information?||To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We endeavor to limit personal information access to only employees, agents and representatives that need to know, and we require companies that work for us to protect your information.|
|How does SRS Acquiom collect my personal information?||We collect your personal information, for example, when you:
|Why can’t I limit all sharing?||Federal law gives you the right to limit only:
State laws and individual companies may give you additional rights to limit sharing.
|What happens when I limit sharing for an account I hold jointly with someone else?||Your choices will apply to everyone on your account.|
|Affiliates||Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include companies with an Acquiom or SRS name, including financial or insurance companies such as Acquiom Financial LLC and Acquiom Insurance LLC, and non-financial companies such as Shareholder Representative Services LLC.|
|Non affiliates||Companies not related by common ownership or control. They can be financial and nonfinancial companies. Nonaffiliates we share with can include financial services companies and nonfinancial companies such as lifestyle products and services companies and membership clubs.|
|Joint Marketing||A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Our joint marketing partners can include financial service companies and insurance companies.|
|Other Important Information|
|EXTERNAL WEBSITES||Our website may be linked to or from third party websites. We are not responsible for the content or privacy practices of websites that are linked to or from our website.|
|CHANGES||We reserve the right to modify this Privacy Notice. You can get updated Privacy Notices by visiting our Website at www.srsacquiom.com.|