Privacy Policy

Last Updated: July 1, 2016

Your privacy is important to us. This Privacy Policy explains how we collect, share, use, and protect information when you visit any of the websites or use any online service or other service operated or offered by SRS Acquiom Inc. and its affiliates.

As you review this Privacy Policy, here are a few general principles to keep in mind:

  • Our services are not intended for children under 13. We do not knowingly collect personal information 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 information that we collect from or about you in accordance with our Acquiom Consumer Privacy Notice provided at the end of this policy.
  • If you reside outside the United States, you understand that your personal information may be processed in countries (including the United States) where laws regarding processing of personal information may be less stringent than the laws in your country.
  • If you have questions after reviewing this policy, please call us at 303-222-2080 or email us at info@srsacquiom.com.

Information We Collect

Personal Information

The types of personal information we collect depend on the product or service you have with us. In addition, 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. We may collect personal information from or about you such as your name, email address, mailing address, telephone number(s), investment information, employment information, security holdings, tax information, user name and password. 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.

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. None of these data are traceable to a specific individual. We may also collect data that help 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 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 under this Privacy Policy.

Use of Information

We use the information discussed above in a number of ways, such as:

  • 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 or anonymous 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 information.

Disclosure of Information

We may share the information we collect from and about you with our 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;
  • Third parties or affiliates in connection with a corporate transaction, such as a sale, consolidation or merger of our businesses; and
  • Other third parties as permitted by law without notice (for example, without limitation, to process and service transactions you request or authorize, to protect against potential fraud or unauthorized transactions, to verify or enforce our terms of use or our other rights, to respond to judicial process, or to comply with federal, state, or local legal requirements)

Where appropriate, we will limit sharing of your information in accordance with the choices you have provided us in response to our Acquiom Consumer Privacy Notice.

We may share anonymous or aggregated information with third parties at our discretion.

Understanding Client-Side Storage Tracking Technologies

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 Flash objects on your hard drive for security purposes, to facilitate site navigation and to personalize your experience.

When you visit our Website we use cookies to monitor your experience. If you have an account with us and access your accounts online, we will maintain information about your visits to personalize your browsing experience and the products and services we offer. If you do not have an account with us and do not wish us to maintain information, please disable cookies for our sites and delete your cookies. To do this, you will need to follow your browser’s instructions for disabling or deleting cookies.

Client-side storage technologies provide us the capability to monitor the use of our website so we can continually improve the design and functionality to better serve you. The data we store does not contain unencrypted personal information. If you choose not to accept cookies from our website, then you may not be able to access and use all or part of the websites or benefit from the information and services offered.

Security

We use reasonable physical, electronic, and procedural safeguards that comply with federal standards to protect and limit access to personal information. This includes device safeguards and secured files and buildings.

Please note that information you send to us electronically may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information (such as your Social Security number) to us.

Updating Your Information

Keeping your account information up-to-date is very important. You may review or update certain account information by logging in and accessing the applicable online service that you have with us. If you cannot change the incorrect information online, or you prefer to request changes offline, please use the contact information on the applicable online service website to call or email us.

Consent and Changes to this Privacy Policy

By using any of our websites or online services, you agree to the terms of this Privacy Policy. You also expressly consent to the use and processing of your personal information according to this Privacy Policy.

We may change this Privacy Policy from time to time. When we do, we will let you know by appropriate means such as by posting the revised policy on this page with a new “Last Updated” date. Any changes to this Privacy Policy will become effective when posted unless indicated otherwise.

Acquiom Consumer Privacy Notice

Facts

What Does 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. Federal 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 July 1, 2016.

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 Acquiom chooses to share, and whether you can limit this sharing.

 

Reasons We Can Share Your Personal Information Does 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
Yes No
For Our Marketing Purposes
To offer our products and services to you
Yes No
For Joint Marketing With Other Financial Companies Yes No
For Our Affiliates’ Everyday Business Purposes
Information about your transactions and experiences
Yes No
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
Yes No
For Our Affiliates to Market to You
To offer personal credit or personal insurance products to you
Yes Yes
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 visit us online: www.srsacquiom.com, log into your account and use the Submit Inquiry button OR email us at info@srsacquiom.com.

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 303-222-2080 or Email us at info@srsacquiom.com

 

Who We Are
Who is Providing This Notice? Acquiom Clearinghouse LLC and the affiliated family of Acquiom companies comprised of our U.S. legal entities using the name Acquiom.

 

What We Do

How does 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 Acquiom collect my personal information? We collect your personal information, for example, when you:

  • Request or receive payments in connection with an acquisition transaction
  • Submit information to us on letters of transmittal or other forms and by other means
  • Use our online sites (for example, to complete a transaction, manage your accounts, or provide your preferences)
  • Use or request other products or services from us

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can’t I limit all sharing?

 

Federal law gives you the right to limit only:

  • Sharing for affiliates’ everyday business purposes—information about your creditworthiness
  • Affiliates from using certain of your information to market to you (unless such affiliates have a preexisting business relationship with you)
  • Sharing for non-affiliates to market to you

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.

 

Definitions
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 Web site at www.acquiom.com.