NORTH CAPITAL PRIVATE SECURITIES CORPORATION PRIVACY STATEMENT
North Capital's Commitment to Privacy
Effective Date: 11/09/2015
What information does North Capital collect?
North Capital collects and maintains the following personal information required to communicate with you, including your name, mailing address, telephone numbers, and email address. In addition, North Capital requests the following personal information to identify who you are, such as government identification, employer name and address, and Social Security or Employer Identification number. To comply with state and federal laws and regulations, North Capital also collects information to assess your current financial situation, your goals and objectives, and your investment experience, and other factors related to your suitability for certain investments. The information requested may include your approximate annual income, sources of income, approximate net worth, and approximate value of investment assets. If you register through the Website, North Capital may collect certain demographic information, including age, gender, education, occupation, etc. Certain information also is collected automatically, which we store in log files, when you access the Website, including your Internet Protocol (IP) address, browser type, operating system, internet service provider (ISP), pages accessed, and prior and following sites that you view. We do this to improve the services we offer you and to improve site functionality.
What kind of tracking technologies do we use?
North Capital and our partners, affiliates, or analytics or service providers may use tracking technologies such as cookies, beacons, tags, and scripts to analyze trends, administer the website, track users' movements around the website, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies from these companies on an individual or aggregated basis.
We use Local Shared Objects, such as Flash cookies to store content information and preferences. Third parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity also use Flash cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. To manage Flash cookies, please click here:
We partner with a third party to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here. Please note this does not opt you out of being served ads. You will continue to receive generic ads.
Frames: Some of our pages utilize framing techniques to serve content to/from our partners while preserving the look and feel of our website. Please be aware that you are providing your personal information to these third parties and not to North Capital.
Social Media Widgets: Our websites include Social Media Features and Widgets, such as the Twitter and LinkedIn interactive mini-programs that run on our website. These Features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. The privacy statement of the company providing it governs your interactions with these Features.
When does North Capital obtain information about you?
Most of the information collected by North Capital is provided directly by you, by completing the questionnaires and documentation required by North Capital to do business with you. Other ways information may be obtained are by (1) observing your usage of the Website, (2) providing services to you, and (3) collecting information (such as address, occupation, investment risk profile, and other marketing data) available from publicly or commercially available sources, such as online databases We collect this information to help us determine the suitability of products and services for you and to ensure regulatory compliance.
Why does North Capital gather information?
North Capital gathers information about you and your financial situation in order to provide you with services that are appropriate for your particular situation and to ensure compliance with applicable laws and regulations. In addition, North Capital may gather information to help expand the scope and improve the quality of services that North Capital might offer to you now or in the future.
How does North Capital use clients' personal information?
The trust of our clients is our most important asset. North Capital is careful to use personal information only as appropriate to provide clients with premium service while maintaining confidentiality and security. For example, North Capital may use information collected to verify your personal identity and contact details. If the information you provide suggests that other services may be suitable and appropriate, North Capital may offer additional services to you. North Capital also may use the demographic information collected, along with general demographic information provided by third parties, in order to develop additional capabilities and services for clients. Should you elect to terminate your relationship with North Capital, we may disclose your personal information as required by law, such as, to comply with a subpoena, bankruptcy proceedings, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. We will retain personal data we process on behalf of our TransactAPI clients for as long as needed to provide services to them. North Capital will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
What information may be shared with affiliates, partners, and third-party service providers?
North Capital will share your personal information with third parties only in the ways that are described in this privacy statement. We may share your personal information with affiliates, partners and third-party service providers if the information is required to provide a service you have requested or to provide you the opportunity to participate in the products or services offered by the affiliates. The use of your personal information is limited to the purposes identified in North Capital's agreement with the affiliate, partner or third-party service provider, although you may be asked to agree to additional terms including acknowledging additional privacy terms, as a condition of accepting the provision of services. An affiliate is a company that North Capital owns or controls or is under common control. North Capital may share information related to the services provided to you, such as name, email address, mailing address, date of birth, employment status, and general account and demographic information. North Capital does not share information with affiliates other than the type of information described above. A partner or third-party service provider is a firm contracted by North Capital to support certain functions of the business, such as transaction posting, information dissemination, internet marketing, account processing, research, due diligence, reporting, information technology support, transfer agency, escrow, or custodial services. Use of any shared information is strictly limited to the provision of the contracted service, and all partners and third-party service providers with whom personal information is shared are required to protect such information in a manner similar to the way we protect such information, including restricting its dissemination except as necessary to provide the contracted service. Within our TransactAPI platform, transfers to subsequent third parties are covered by the service agreements with our TransactAPI clients.
Does North Capital's Privacy Statement apply to other websites linked to the Website?
What steps does North Capital take to safeguard clients' personal information?
North Capital utilizes a broad array of security software, systems, and operational procedures to ensure the confidentiality and safety of your personal information. While no security system is flawless, North Capital is regularly reviewing and upgrading the security technology and procedures that safeguard your confidential information. If you access the Website, a unique login identifier and password will be maintained for your online account access. You are responsible for keeping this information secret. You also may be offered online access to information related to your account through a third party service provider, such as an investment portal, advisor, custodian, transfer agent, or escrow agent. In such case you are responsible for safeguarding the credentials provided by such third party.
Will I be able to review, change, delete or correct my information?
Yes. Personal identifying information may be reviewed, changed, or corrected at any time. Your personal information cannot be deleted due to our regulatory compliance obligations. However, if you request that we no longer use your personal information, it will be maintained for regulatory archival purposes only. You are responsible for maintaining the accuracy and completeness of your personal and other information. Please review your information at regular intervals to ensure that it is accurate and complete. If you would like to review your personal information, or request deletion of your personal information, or if you believe that any of the information you have provided may be incorrect or out of date, or if you have any other questions or concerns regarding your personal information or regarding this Privacy Statement, please contact us using the Contact tab or email firstname.lastname@example.org.
North Capital may not have any direct relationship with the individuals whose personal data it processes on TransactAPI. In such instance, an individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to North Capital's client (the data controller). If requested to remove data we will respond within a reasonable timeframe.
Our blog is managed by a third party application that may require you to register to post a comment. We do not have access or control of the information posted to the blog. You will need to contact or log in to the third party application if you want your personal information that was posted to the comments section removed. To learn how the third party application uses your information, please review their privacy statement.
If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page, or you can contact us at email@example.com
If you choose to use our referral service to tell a contact about a blog post, we will ask you for your contact's name and email address. We will automatically send your contact a one-time email inviting him or her to visit the blog. North Capital stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program.
Your contact may contact us at firstname.lastname@example.org to request that we remove this information from our database.
How will I know if there are any changes to this Privacy Statement?
In the event that North Capital makes any material changes to this Privacy Statement, the revised Privacy Statement will be posted to the Website along with a notice informing you of such changes. In addition, this Privacy Statement has an effective date displayed at the beginning of this statement indicating when it first came into effect. You should review this Privacy Statement at regular intervals to remain informed of any changes. You agree that the act of posting a revised Privacy Statement electronically on the Website satisfies any obligation of North Capital to physically deliver the Privacy Statement to you.
This Agreement, including the additional Legal Notices, forms a legally binding contract between you and the Company in relation to your use of the Website. It is important that you take the time to read all of the documents carefully. If there is any contradiction between what the Legal Notices say and what the Agreement says, then the Legal Notices shall take precedence in relation to that part of the Website.
3. Provision of the Website.
You understand and agree that affiliates and service providers of NCIT, including subsidiaries, parent companies, companies under common control with NCIT, and / or companies with whom NCIT has contracted, may provide the Website to you, that the form and substance of the Website provided to you may change from time to time without prior notice to you, and that NCIT may stop (permanently or temporarily) providing the Website (or any features within the Website) to users generally or you specifically at the Company's sole discretion, without prior notice.
You understand and agree that if NCIT disables your access to the Website, you may be prevented from accessing the Website, your account details or any files or other content that is contained in your account.There is no service-level agreement (an "SLA") with the Company or the Website. You understand and agree that the Website may not be available from time to time due to maintenance or service or network disruptions, and by your use of the Website you agree to hold harmless the Company for any such service interruptions.
4. Your use of the Accredited.AM Website
You agree not to access (or attempt to access) the Website by any means other than through the interface that is provided by NCIT unless you have been specifically allowed to do so in a separate agreement with the Company. You specifically agree not to access (or attempt to access) any element of the Website through any automated means (including use of scripts or web crawlers) and shall ensure that you comply with the instructions in any robots.txt file present in the root directory of the Website. You agree that you will not engage in any activity that interferes with or disrupts the Website (or the servers and networks that host the Website or that are connected with any elements thereof).
5. Your passwords and security
You agree and understand that you are responsible for maintaining the confidentiality of passwords associated with any credentials you use to access the Accredited.AM Website. Accordingly, you agree that you will be solely responsible for all activities that occur under your credentials. If you become aware of any unauthorized use of your password or of your account, you agree to notify the Company promptly.
6. Privacy and your personal information
You understand and agree that NCIT is not responsible for the privacy or security of any information that you provide to third parties via the Website.
7. Content in the Website
You understand that all information (such as data files, written text, publications, images) that you may have access to as part of, or through your use of, the Website are the sole responsibility of the person from which such content originated. All such information is referred to as the "Content."
You should be aware that Content presented to you as part of the Website may be protected by intellectual property rights that are owned by providers of that Content (or by other persons or companies on their behalf), and may be subject to confidentiality provisions. You may not modify, rent, lease, loan, sell, distribute or create derivative works based on this Content (either in whole or in part) unless you have been specifically told that you may do so by the Company and by the owners of that Content, in a separate agreement.
You agree that you are solely responsible for (and that NCIT has no responsibility for) any Content that you create, transmit or display while using the Website and for the consequences of your actions (including any loss or damage that the Company may suffer) by doing so.
8. NCIT's Rights
You recognize and agree that the Company or its licensors own certain legal right, title and interest in and to the Website, including any intellectual property rights that subsist in the Website (whether those rights happen to be registered or not, and wherever in the world those rights may exist). You further understand and agree that the Website may contain information that is designated confidential by the Company or its licensors and that you shall not disclose such information without the Company's prior written consent.
Unless you have been expressly authorized to do so in writing, you agree that in using the Website, you will not use any trade mark, service mark, trade name, logo of any company or organization in a way that is likely or intended to cause confusion about the owner or authorized user of such marks, names or logos.
9. Your License to use the Accredited.AM Website.
You may not (and you may not permit anyone else to) copy, modify, create a derivative work of, reverse engineer, decompile or otherwise attempt to extract the source code of the Website or any part thereof, unless this is expressly permitted or required by law, or unless you have been specifically told that you may do so by the Company, in writing.
You may not assign (or grant a sub-license of) your rights to use the Website, grant a security interest in or over your rights to use the Website, or otherwise transfer any part of your rights to use the Website.
Certain software utilized by the Company may be licensed by the Company under the GNU General Public License or other public licenses. Nothing in this provision shall be construed as abrogating any rights of anyone to use software that has been used by NCIT under such public license.
10. Content license from you.
You retain copyright and any other rights you already hold regarding Content that you may be permitted to publicly submit, post or display on or through the Website.
By submitting, posting or displaying the content you give the Company a perpetual, irrevocable, worldwide, royalty-free, and non-exclusive license to reproduce, adapt, modify, translate, publish, publicly perform, publicly display and distribute any Content that you submit, post or display on or through, the Website.
You agree that this license includes a right for the Company to make such Content available to other companies, organizations or individuals with whom the Company has relationships in connection with the provision of the Website.You understand that the Company may (a) transmit or distribute your Content over various public networks and in various media; and (b) make such changes to your Content as are necessary to conform and adapt that Content to the technical requirements of connecting networks, devices, services or media. You agree that this license shall permit the Company to take these actions. You confirm and warrant to the Company that you have all the rights, power and authority necessary to grant the above license.
11. Software updates.
NCIT may offer proprietary software in conjunction with the Website, and it is possible that such Software may automatically download and install updates from time to time. These updates are designed to improve, enhance and further develop the Website and may take the form of bug fixes, enhanced functions, new software modules and completely new versions.
You agree to receive such updates (and permit the Company or its designee to deliver these to you) as part of your use of the Website.
12. Terminating your use of the Website
(2) the Company is required to do so by law (for example, where the provision of the Website to you is, or becomes, unlawful); or
(3) any partner or affiliate with whom NCIT offered the Website to you has terminated its relationship with the Company or ceased to offer elements of the Website to you; or
(4) the provision of the Website to you by the Company is, in the Company's sole opinion, no longer commercially viable.
13. EXCLUSION OF WARRANTIES.
YOU EXPRESSLY UNDERSTAND AND AGREE THAT YOUR USE OF THE WEBSITE IS AT YOUR SOLE RISK AND THAT THE WEBSITE IS PROVIDED "AS IS" AND "AS AVAILABLE." IN PARTICULAR, EVISOR, ITS SUBSIDIARIES AND AFFILIATES, AND ITS LICENSORS DO NOT REPRESENT OR WARRANT TO YOU THAT:
(1) YOUR USE OF THE WEBSITE WILL MEET YOUR REQUIREMENTS,
(2) YOUR USE OF THE WEBSITE WILL BE UNINTERRUPTED, TIMELY, SECURE OR FREE FROM ERROR,
(3) ANY INFORMATION OBTAINED BY YOU AS A RESULT OF YOUR USE OF THE WEBSITE WILL BE ACCURATE OR RELIABLE, AND
(4) THAT DEFECTS IN THE OPERATION OR FUNCTIONALITY OF ANY SOFTWARE PROVIDED TO YOU AS PART OF THE WEBSITE WILL BE CORRECTED.
THE COMPANY FURTHER EXPRESSLY DISCLAIMS ALL WARRANTIES AND CONDITIONS OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO THE IMPLIED WARRANTIES AND CONDITIONS OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT.
14. LIMITATION OF LIABILITY.
YOU EXPRESSLY UNDERSTAND AND AGREE THAT THE COMPANY, ITS SUBSIDIARIES AND AFFILIATES, AND ITS LICENSORS SHALL NOT BE LIABLE TO YOU FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL CONSEQUENTIAL OR EXEMPLARY DAMAGES THAT MAY BE INCURRED BY YOU, HOWEVER CAUSED AND UNDER ANY THEORY OF LIABILITY. THIS SHALL INCLUDE, BUT NOT BE LIMITED TO, ANY LOSS OF PROFIT (WHETHER INCURRED DIRECTLY OR INDIRECTLY), ANY LOSS OF GOODWILL OR BUSINESS REPUTATION, ANY LOSS OF DATA SUFFERED, COST OF PROCUREMENT OF SUBSTITUTE GOODS OR SERVICES, OR OTHER INTANGIBLE LOSS;ANY LOSS OR DAMAGE THAT MAY BE INCURRED BY YOU, INCLUDING BUT NOT LIMITED TO LOSS OR DAMAGE AS A RESULT OF:
(1) ANY RELIANCE PLACED BY YOU ON THE COMPLETENESS, ACCURACY OR EXISTENCE OF ANY ADVERTISING, OR AS A RESULT OF ANY RELATIONSHIP OR TRANSACTION BETWEEN YOU AND ANY ADVERTISER OR SPONSOR WHOSE ADVERTISING APPEARS ON THE WEBSITE;
(2) ANY CHANGES THAT THE COMPANY MAY MAKE TO THE WEBSITE, OR FOR ANY PERMANENT OR TEMPORARY CESSATION IN THE PROVISION OF THE WEBSITE (OR ANY FEATURES WITHIN IT);
(3) THE DELETION OF, CORRUPTION OF, OR FAILURE TO STORE, ANY CONTENT AND OTHER COMMUNICATIONS DATA MAINTAINED OR TRANSMITTED BY OR THROUGH YOUR USE OF THE WEBSITE;
(4) YOUR FAILURE TO PROVIDE THE COMPANY WITH ACCURATE ACCOUNT INFORMATION;
(5) YOUR FAILURE TO KEEP YOUR PASSWORD OR ACCOUNT DETAILS SECURE AND CONFIDENTIAL;
THE LIMITATIONS ON THE COMPANY'S LIABILITY TO YOU SHALL APPLY WHETHER OR NOT THE COMPANY HAS BEEN ADVISED OF OR SHOULD HAVE BEEN AWARE OF THE POSSIBILITY OF ANY SUCH LOSSES ARISING.
15. Other content
The Website includes hyperlinks and embedded frames linked to other web sites, content and resources. NCIT may have no control over any web sites, content or resources that are provided by companies or persons other than NCIT.
You understand and agree that NCIT is not responsible for the availability of any such external sites or resources, and does not endorse any advertising, products or other materials on or available from such web sites or resources.
You understand and agree that NCIT is not liable for any loss or damage that may be incurred by you as a result of the availability of those external sites or resources, or as a result of any reliance placed by you on the completeness, accuracy or existence of any advertising, products or other materials on, or available from, such web sites or resources.
Sometimes when you use the Website, you may (as a result of, or through your use of the Website) use a service, download a piece of software, or purchase goods that are provided by another person or company.
This Agreement (including the additional Legal Notices incorporated by reference) constitute the whole legal agreement between you and NCIT and govern your use of the Accredited.AM Website (but excluding any services that the Company or its affiliates may provide to you under a separate written agreement), and completely replace any prior agreements between you and NCIT in relation to the Website..