Website Usage and Privacy Policy

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General Privacy Notice

Effective Date: March 17, 2020

At Merriman we do everything we can to provide our clients with peace of mind. This privacy notice applies to all current and former clients (including prospects) who have shared information with us via our website or phone and in-person conversations. We know you have entrusted us with your financial and personal information and we are committed to safeguarding that private information.

FACTS WHAT DOES MERRIMAN WEALTH MANAGEMENT DO WITH YOUR PERSONAL INFORMATION?
Why? Financial 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:

  • Social Security number and income
  • account balances and transaction history
  • Insurance and tax information
  • risk tolerance preferences
  • Wire transfer and ACH payment instructions
  • investment experience and account transactions

When you are no longer our customer, we continue to share your information as described in this notice.

How? All financial companies need to share customer’s personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customer’s personal information; the reasons Merriman Wealth Management chooses to share; and whether you can limit this sharing.

 

Reasons we can share your personal information Does Merriman Wealth Management share? Can you limit this sharing?
For our everyday business purposes — such as to process your transactions (i.e. trades and money requests), 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 No We don’t share
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 don’t share
For nonaffiliates to market to you No We don’t share

 

Questions? Call 1-800-423-4893 or email: erick@merriman.com

 

Who we are
Who is providing this notice? Merriman Wealth Management
What we do
How does Merriman Wealth Management protect my personal information? To protect your personal information from unauthorized access and use, we use industry standard security measures that include encryption at rest and in transit for all sensitive data, strong passwords, restrictive permissions and access, security conscious processes, and a progressive training schedule for all policies and procedures.
How does Merriman Wealth Management collect my personal information?

We collect your personal information, for example, when you

  • open an account or request an initial consultation with our Advisory team.
  • tell us about your portfolio or deposit money
  • show your government-issued ID or driver’s license
  • give us your income and asset information
  • enter into an investment advisory contract

We 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 your information to market to you
  • sharing for nonaffiliates to market to you

See below for more on your rights under state law.

Definitions
Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

  • Our affiliates include Focus Operating, LLC and Focus Client Solutions, LLC.
Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

  • Merriman Wealth Management does not share with nonaffiliates so they can market to you their products or services.
Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

  • Merriman Wealth Management, LLC does not jointly market.
Other important information
If you are a California resident, California law may provide you with additional rights. You can access our California Consumer Privacy Act Notice at: http://www.merriman.com/privacy-policy/

California Personnel Privacy Notice

Effective Date: March 17, 2020

Merriman values the privacy of the sensitive information you entrust us with during your job application process.  As part of our compliance with the California Consumer Privacy Act (CCPA), we are providing you with our California Personnel Privacy Notice that outlines our data collection practices.  If you have any questions about this notice, please feel free to contact Dawn McGeorge,  dawn@merriman.com, or (206) 285-8877.

I. PURPOSE

Pursuant to the California Consumer Privacy Act (“CCPA”) (California Civil Code Section

1798.100 et seq.), this Personnel Data Privacy Notice (“Notice”) describes how Merriman Wealth Management, LLC (“Merriman,” “we,” “our,” and/or “us”) handles Personal Information regarding current and former California employees, job applicants, contractors, consultants, and officers (collectively, “Personnel”), third parties whose Personal Information is provided to us in connection with the employment or engagement relationship, and individuals who have applied for employment to or been recruited for employment by Merriman. This Notice provides examples of the types of Personal Information we collect, how we may use and share such Personal Information, and the choices available to you with respect to how we handle your Personal Information.

Where we refer to “Personnel,” “employment” or “engagement” in this Notice, we do so for convenience only and should in no way be interpreted as purporting to confer employment status on non-employees to whom this Notice also applies. This Notice does not form part of any contract of employment or engagement, does not confer any employment status or contractual right on any Personnel, or place any contractual obligation on Merriman.

II. SCOPE

This Notice applies to all California employment applicants, current and former Personnel, and their spouses, and dependents.

III. COLLECTION OF PERSONAL INFORMATION

Merriman only collects Personal Information needed to accomplish its legitimate business purposes. For example, Merriman collects:

  • Contact information, such as name, email address, mailing address, and phone number shared by you;
  • Government or national identification information, such as driver’s license number, passport number, national insurance number, social security number (including verification of it), visa status and number and work authorizations shared by you and applicable government agencies or authorities;
  • Recruitment information shared by you or an employment recruiting agency, including Personal Information contained on your employment application, resume, curriculum vitae, and cover letter, shared by your references, and included in criminal background checks, where applicable;
  • Payroll information shared by you, banking institutions and other payroll-related entities, such as banking and direct deposit forms, salary, tax forms, expense reimbursement records, and vacation and personal time off balances;
  • Benefits information shared by you, such as benefits elections, the names and other legally required information of beneficiaries, spousal, partner, and dependent information, and emergency contact information;
  • Performance information, such as performance reviews and disciplinary reports;
  • Diversity-related information shared by you, such as gender, marital status, race or ethnicity, sexual orientation, and veteran or disability status to comply with legal obligations and internal policies relating to diversity and anti-discrimination;
  • Health information shared by you or medical/wellness providers, such as medical conditions, health records, and biometric data, where necessary and appropriate to provide reasonable workplace accommodations;
  • Credit report history, subject to personnel consent;
  • Travel information shared by you or meeting/travel-related providers, such as loyalty program membership numbers, credit card numbers, and health, disability, or religiously-affiliated accommodations (e.g., ADA-compliant hotel room or specific meal requirements (i.e., diabetic, low-salt meal, or kosher)).
  • Company resource information provided by Merriman, such as use of company technology and resources, including email, instant messaging, file share and employee collaboration platforms, IT help desk, and employee training tools.
  • Other Personal Information collected for our legitimate business purposes.

Some Personal Information types listed above are considered to be “special categories” or sensitive Personal Information requiring a higher level of protection. Please note that we may collect, store, and use the following special categories of sensitive Personal Information:

  • Information about your race or ethnicity, religious beliefs, sexual orientation, political opinions, or veteran status;
  • Information about criminal convictions (misdemeanors and felonies) and legal offenses.

We collect such sensitive Personal Information as provided by you and others (e.g., medical/wellness providers, government agencies, background check providers) for specific purposes, such as health/medical information in order to accommodate a disability or illness and to provide benefits, and diversity-related Personal Information (such as gender, race or ethnicity) in order to comply with legal obligations and internal policies relating to diversity and anti-discrimination. Please be assured that we will only use such sensitive information for the purposes set out in this Notice and as provided by law.

IV. USE OF PERSONAL INFORMATION

Merriman only uses Personnel Personal Information for its legitimate business purposes, such as payroll processing, network and facility security, provision of Personnel benefits, and management of its Personnel. In some cases, Merriman may use Personal Information to pursue legitimate interests of its own or those of third parties, provided Personnel’s interests and fundamental rights do not override those interests. Situations in which Merriman processes Personal Information include:

  • Recruitment purposes, such as evaluating an application for employment, conducting interviews, contacting references, conducting background checks (when we have your consent and have extended an offer of employment), and deciding terms of an employment offer;
  • Onboarding purposes, such as establishing payroll processes, benefits enrollment, and other Personnel management services such as registration with state securities administrators and compliance monitoring of employee brokerage accounts;
  • Personnel management purposes, such as monitoring assignments, evaluating performance, training, and responding to Personnel requests, inquiries, and comments;
  • Operational purposes, such as distributing payroll and administrating benefits, updating Personnel files, conducting audits, and providing IT support and other troubleshooting; and
  • Legal and compliance purposes, such as implementing internal policies, responding to suspected fraud, illegal, or other noncompliant activity, protecting Merriman and others’ rights and property, and complying with laws, legal processes, or governmental requests. Additionally, and as permitted by applicable law, Merriman reserves the right to monitor and audit any traffic or information in its environments and managed services. As such, Personnel connecting to these environments and managed services have no expectation of privacy when using computing and information services, whether from a Merriman owned or -managed device or a personal device.

We only use Personal Information for the purposes for which it was collected, unless we reasonably consider that such Personal Information should be used for another reason and that reason is compatible with the original purpose of collection. These purposes are disclosed (or otherwise reasonably apparent) to Personnel at the time of collection. Merriman will notify its Personnel if it intends to use their Personal Information for a materially different purpose. When possible, consistent with its legitimate business purposes, Merriman offers its Personnel choices regarding the Personal Information collected and how Merriman uses or discloses such Personal Information.

If you do not wish to or cannot provide certain Personal Information requested or do not permit Merriman to use it for its stated purpose(s), we may not be able to perform certain activities (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

V. DISCLOSURE OF PERSONAL INFORMATION

Merriman may disclose Personal Information to entities within its corporate structure (e.g., its parent company, Focus Financial Partners) and to third parties (e.g., service providers) assisting Merriman in accomplishing the business purpose for which the Personal Information was collected. For example, Merriman may disclose Personal Information:

  • With employment-related vendors such as recruitment and background check providers;
  • With payroll processing vendors and providers of online HR management services, as well as providers of Personnel benefits;
  • With legal or regulatory authorities to comply with our obligations, to protect the rights and property of Merriman Personnel, our clients, and the public, and to detect and respond to suspected illegal activity and threats to the safety of any person or of our systems or services;
  • With public authorities responsible for public safety, law enforcement, or national security; and
  • With your consent and at your direction in situations not related to your official employment or engagement with Merriman.

VI. SECURITY OF PERSONAL INFORMATION

Where Merriman discloses Personal Information to third parties, it does so for the same business purposes described below and where appropriate, requires that such parties maintain its confidentiality and maintain appropriate systems and processes to ensure its security and protection. Merriman encrypts Personal Information transmitted to third parties consistent with its Information Technology policies and procedures.

VII. NO SALE OF PERSONAL INFORMATION

In the preceding 12 months, Merriman has not sold, nor will it sell, any Personal Information. The firm does share information with other entities as described in Section V of this notice.

CONTACT US

If you have questions or concerns regarding this Notice, please contact Dawn McGeorge at: 1-800-423-4893 or dawn@merriman.com.

California Consumer Privacy Act Privacy Notice for California Residents

Effective Date: March 17, 2020

This Privacy Notice applies only to website visitors, prospective clients, and current clients that are California residents.  It outlines our data collection practices, purposes for them, and your rights as a California resident.  If you have any questions about this notice, please feel free to contact Erick Aguayo, erick@merriman.com or (206) 285-8877.

We provide this privacy notice (“Notice”) to comply with the California Consumer Privacy Act of 2018 (“CCPA”)  This Notice applies to California residents (“California residents” or “you”) who engage with us in connection with obtaining or seeking to obtain our service (collective, the “Services”). It supplements the privacy policies of Merriman Wealth Management, LLC and its affiliate, Leveraged Global Opportunity Fund, L.P. (“Merriman,” “we,” or “us”).

This Notice describes how we collect, use, and disclose 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 (“Personal Information”).  Personal Information does not include aggregate or de-identified information or publicly-available information from government records.

YOUR CCPA RIGHTS

If you are a California resident, you have the rights related to your Personal Information including: (1) to request more information about the categories and specific pieces of Personal Information we have collected and disclosed for a business purpose in the last 12 months, (2) to request deletion of your Personal Information, and (3) to not be discriminated against for exercising these rights. You may make these requests by calling 1-800-423-4893 or contacting Erick Aguayo: erick@merriman.com.

We will verify your request by matching information you have previously provided to us to information you provide as part of your request.  You have the right to request that an agent submit a request to exercise your rights on your behalf.  We require that your agent provide a notarized statement from you authorizing your agent to take the requested action. We reserve the right to contact you directly if we have any questions or concerns about the agent’s submission.

Merriman Wealth Management does not sell your Personal Information. Information about how to exercise your rights is provided below.  The CCPA includes exceptions and exemptions that will limit your ability to exercise your CCPA rights for certain types of Personal Information.  We will not discriminate against you if you exercise your rights under the CCPA.

RIGHT TO KNOW

Under the CCPA, you have the right to request more information about the Personal Information we have collected about you during the past 12 months and what categories of Personal Information we have shared with unaffiliated third parties.

Collection of Personal Information

  • Information You Provide to Us: We collect information you provide directly to us.  For example, we collect information when you apply for or request information related to our investment and wealth management advisory services, fill out a form, engage the Firm, communicate with us via third party social media sites, request client assistance, or otherwise communicate with us.  The types of information we may collect include your name, email address, postal address, phone number, financial account details, government–issued identifiers, income and asset information, beneficiary information, and any other information you choose to provide such as employment and insurance information.
  • Other Information We Collect When You Use our Services: When you access or use our Services or transact business with us, we automatically collect information about you, including:
    • Usage Information: We collect information about your use of the Services, such as the information and documentation you upload, etc.
    • Transactional Information about our Engagement: When you engage us, we collect information about the terms of our Services, our fees and your expectations.
    • Log Information: We collect information related to your access to and use of the Services, including access times, pages viewed, and your IP address.
    • Location Information: We may derive the approximate location of your device from your IP address.
  • Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use different technologies to collect information, including cookies and web beacons.  Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits.  Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness.
  • Google Analytics: We use Google Analytics for aggregated, anonymized website traffic analysis. In order to track your session usage, Google drops a cookie (_ga) with a randomly-generated ClientID in your browser. This ID is anonymized and contains no identifiable information like email, phone number, name, etc. We also send Google your IP Address. We use Google Analytics to track aggregated website behavior, such as what pages you looked at, for how long, and so on. This information is important to us for improving the user experience and determining site effectiveness. If you would like to access what browsing information we have – or ask us to delete any Google Analytics data – please delete your _ga cookies, reach out to us via this form, and/or install the Google Analytics Opt-Out Browser Add-On.

Use of Information

We use the information we collect:

  • To provide the investment advisory services you have requested;
  • To protect the security and integrity of our systems, networks, applications, and data, including detecting, analyzing, and resolving security threats, and collaborating with cybersecurity centers, consortia, and law enforcement about imminent threats;
  • To enforce our contracts and to protect against injury, theft, legal liability, fraud, or abuse, and to protect people or property, including physical security programs;
  • To classify Personal Information or create aggregated datasets, such as for consolidating reporting, research, or analytics;
  • For identity and credential management, including identity verification and authentication and system and technology administration;
  • For fraud detection and prevention;
  • For legal and regulatory compliance, including all uses and disclosures of Personal Information required by law or reasonably needed for compliance with our policies and procedures, such as: money request verifications, security and incident response programs, intellectual property protection programs, and corporate ethics and compliance hotlines procedures;
  • For corporate audit, analysis, and reporting;
  • For business continuity and disaster recovery purposes; and
  • For corporate governance, including mergers, acquisitions, and divestitures.

Sharing of Information

We may share information about you as follows or as otherwise described in this Notice:

  • With vendors, service providers (i.e. custodians, portfolio management, and client relationship management systems), and professional advisors that perform services for us, including accountants, tax planners, and attorneys;
  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
  • If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of Merriman or others;
  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
  • Between and among Merriman and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
  • In other manners with your consent or at your direction.

We may also share aggregated or de-identified information that cannot reasonably be used by those third parties to identify you.

RIGHT TO ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY

Under the CCPA, you have the right to request that we disclose the following to you:

  • The categories of Personal Information we collected about you.
  • The specific pieces of Personal Information we collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • The business or commercial purpose for collecting that Personal Information.
  • The categories of third parties with whom we share that Personal Information.

Once we receive and confirm your verifiable access request, we will disclose the requested information covering the preceding 12 months, unless an exception applies.

RIGHT TO DELETE

Under the CCPA, you have the right to request that we delete your Personal Information.  Once we receive and confirm your verifiable deletion request, we will delete or de-identify (and direct our service providers to delete or deidentify) your Personal Information from our records unless an exception applies or retaining your Personal Information is necessary for us or our service providers to:

  • Comply with a legal or regulatory obligation.
  • Provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for such activities.
  • Debug software to identify and repair errors that impair existing intended functionality.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

HOW TO EXERCISE YOUR CCPA RIGHTS

If you are a California resident, you may exercise your CCPA-provided rights described above by either:

We are not obligated to respond to more than two access requests for the same individual’s personal information within a 12-month period.

VERIFICATION OF CONSUMER REQUESTS

Each verifiable consumer request must provide sufficient information to allow us to reasonably verify that you are the person about whom we collected Personal Information or an authorized agent.  We cannot respond to your request if we cannot verify and confirm your identity or authority to make the request.

RESPONSE TIMING AND FORMAT

We intend to respond to a verified consumer request within 45 days of our receipt. If we require additional time to respond, we will inform you of the reason for additional time needed and anticipated timing for our response.  Our response will also explain why we cannot comply with your request, if applicable.

SHINE THE LIGHT

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes.  The Firm does not share Personal Information with third parties for their direct marketing purposes.

CONTACT US 

You are encouraged to review this Notice regularly, as we may change it from time to time.  If we make changes, we will notify you by revising the date at the top of the Notice and, in some cases, provide you with additional notice (such as adding a statement to our website homepage or sending you a notification).

If you have any questions about this Notice, please contact:

Erick Aguayo, Chief Compliance Officer

Merriman Wealth Management, LLC

800 5th Ave Suite 2900 | Seattle, WA 98104

erick@merriman.com

1-800-423-4893 (Toll-Free) | 1-206-257-2042 (Fax)

 

APPENDIX 1

Merriman Wealth Management, LLC | Categories of Data Collected

The below table lists the categories of Personal Information Merriman Wealth Management, LLC (“Merriman” or “the Firm”) may collect about its clients, including examples of information that fall within each category. For each category, we have also provided the categories of sources from which the information was collected, the purposes of collection and use, and the categories of third parties with whom we will share such data.  To learn more about how Merriman uses your data and your choices, please see our CCPA Privacy Notice for California Residents.

Category of Personal Information Collected Categories of Sources of Personal Information Business or Commercial Purposes for Collection and Use of Personal Information Categories of Third Parties with Whom Personal Information is Shared

Identifiers, such as:

  • Full name, nicknames, or previous names (such as maiden names)
  • Mailing address(es)
  • Email address(es)
  • Phone number(s)
  • Contact information for related persons, such as authorized users of your account
  • Social Security or other taxpayer identification numbers
  • Federal and state issued identification numbers
  • Client ID
  • Account number(s)

For security purposes, we will not disclose these identifiers in response to an access request under the CCPA.

  • You
  • Other clients (in your household)
  • Service Providers
  • Social media
  • Provide advisory or business management services
  • Maintain the integrity of our records
  • Security and risk management, fraud prevention, and similar purposes
  • Develop, provide and improve our products and services
  • Provide client service
  • Perform our contractual obligations
  • Maintain our ongoing business relationship
  • Create and manage your account(s)
  • Send personalized communications and notifications related to your transactions and account
  • Respond to your communications
  • Communicate with you about products, services and events that may be of interest to you
  • Corporate affiliates such as Focus Financial Partners
  • Service providers
  • Professional advisors including lawyers, auditors, consultants, and others who provide professional services to the Firm
  • Law enforcement officials and individuals involved in legal proceedings
  • U.S. Postal Service and other couriers
  • Social media companies using information only to identify which clients use such platform(s) so we can deliver ads to you on such platform(s)
  • Other third parties with your consent or at your direction

Financial Information, such as:

  • Bank account number(s) and details
  • Your account numbers at other financial institutions

 

  • You
  • Service providers

 

  • Maintain our business relationship with you, including processing purchases and sales of securities in your accounts
  • For recordkeeping and compliance, including dispute resolution
  • For internal business purposes, such as finance, audits, training, reporting, and analytics
  • Service Providers including payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention
  • Professional advisors including lawyers, auditors, consultants, and others who provide professional services to the Firm
  • Other unaffiliated parties (including government agencies) as required by law

Commercial Information, such as:

 

  • Client account information, transaction history, and related records (such as records of real estate purchases and sales of securities)
  • Records related to website and mobile application usage
  • Non-biometric data collected for client authentication (passwords, account security questions)
  • Client service records
  • You
  • Other financial institutions involved in processing your transactions (for example, your bank)
  • Automatically, such as when you use our websites or mobile applications

 

  • To maintain our business relationship with you, including client service
  • For recordkeeping and compliance, including dispute resolution
  • For internal business purposes, such as finance, quality control, training, reporting, and analytics
  • For risk management, fraud prevention, and similar purposes
  • Service providers as needed to complete the transaction, including mailing and delivery providers and print vendors
  • Professional advisors including lawyers, auditors, consultants, and others who provide professional services to the Firm
  • Other unaffiliated parties (including government agencies) as required by law

 

Internet or Electronic Network Activity Information, such as:

 

  • IP address
  • Advertising ID
  • Web server logs
  • Browsing data and search history on the firm’s managed websites
  • Third-party cookies
  • Pixel tags
  • You and from your devices when you interact with our websites and mobile applications.  For example, when you visit our websites, our server logs record your IP address and other information.
  • Automatically, via technologies such as cookies and web beacons, when you visit our websites or mobile applications
  • Service providers, including advertising technology providers
  • For system administration and technology management, including optimizing our websites and applications
  • For recordkeeping and reporting, including logs and records maintained as part of transaction and interaction information
  • For metrics and analytics
  • For online targeting and advertising purposes
  • To track your use of our products, services, websites, and online services, including for targeted ad delivery.

 

  • Third party social media providers
Geolocation Data, such as general geographic location (for example, city, state, and zip code)
  • IP address when you use our online services
  • You

 

  • For our business purposes

 

  • Professional advisors including lawyers, auditors, consultants, and others who provide professional services to the Firm
  • Other unaffiliated parties (including government agencies) as required by law

Audio, electronic, visual, thermal, olfactory, or similar information, such as:

 

  • Video images
  • Call monitoring records
  • Voicemails
  • You
  • Automatically, such as when we record calls in our phone system.

 

  • For internal business purposes, such as call recordings used for training, coaching, or quality control
  • For relationship purposes, such as the use of photos and videos for social media purposes (with your consent)
  • Prospects and clients (only applicable to photos provided with your consent).
  • Other unaffiliated parties (including government agencies) as required by law
Professional, educational, or employment-related information, such as job title, employer name and industry, and date of hire.
  • You
  • Your employer(s)

 

  • To establish and maintain our business relationship with you, including processing purchases and sales of securities in your accounts
  • For recordkeeping and compliance

 

  • Professional advisors including lawyers, auditors, consultants, and others who provide professional services to the Firm
  • Other third parties (including government agencies) as required by law

 

Other information that relates to or is reasonably capable of being associated with you, such as:

 

  • Child’s name, date of birth, address, Social Security number or other taxpayer identification number, educational information (if account assets are used to pay education expenses directly to an educational institution)
  • Personal characteristics and preferences, such as your age, marital and family status, and languages spoken
  • Household demographic data, including from real estate records and census data
  • Data from public social media profiles, such as LinkedIn, and similar platforms
  • Hobbies and interests
  • We do not collect Personal Information directly from children under 16. We receive limited Personal Information about children from clients (parents and other adults) only as required to establish and maintain accounts for the children’s benefit
  • Unaffiliated parties that provide access to information you make publicly available, such as social media

 

 

 

  • To provide the information, products, or services requested by the child’s parent or other authorized adult
  • To better understand you and to understand our clients generally
  • To design products, services, and programs that may be of interest to our clients
  • To identify prospective clients
  • For internal business purposes, such as quality control, training, and analytics
  • Professional advisors including lawyers, auditors, consultants, and others who provide professional services to the Firm
  • Other third parties (including government agencies) as required by law