“Data Subject”: Apex’s clients, prospective clients, advisors, and prospective advisors
“Personal Information”: any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Data Subject or household.
“Process”: any operation or set of operations that are performed on personal information or on sets of personal information, whether or not by automated means.
Apex may process the following categories of personal information:
- Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers;
- Signature, physical characteristics or description, telephone number, employment, employment history, bank account number, credit card number, debit card number or any other financial information;
- Characteristics of protected classifications under California or federal law;
- Commercial information, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history and information regarding a Data Subject’s interaction with an internet website, app or advertisement;
- Geolocation data;
- Audio, electronic, visual, or similar information;
- Professional or employment-related information;
- Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act; or
- Inferences that could be drawn from the above to build a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
IV. HOW WE COLLECT YOUR PERSONAL INFORMATION
PERSONAL INFORMATION RECEIVED FROM YOU
You may provide Apex with your personal information by filling out forms that we request from you; sending us documents; through our website; through our hosted online portals; or through our correspondence with you via mail, email, phone, or otherwise.
PERSONAL INFORMATION RECEIVED FROM THIRD-PARTY SOURCES
Apex may collect your personal information from other sources such as, but not limited to, publicly available databases, know-your-client checking agencies, background checking agencies, third-party hosted online portals, or our website.
APEX’S PROCESSING ACTIVITIES
- To improve customer service
- To send periodic emails
- The email address you provide may be used to send you information, respond to inquiries, and/or other requests or questions during the normal course of Apex’s business
- Gathering Personal Information from publicly available sources to conduct research and outreach on behalf of clients
- To provide Apex clients with targeted advisor recommendations
- For other business-related purposes
CHANGE OF PURPOSE
We will only process your personal information for the purpose it was originally collected for or for another reason that relates to the original purpose. If you wish to get an explanation on how another reason can relate to the original purpose, please contact us at email@example.com.
If we need to process your personal information for a new purpose, we will notify you prior to processing your personal information for the new purpose and explain the legal basis that allows us to do so. If consent is required to process your personal information for a new purpose, we will contact you to obtain your consent prior to processing your personal information.
VI. SHARING YOUR PERSONAL INFORMATION WITH OTHERS
Privacy is an integral part of our organization and we will never sell any of your personal information to third parties. We may share your personal information with third parties for the below stated purposes.
We may share your personal information to authorized service providers for fund administration, customer relationship management, risk management, IT, data backup, payroll, insurance, tax, accounting, audit, legal, background checking, secretarial, or other related purposes.
We require all service providers to respect the security of your personal information and to treat it in accordance with their legal or regulatory requirements. We only permit our service providers to process your personal information for specified purposes and in accordance with our instructions.
SALE OF BUSINESS
We may share your personal information to a third party in the event of any contemplated or actual re-organization; merger; sale; joint venture; assignment; transfer; or other disposition of all or any portion of our business, assets, or stocks.
We may share your personal information as we deem necessary or as appropriate under applicable laws; to respond to requests from public, governmental, and regulatory authorities; to comply with court orders, litigation procedures, and other legal processes; to obtain legal remedies or limit our damages; to protect the operations of our group entities; and to protect the rights, safety, or property of our employees, you, or others.
Apex has technical, administrative, and physical safeguards in place to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Please contact us at firstname.lastname@example.org for more information on the Firm’s security practices and procedures.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date. A session cookie will expire at the end of the user session when the web browser is closed.
COOKIES THAT WE USE
- Authentication: to identify you when you visit our website and as you navigate our website
- Status: to help us to determine if you are logged into our website
- Personalization: to store information about your preferences and to personalize the website for you
- Security: to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally
- Advertising: to help us to display advertisements that may be relevant to you
- Analysis: to help us to analyze the use and performance of our website and services
Most browsers allow you to refuse to accept cookies and to delete cookies. Disabling all cookies may have a negative impact upon the usability of many websites. If you disable cookies, you may not be able to use all the features on our website. For information on how to disable cookies, please visit the Help/Settings section of your web browser.
IX. THIRD-PARTY WEBSITES & SERVICES
X. AUTOMATED DECISION-MAKING
We do not use computer algorithms to automate decisions based on your personal data.
XI. YOUR RIGHTS & REQUESTS
Under applicable privacy laws or regulations, you may have the following rights in relation to your personal information:
- Right to access your personal information or request information regarding your personal information
- Right to request erasure of your personal information
- Right to withdraw your consent to the processing of your personal data
- Right to object to processing of your personal data for any purpose
- Right to request correction of your personal data
- Right to restrict processing your personal data
- Right to request transfer of your personal data
- Right to lodge a complaint with a supervisory authority
- Right to data portability/receive the personal information that you provided to us in a structured, commonly used, and machine-readable format, and have the right to receive such data without hindrance from us
EXERCISING YOUR RIGHTS
If you would like to request information about our processing activities with respect to your personal information or would like to exercise your rights, as described in the Rights section, you may contact us email@example.com. Apex does not charge for this service. For your protection, we will need to verify your identity prior to complying with your request.
Apex will make a good faith effort to provide you with the requested information without undue delay, but no later than required by law. Apex reserves the right to limit or deny access to the requested information where providing such information would be unreasonably burdensome or expensive, or as otherwise permitted under relevant laws or regulations. If Apex determines that the requested information cannot be provided in any particular instance, Apex will provide the requestor with an explanation for why the information cannot be provided.
XII. AMENDMENTS TO THIS PRIVACY NOTICE
1109 W. Main St, Suite #500
Boise, ID 83702
Apex Leaders 2020-2021