Last updated: October 2020
Smartleaf Asset Management, LLC (“SAM”) respects your right to privacy. We are proud of our privacy practices and want our current and prospective customers to understand what information we collect and how we use it.
We gather information about you and your accounts so that we can (1) know who you are and thereby prevent unauthorized access to your information, (2) design and improve the products and services we offer and (3) comply with the laws and regulations that govern us. In providing financial services and products to you, we collect certain non-public personal information about you. Our policy is to keep this information strictly safeguarded, and to use or disclose it only as needed to provide services to you, or as required by law.
The non-public personal information we may have about you includes what you provide to us when opening an account or communicating with us. We may collect the following types of non-public personal information about you:
We collect nonpublic personal information about clients such as you from the following sources:
We keep track of users coming to our website using Google Analytics, Google Tag Manager, HubSpot. These services allow us to analyze our website traffic and help us make decisions to better serve our visitors. This information includes general demographics such as the region you are located in and the type of technology you use to access the site. We do not use 3rd-party cookies to track you on websites outside of our domain.
We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as required by law. Moreover, we will not release information about our customers or former customers unless one of the following conditions is met:
We only use information about you and your account to help us better serve your investment needs or to suggest services or educational materials that may be of interest to you. We may share aggregate non-personally-identifiable information with interested third parties to assist them in understanding the usage patterns for certain content, services, advertisements, promotions, and/or functionality.
We will retain your non-public personal information for as long as your account is active or as needed to provide you services, or as required by law. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may also use aggregate non-personally identifiable information to calculate aggregate investment performance for marketing and internal purposes.
Confidentiality & Security SAM has procedures in place that we believe are reasonably designed to protect the security and confidentiality of your information. These include confidentiality agreements with companies we hire to help us provide services to you, password-protected user access to our computer files and strict confidentiality policies that apply to all SAM personnel.
We maintain physical, electronic and procedural safeguards to guard your personal account information. We also restrict access to your personal and financial data to authorized SAM associates who have a need for these records. We require all non affiliated organizations to conform to our privacy standards and are contractually obligated to keep the information provided confidential and used as requested. Furthermore, we will continue to adhere to the privacy policies and practices described in this notice even after your account is closed or becomes inactive.
No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission of information, we make commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. By using this website or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of this website. We may post a notice on the website if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach (or to withdraw your consent from receiving electronic notice) you should notify us via email at firstname.lastname@example.org.
We will never knowingly request personally identifiable information from anyone under the age of thirteen (13). No part of the Site is directed to persons under thirteen). IF YOU ARE UNDER THIRTEEN YEARS OF AGE, THEN PLEASE DO NOT USE OR ACCESS THE SITE AT ANY TIME OR IN ANY MANNER. Any person who provides their personal information to SAM through the SAM website represents that they are thirteen years of age or older.
We will continue to conduct our business in a manner that conforms with our pledge to you, your expectations and all applicable laws.
We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify active clients by email or by means of a notice on our home page prior to the change becoming effective.