Last updated: November 2018
For this Notice, a Customer is an individual who by signing our Investment Advisory Agreement or other document has enabled to provide advice.
Information the Firm Collects
If you choose to become a Customer the information we collect from you includes information regarding age, family, income and tax bracket, we will ask you for certain nonpublic personal identifying information (“Personal Information”) including, but not limited to, your name, address, social security number, date of birth, and employment status.
You may choose not to provide any of this above information, however you cannot become a Customer without providing it.
Use of Information
We store, process and maintain data related to you in order to provide client support, offer new products or services and to provide our online services to Customers in accordance with applicable laws and regulations.
Information the Firm Discloses
FWP does not disclose the nonpublic personal information it collects about you to anyone except:
- to the Broker who will act as Custodian for the Customer Account;
- our attorneys, accountants, and auditors; or
- as otherwise required to do so by law.
We will disclose your Personal Information where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Platform.
Security of Information
We restrict access to customers’ Personal Information to those persons who need to know that information in order to service your account. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards. In furtherance of such safeguards, we have adopted a policy.
Do Not Track Disclosure
We support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
We may employ third party companies and individuals to facilitate services.
Insofar as these third parties have access to your Personal Information, it is only to perform specific tasks on our behalf and they are obligated not to disclose or use your information for any other purpose.
We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
Your information, including Personal Information, may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your home jurisdiction.
Links to Other Sites
We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
Our website is not to be used by anyone under the age of 18 and, as such does not knowingly collect Personal Information from anyone under the age of 18. If you are under the age of 18, please do not submit any Personal Information to us. If you are a parent or guardian and have become aware that your child under the age of 18 has provided us with personally identifiable information without your consent, please contact us at firstname.lastname@example.org and we will delete such information from our files.
Our policy about obtaining and disclosing information may change from time-to-time. In all such instances, we will provide you with notice of any material change to this policy before implementing the change.