CALIFORNIA CONSUMER PRIVACY ACT DISCLOSURE
Last updated January 1, 2020
This California Consumer Privacy Act Disclosure explains how Signature Intelligent Portfolios, LLC will collect, use, and disclose personal information relating to California residents covered by the California Consumer Privacy Act (“CCPA”). This notice is provided pursuant to the CCPA.
Under the CCPA, ‘Personal Information’ is information that identifies, relates to, or could reasonably be linked directly or indirectly with a specific California resident. The CCPA, however, does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act (“GLBA”).
The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on our relationship or interaction with that individual. This Disclosure does not apply with respect to information that we collect about California residents as part of an application for financial services or when obtaining our financial services for personal, family, or household purposes. For more information about how we collect, disclose, and secure information relating to these customers, please refer to our Privacy Notice.
Keeping Personal Information secure is one of our most important priorities. Consistent with our obligations under applicable laws and regulations, we maintain physical, technical, electronic, procedural and organizational safeguards and security measures that are designed to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access, whether it is processed by us or elsewhere.
COLLECTION AND DISCLOSURE OF PERSONAL INFORMATION
In the past 12 months, we have collected, and disclosed to third parties for our business purposes, the following categories of Personal Information relating to California residents covered by this disclosure:
- Information we receive from you on account applications, which include identifiers, such as name, address, date of birth, occupation, financial goals, and government-issued identifier (e.g., Social Security number);
- Information about your transactions with us, our affiliates, or others;
- Personal information, as defined in the California safeguards law, such as contact information and financial information;
- Characteristics of protected classifications under California or federal law, such as sex and marital status;
- Commercial information, such as transaction information and purchase history;
- Professional or employment-related information, such as work history and prior employer;
- Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.
The categories of sources from whom we collected this Personal Information are:
- Directly from a California resident or the individual’s representatives
- Service Providers, information from our affiliates and other third parties
- Public Record Sources (Federal, State or Local Government Sources)
- Website and Social Media
- Information from Client Directed Third Parties or Institutions representing a Client/Prospect
- Information from Corporate Clients about individuals associated with the Clients (e.g., an employee or board member)
The categories of third parties to whom we disclosed Personal Information for our business purposes described in this privacy disclosure are:
- Affiliates and Subsidiaries of Signature Intelligent Portfolios, LLC.
- To entities that perform services for us or function on our behalf, including financial service providers, custodians, broker dealers, investment companies, or insurance companies.
- To your attorney, trustee or anyone else where you have given written permission to share information.
- To our attorneys or auditors.
- To government entities or other third parties in response to subpoenas or other legal process as required by law or to comply with regulatory inquiries. Signature Intelligent Portfolios, LLC does not sell customer lists or customer information to third parties.
- Vendors and Service Providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology, supervisory analysis, customer service, email delivery, auditing, marketing and marketing research activities.
- Partners and Third Parties who provide services such as payment, communication infrastructure, storage, legal expertise, tax expertise, notaries and auditors, who analyze the financial services and products to customers and other prospective buyers.
USE OF PERSONAL INFORMATION
In the past 12 months, we have used Personal Information relating to California residents to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including the following:
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services.
- To protect your accounts from unauthorized access or identity theft. For example, detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity.
- Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the business.
- To establish or maintain an account with an unaffiliated third party, such as a clearing broker-dealer.
- Complying with laws and regulations and to comply with other legal process and law enforcement requirements which includes any internal policy based on or reflecting legal or regulatory guidance, codes or opinions.
SALE OF PERSONAL INFORMATION
In the past 12 months, we have not “sold” Personal Information, including Personal Information of minors under the age of 16. For purposes of this Disclosure, “sold” means the disclosure of Personal Information to a third-party for monetary or other valuable consideration.
RIGHTS UNDER THE CCPA
If you are a California resident, you have the right to:
- Request we disclose to you free of charge the following information covering the 12 months preceding your request:
- the categories of Personal Information about you that we collected;
- the categories of sources from which the Personal Information was collected;
- the purpose for collecting Personal Information about you;
- the categories of third parties to whom we disclosed Personal Information about you and the categories of Personal Information that was disclosed (if applicable) and the purpose for disclosing the Personal Information about you; and
- the specific pieces of Personal Information we collected about you;
- Request we delete Personal Information we collected from you, unless the CCPA recognizes an exception; and
- Be free from unlawful discrimination for exercising your rights under the CCPA.
We will acknowledge receipt of your request. We will then seek to verify your identity. Requests for specific pieces of Personal Information will require additional information to verify your identity.
If you submit a request on behalf of another person, we may require proof of authorization and verification of identity directly from the person for whom you are submitting a request.
In some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we will not honor your request where an exception applies, such as information covered by GLBA or where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that we maintain about you is not subject to the CCPA’s access or deletion rights.
We will advise you if we are not able to honor your request. We will not provide social security numbers, driver’s license numbers or government issued identification numbers, financial account numbers, health care or medical identification numbers, account passwords or security questions and answers, or any specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft or fraud or unreasonable risk to data or systems and network security.
We will work to process all verified requests within 45 days pursuant to the CCPA. If we need an extension for up to an additional 45 days in order to process your request, we will provide you with an explanation for the delay.
HOW TO EXERCISE YOUR RIGHTS
If you are a California resident, you may submit a request by:
- Completing the Personal Information Request Form and emailing the completed form to firstname.lastname@example.org
- Calling (800) 723-5115
QUESTIONS OR CONCERNS
You may contact us with questions or concerns about this Disclosure and our practices by:
- Writing us at:
Signature Intelligent Portfolios, LLC
2121 Avenue of the Stars, Suite 1600
Los Angeles, CA 90067
- Emailing us at:
CHANGES TO THIS CALIFORNIA CONSUMER PRIVACY ACT DISCLOSURE
We may change or update this Disclosure periodically. Each update will be reflected via the “Last Updated” date.