EFFECTIVE DATE – January 28, 2011
YOUR PRIVACY IS IMPORTANT TO US
At Pactolus LLC (“Pactolus”), we recognize the importance of protecting your privacy. We strive to maintain the privacy of your personal, non-public information while we help you achieve your financial objectives. The following disclosure explains what non-public personal information we collect about you, why we collect it, what we do with that information, and the steps we have put in place to protect the non-public personal information that you have entrusted to us.
INFORMATION WE COLLECT
To serve you better and to manage our business, it is important that we collect and maintain accurate information about you. We collect non-public personal information about you, including, your name, address, social security number, and financial information, from the following sources:
- From you on the telephone, in person, or through mail;
- From you on applications or other forms you complete;
- Through transactions in your accounts with us, our affiliates, or others;
- From our web site; and
- From third parties with whom we deal, such as a consumer reporting agency, to verify information we receive from you about your creditworthiness.
PROTECTING YOUR INFORMATION
We restrict access to your nonpublic personal information to those employees and agents who need access to the information to perform their job functions or provide products or services to you. We protect your nonpublic personal information from access by third parties by maintaining physical, electronic, and procedural safeguards. We strive to ensure the protection of client personal information from receipt through destruction.
INFORMATION WE DISCLOSE TO THIRD PARTIES
We do not disclose any of your non-public personal information to non-affiliated third parties without your consent except as required or permitted by law or unless those parties are providing services or support to us and have agreed to keep your nonpublic personal information confidential. Examples of these parties include the companies or individuals we use to (a) execute and clear our securities transactions, (b) prepare and mail your account statements, (c) help us verify information, including identity, (d) provide us with consulting, legal, and accounting services, (e) help us develop, operate, and maintain our services and systems, and (f) provide services and products to you, such as mutual fund companies, investment management program sponsors, investment managers and advisers, and insurance companies. Even if you cease to transact business with us, we will continue to apply the same protections to your nonpublic personal information as we did when you were an active client.
POLICY REGARDING ONLINE INFORMATION
OUR DISCLOSURE POLICIES
Pactolus does not sell, rent, exchange or otherwise disclose any information we collect about our site visitors. We will, however, comply with law enforcement requests for information that follow appropriate legal standards and procedures.
OUR RETENTION POLICIES
Email addresses submitted to subscribe to mailings lists are retained until you remove your name from the mailing list. Copies of mailing lists may be retained for backup storage. In the event that we experience technical difficulties that cause us to revert to a backup copy of a mailing list, and in the unlikely circumstance that the backup list does not include the most recent changes, our systems may restore your address to a mailing list, and you may be required to remove your address a second time.
Any information you provide to us via email or through feedback forms on our Web site (as well as responses, if any, to your inquiry or comment) may be retained indefinitely.
WHAT INFORMATION DOES PACTOLUS AUTOMATICALLY COLLECT WHEN YOU VISIT OUR WEBSITE?
When you visit our Web site, we will record the following information about you in our log files:
- Internet Protocol (IP) address;
- Browser type, version, and operating system;
- URL of the page that directed you to our site;
- Whether you have bookmarked our Web site on your Web browser (only for Internet Explorer users);
- The web pages within our site that you visit;
- The amount of time you spend during a visit to our site;
- The time and date of your site visit; and,
- Search terms used in searches on our web site.
HOW DO WE USE THE INFORMATION YOU SHARE WITH US?
Except as noted here, Pactolus uses information that you share with us only for internal purposes. Specifics types of information include:
- Mailing Lists – If you submit your email address to be added to a mailing list, we will use the email address for the sole purpose of sending you announcements and news bulletins.
- Feedback and Emailing Us – We use your feedback to improve our site and our organization. If you choose to provide information about yourself using a feedback or email form on our Web site, we will not use the information for any purpose other than to respond to your inquiry or to act on your suggestion or comment. We will not share your information with others except with your permission or upon your request.
WHAT INFORMATION IS COLLECTED BY THIRD PARTIES ON OUR WEBSITE?
None of the third-party media features on our Web site will collect information about you unless you actively click on them (for example, choosing to log in to a third party website such as www.fidelity.com) . As other organizations’ privacy policies may differ from those of Pactolus and you should examine their policy prior to taking advantage of these links.
WHAT IF I HAVE CONCERNS OR WANT TO KNOW WHAT INFORMATION YOU HAVE COLLECTED ON ME?
Feel free to contact us at firstname.lastname@example.org to ask us to disclose to you any information we have about you. You have the right to correct, update, or delete information that we may have about you.
IF YOU HAVE ANY CONCERNS ABOUT THIS POLICY, PLEASE CONTACT:
8614 Westwood Center Drive, Suite 620