Innovia Wealth Website Privacy Policy
This Privacy Policy is designed to help you understand how Innovia Wealth (“Innovia”) and its related organizations and affiliates, (collectively, “we”, “us” or “our” and “Innovia”), collects, uses and shares personal information collected through this website. We value your privacy, and we will not share your personal information with third parties except as described in this Privacy Policy without your consent.
By using THIS website, you agree to be bound by this Privacy Policy. If you do not agree with any of the terms of the Privacy Policy, please do not use THIS website OR PROVIDE US WITH YOUR INFORMATION.
What this Privacy Policy Covers
This Privacy Policy applies to our collection, use and sharing of your personal information (a) when you visit our website at www.innoviawealth.com (the “Site”), (b) receive our communications or participate in our online or offline activities or events, (c) fill out an application or a request for information, and (d) that we obtain from third parties such as resellers, database vendors, content publishers and suppliers.
This Privacy Policy applies only to information gathered as described above and does not apply to any other information or websites not owned or operated by Innovia or information collected by Innovia by other means, and the information you provide may also be subject to additional terms. For example, the information we collect about you if you engage us to provide investment services is subject to additional terms detailing how we use and share your information as your financial adviser, which can be found here.
PERSONAL INFORMATION WE COLLECT
HOW WE USE YOUR PERSONAL INFORMATION
HOW WE SHARE YOUR PERSONAL INFORMATION
OTHER IMPORTANT PRIVACY INFORMATION
CHANGES TO THIS PRIVACY POLICY
Personal Information We Collect
Information You Give Us. Personal information you may provide through the Site or otherwise communicate to us includes:
- Contact information. We collect information about you when you provide contact information to us via email or through the Site, including as a result of creating an account. This information may include your first and last name, email address, mailing address, phone number, and credit card information.
- Sensitive personal information. If you are a client using our client portal, we will collect certain information that may be considered sensitive, such as your county of citizenship, race, gender, financial information, and social security number.
- Feedback and correspondence. We may collect information about you when you request information, respond to surveys, or otherwise correspond with us.
- Other information. We may collect other information from you that is not specifically listed here. We may use such information in accordance with this Privacy Policy.
Information We Get From Others. We may obtain additional information about you from third party sources, such as service providers, vendors, social media sites, and advertising agencies to provide you with more relevant information about our services.
Information Automatically Collected. Our servers and third-party service providers may automatically record certain information about how you use the Site, such as your Internet Protocol (IP) address, device and browser type, operating system, DNS, the pages or features of the Site that you browsed and the time spent on those pages or features, the frequency with which you use the Site, the links that you click on or use, and other statistics. We collect this information in server logs and by using cookies and similar tracking technologies. See our Cookie Policy, below. for more information.
Statistical Analyses. We use Google Analytics to help us gather statistical information about the visitors to our Site and how they use the Site on an anonymous, aggregate basis. However, we will not associate this data with your personally identifiable data unless required to do so to cooperate with law enforcement activity or other governmental request or to comply with law. We may use this information to gain a better understanding of the users of our Site, to improve our Site, and to improve our services. Depending on the type of browser and device that you use, you may have the ability to control the type of information that Google Analytics use. To understand how Google Analytics collects and processes data, please visit www.google.com/policies/privacy/partners/. We reserve the right to license or sell aggregate, de-identified information about the visitors to our Site, but this information will not contain your personal information or otherwise be individually identifiable.
Sensitive Personal Information. If you are a client, we may collect some sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, gender, financial holdings and account numbers, and criminal background) through the Site in connection with the services we provide you as a registered investment adviser. You may decline to provide information, however, some information we collect is mandatory to provide our services. Refusing to provide mandatory information may result in Innovia being unable to engage you as a client.
In collecting this sensitive personal information, Innovia respects individual privacy, protects against unauthorized access to or use of information, and complies fully with all laws and government regulations in the collection, use, storage, display, distribution and disposal of such information. Authorized uses of sensitive information with are limited to uses which are necessary to: a) meet our legal and regulatory requirements; or b) facilitate access to services, transactions, facilities and information.
How We Use Your Personal Information
We use your personal information for the following purposes and as otherwise described to you in this Privacy Policy or at the time of collection:
To Provide the Site and Communicate With You. We use your personal information:
- to provide, maintain and improve the Site;
- to better understand your needs and interests, and personalize your experience with the Site;
- to register you for events and contests;
- to respond to your requests, questions, comments, and feedback; and
- to perform website analytics and database management services.
To Send You Marketing Communications. We may send you newsletters, promotions or other marketing communications, but you may opt out of receiving them as described in the Your Choices section below.
To Create and Maintain Your Account. In order to utilize the services provided through the Site, you may create an account using certain personal information, including your name, email address, and phone number. You have choices about the information included in your account profile. You do not have to provide additional information on your profile; however, additional profile information may help you get more from our services. It is your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.
To Advertise To You. We may use your personal information to manage and serve ads in the Site or on third party sites and to tailor ads to your interests and browsing history. In addition to the cookies utilized by us on this Site, Innovia may allow trusted third parties to place advertisements for our services on sites and applications operated by others. These third parties may use cookies and web beacons to measure the effectiveness of our ads and to determine the display of content and advertising to you based on your interests both on our Site and other sites and applications that you may visit (see our Cookie Policy below). To support this interest-based advertising solution, we and the companies we have contracted with may use anonymous information about your visits to our and other websites and applications. The information collected and used by this process is always anonymous and does not enable any third party to identify you individually. You can learn more about interest-based advertising and opt out of such advertising from certain companies at aboutads.info.
For Compliance, Fraud Prevention and Safety. We may use your personal information as we believe appropriate to: (a) investigate or prevent violation of the law or your agreements with us; (b) protect our, your or others’ rights, privacy, safety or property (including by prosecuting and defending legal claims); (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; (d) comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; and (e) where permitted by law in connection with a legal investigation. For example, we may share information with law enforcement to reduce the risk of fraud or if someone uses or attempts to use our site for illegal reasons.
With Your Consent. In some cases we may ask for your consent to collect, use or share your personal information.
We may use third parties to help us design and operate the Site, provide services to support the Site, process your information, and provide promotional and marketing activities on our behalf. For example, we may hire a company to run certain website applications, help us analyze our data, or send information on our behalf about services and events in which you may be interested. Unless otherwise indicated at the time we collect your information, if we allow third parties to access the personal information we collect, we will have contractual provisions or other appropriate protections in place to ensure such access is for limited purposes and in compliance with this Privacy Policy. We do not share your personal information with third parties without your consent, except in the following circumstances:
Related and Affiliated Organizations. We may share your personal information with Innovia’s affiliates and related organizations for use consistent with this Privacy Policy.
Service Providers and Business Partners. We may share your personal information with third party companies and individuals as needed for them to provide us with services that help us with our business activities and to promote our services to you. We may also share your personal information with our business partners who offer a service to you jointly with us.
Security, Compliance, Fraud Prevention, Safety; Compliance with Law. We may disclose your personal information as we believe appropriate to government or law enforcement officials or private parties for the purposes described above under the following sections: For compliance, fraud prevention and safety and for compliance with law.
Business Transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy.
Your Choices
Opt Out of Communications. You may opt out of email notifications by changing the communication preferences in your account settings.
Opt Out of Marketing Communications. You may opt out of marketing-related emails by changing the communication preferences in your account settings or by following the opt-out prompt in the email. To opt out of other forms of marketing communications, please contact us using the contact information provided at the end of this Privacy Policy.
Consequences of Not Providing Personal Information. You are not required to provide all personal information identified in this Privacy Policy to use our Site or to interact with us offline, but certain functionality will not be available if you do not provide personal information. For example, if you do not provide personal information, we may not be able to respond to your request, perform a transaction with you, or provide you with marketing that we believe you would find valuable.
What are Cookies? Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies set by the website are called “first party cookies”. Cookies set by parties other than the website are called “third party cookies”. Third party cookies enable third party features or functionality, such as advertising or website analytics, to be provided on or through the website. The parties that set these third party cookies can recognize your computer or device both when it visits the website in question and also when it visits certain other websites and/or mobile apps.
What Cookies and Other Tracking Technologies does Innovia Use? We use several different kinds of cookies on this Site, including strictly necessary cookies, which are cookies that are necessary for the Site to function and cannot be switched off in our systems; performance cookies, which allow us to count visits and traffic sources so we can measure and improve the performance of our Site; and functional cookies, which enable the Site to provide enhanced functionality and personalization. We also collaborate with various third-party service providers who also use cookies to help us optimize our website and understand more about the visitors to our website. For example, we use Google Analytics to provide us with demographic information about our visitors and to help us analyze how people use our website. To learn more about how Google uses cookies, please click the link above or visit its website to view its privacy policy.
How Can You Disable Cookies and Other Tracking Technology? Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.
Some Internet browsers also may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.
Other Important Privacy Information
Third Party Sites and Services. The Site may contain links to other websites and services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third party websites, applications or services, and we are not responsible for their actions. Other websites and services follow different rules regarding their collection, use and sharing of your personal information. We encourage you to read their privacy policies to learn more.
Security. The security of your personal information is important to us. We take a number of organizational, technical and physical measures that are designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the absolute security of your personal information.
International Data Use and Cross-Border Transfers. We are located in the United States and have affiliates and service providers in other countries, and your personal information may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. However, we will handle your personal information in accordance with this Privacy Policy regardless of where your personal information is kept. Regarding transfers from the European Economic Area, Switzerland or United Kingdom to the United States, we rely on the derogations for transfers which are necessary to perform the transaction with you. Where required by law, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below. If you reside in other non-US jurisdictions, your use of the Site or provision of any personal information constitutes your consent for the transfer of such data to the United States for the purposes identified in this Privacy Policy. If you have questions about cross-border transfers, please contact us as detailed at the end of this Privacy Policy.
Verifying, Changing, and Deleting Your Information. If you have registered for an account through our Site, you can access, review and manage many changes yourself via your account, including updating your profile information and changing your communication preferences. If the information you are seeking is not available within your account, you can contact us as detailed below and ask us to change, update or fix your information in certain cases, particularly if it is inaccurate. You can also request that we erase or delete all or some of your personal information or otherwise object to, limit, or restrict the use of such information (if we have no legal right or legitimate business interest in retaining such information).
Children. The Site is not intended for use by anyone under the age of 18, nor do we knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, you should not attempt to use the Site or send any information about yourself to us.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make changes to this Privacy Policy, we will post them on the Site and indicate the effective date of the change. If we make material changes to this Privacy Policy we will notify you by email or through the Site.
Location-Specific Disclosures
The law requires that we provide additional disclosures to residents of certain countries, regions and states. Please see below for disclosures that may be applicable to you.
Notice to California Residents
If you are a California resident, this section applies to you in addition to the rest of this Privacy Policy. Please note that we may collect, use and share additional personal information about you that is governed by laws other than California law, such as the Gramm-Leach-Bliley Act, and that our activities related to such personal information are not disclosed here. Click here to learn more about our privacy practices related to such personal information.
Personal Information We Collect. We collect your personal information when you interact with our Site or otherwise communicate with us. In the past 12 months, we have collected the following categories of personal information from consumers and have used that information for the following purposes:
| Category of personal information collected | Business purpose of collection | Source(s) of information |
|---|---|---|
| Identifiers such as a real name, postal address, Internet Protocol address, email address and phone number | To provide our services and market to you | Directly from you when you provide it to us; we also collect your IP address passively from you when you visit our Site |
| Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with an internet website application, or advertisement | To provide you more relevant content, track original Site visits, and optimize your Site experience as well as to ensure our systems are properly functioning | Passively when you visit our Site or receive or interact with our communications |
We will not collect additional categories of personal information or use or retain the personal information we collected for materially different, unrelated, or incompatible business purposes without providing you notice. We will only retain your personal information for the period of time indicated above.
Retaining Your Information. We will only keep your personal information in an accessible form which can identify you for as long as we need to for the purposes for which it was collected. Because retention periods vary depending on the purpose for collection, we use certain categories and criteria to determine how long we keep personal information, as further described below. Where your personal information is used for more than one purpose, we will retain your Information for the longer of those periods.
| Category of personal information | Retention Period |
|---|---|
| Personal information processed in connection with client matters | Up to 2 years after you have closed your account with us, unless: (a) otherwise required by applicable law or for regulatory, compliance or insurance purposes; (b) there is a dispute that requires it to be kept for longer; or (c) there is another legitimate reason which requires it to be kept for longer. |
| Personal information processed for marketing purposes | For as long as you have not opted out of our marketing. If you ask us to no longer use your personal information for marketing purposes, we will need to retain certain of your details in our database to ensure that we do not accidentally send you marketing material. |
| Personal information held in our electronic backups | Our electronic backups are retained for 30 days. |
When we no longer require your personal information, we will take steps to delete or anonymize it. If the information cannot be permanently deleted or anonymized (for example when it is stored in our electronic backups), we will take appropriate steps to ensure that it is: (a) not used in connection with any decision involving you; (b) not shared with anyone except when we are legally required to do so; (c) kept secure; and (d) permanently deleted once possible.
Sharing Your Information. We do not share your personal information with third parties for cross-context behavioral advertising purposes or otherwise sell your personal information, but we may disclose your personal information to third parties for everyday business purpose, such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus.
In the past 12 months, we have disclosed the following categories of personal information to certain third party subcontractors and service providers for a business purpose:
| Category of personal information disclosed | Category of third parties to whom information is disclosed | Business purpose for disclosure |
|---|---|---|
| The following identifiers: real name, mailing address, email, phone number, and IP address | Customer relationship management software, internet service providers, email marketing provider, operating systems and platforms, marketing intelligence tools, and printers | To help us provide our Site and services and market our services to you. |
| The following internet or electronic information: browsing history, search history, and information regarding an individual’s interaction with an internet site, application or advertisement | Customer relationship management software, internet service providers, email marketing provider, operating systems and platforms, and marketing intelligence service providers | To help us provide our Site and market our services to you. |
Sensitive Personal Information. We do not use or disclose sensitive personal information except as necessary to provide you with our products and services or prevent fraud. You can request that we limit our processing of your personal information as detailed in the “Exercising Your Rights” section, below.
Personal Information of Children. We have no actual knowledge that we sell or share personal information of consumers under 16 years of age.
Your Rights. California residents have certain rights regarding their personal information:
- Right to Know. You may request no more than twice in a 12-month period that we provide you with copies of specific personal information we have collected, sold, or disclosed about you. However, under California law, we cannot provide you with certain sensitive information, despite your request (for example, we will not send you copies of your social security number even if it is something we collected).
- Right to Delete. You may request that we delete certain personal information we have collected about you, with certain exceptions.
- Right to Correct. You may request that we correct inaccurate personal information that we maintain about you.
- Shine the Light. Under California’s “Shine the Light” law, you have the right to ask us once a year if we have shared your personal information with third parties for direct marketing purposes.
Exercising Your Rights. To exercise your rights above, please submit a request to us by emailing us at contactus@innoviawealth.com, calling us at (800) 717-7865. Please describe your request with sufficient detail so we can properly respond to your request. As part of your request, please specify which right you are exercising and be prepared to provide the following information: name, phone number, and email address. We may ask for additional information to verify your identity. The information you provide in your request and any follow up information we ask for from you will be used solely to verify your request. After receiving your request, we may need to contact you for further information and will notify you if your request has been granted or declined, or if an exception applies to your request. Only you or an individual designated as your authorized agent to act on your behalf may make a request related to your personal information. We will not discriminate against you if you choose to exercise your rights.
Responding to Your Rights Request. We will try to respond to your request within 45 days. If we need more time, we will contact you with the reason we need more time and the extension period. We will deliver our written response by mail or electronically, at your option. In response to your request to know, we will only disclose the information we have collected in the 12 months prior to our receipt of your request. Our response will also explain the reasons we cannot comply with any request, if applicable. We do not charge a fee to process or respond to your request unless your request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate prior to completing your request.
If you have any questions or concerns about our privacy practices or information practices, please contact us as detailed at the end of this Privacy Policy.
Notice to Nevada Residents
Nevada law gives Nevada consumers the right to request that a company not sell their personal information for monetary consideration to certain other parties. We do not sell your personal information for monetary consideration; however, this right still applies. If you are a Nevada consumer and wish to exercise this right, please submit your request by contacting us as detailed at the end of this Privacy Policy.
How to Contact Us
Innovia Wealth, LLC
171 Monroe Avenue NW, Suite 800
Grand Rapids MI 49503
United States of America
Email: contactus@innoviawealth.com
Phone: 616-719-5007
This Privacy Policy was last updated February 9, 2023.