PERSONAL INFORMATION WE COLLECT
HOW WE USE YOUR PERSONAL INFORMATION
HOW WE SHARE YOUR PERSONAL INFORMATION
OTHER IMPORTANT PRIVACY INFORMATION
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.
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.
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
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.
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.
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.
Opt Out of Communications. You may opt out of email notifications by changing the communication preferences in your account settings.
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.
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.
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.
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
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 firstname.lastname@example.org, 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.
Notice to Nevada Residents
How to Contact Us
Innovia Wealth, LLC
171 Monroe Avenue NW, Suite 800
Grand Rapids MI 49503
United States of America