Privacy Policy

 

AdvisorTarget Privacy Statement

AdvisorTarget, LLC, d/b/a FinSum, a Broadridge Financial Solutions, Inc., company (“AdvisorTarget”, “we” or “us”), is committed to respecting privacy. If you have any additional questions about the privacy of your Personal Information, please contact our Privacy Office via email at This email address is being protected from spambots. You need JavaScript enabled to view it..

If you are a resident of California or Texas, please see “Additional Information for Residents of California or Texas” below for more information about your privacy rights under the laws of such states.

  1. AdvisorTarget Privacy Statement
  2. AdvisorTarget Cookie and Online Privacy Notice
  3. Additional Information for Residents of California or Texas
  4. How to Contact Us and Our Chief Privacy Officer

A.         AdvisorTarget Privacy Statement

This AdvisorTarget Privacy Statement (this “Privacy Statement”) describes the practices that we will follow with respect to the Personal Information (defined below) we collect from our clients and business partners (collectively, “Business Partners”), service providers and from individuals who interact with us directly, including through AdvisorTarget websites that link to this Privacy Statement.  This Privacy Statement does not apply to our job applicants, current employees, former employees, or independent contractors.

“Personal Information” or “PI” is any information that can be used to identify, locate or contact you. It also includes other information that may be associated with your name or other identifiers. The chart below describes the categories of Personal Information we collect, the sources of that information, the reasons we collect it, and the types of people to whom we may disclose the information.

Please note that we may use and disclose any Personal Information for our “Everyday Business Purposes”[1]  as permitted by law. We may also disclose any Personal Information to our affiliates and to the service providers and contractors that need to use the information to provide services to us (collectively, “Vendors”). We have contracts with our Vendors that require them to protect our information and to comply with law. We may also disclose any information when required by law, such as to law enforcement agencies or to parties in litigation.

We may “Sell” Personal Information, as that term is broadly defined under the CCPA (defined below). We may also “Share” Personal Information for cross-contextual behavioral advertising or online targeted advertising, as that term is defined by the CCPA. Personal Information we have Sold or Shared is described in the table below. You can opt-out of the Sale or Sharing of your Personal Information by visiting our privacy rights portal at Your Privacy Choices. 

We collect Personal Information from or about business professionals who sign up for our newsletters, visit our websites or those of our Business Partners or otherwise initiate a relationship with us (“Commercial Customers”) and business professionals who may be interested in becoming our Commercial Customers whom we contact independently (“Commercial Contacts”).

We may disclose Personal Information to our Vendors for Everyday Business Purposes. Additionally, we may also disclose PI to Business Partners so that they can provide you with services you may be interested in, and such disclosures may be considered Sales or Sharing, as defined by the CCPA. Our data practices are further described in the following table.

CATEGORY AND SOURCES OF PI

PURPOSES FOR COLLECTING THIS PI

DISCLOSURES OF THIS PI

Commercial Customer and Commercial Contact Information (Identifiers)

This is the type of information that can be found on your business card, such as your name and title, company affiliation, mailing address, email address and telephone number.

We collect this type of information from you (when you engage with us by signing up for our newsletter or subscription services), from publicly available sources (such as publicly available filings, financial institution sites, and social media sites). We also may receive your data from third parties, such as data aggregators, Business Partners, trade associations, or trade shows.

We use this type of information to identify you and communicate with you, including:

·     To send marketing communications, surveys and invitations; and

·     To connect you with products or services you may be interested in.

We may disclose this type of information for Everyday Business Purposes to:

·     Vendors and contractors;

·     Government entities; and

·     Other parties within the limits of Everyday Business Purposes.

We may Sell/Share to:

·     Third-Party Digital Businesses; and

·     Business Partners.

Business Partner and Vendor  Information

We collect “B2B” Personal Information about business professionals associated with our Business Partners and Vendors in the context of our relationships we have with these companies. This includes:

·       Information about your authority to use our products and place orders with us;

·       Transaction records, including product usage, customer service, training and related records;

·       Professional interests and credentials;

·       Relationship information, including marketing and communication preferences; and

·       Visitor logs.

We collect this type of information from you and from your company. We also may receive your data from third parties, such as trade associations or trade shows.

We use this type of information:

·     To fulfill our business relationship with you;

·     To develop and maintain our relationship with you, including sending you marketing communications as permitted by law and subject to your preferences;

·     For internal business purposes, such as finance, quality control, training, reporting and analytics;

·     For risk management, fraud prevention and similar purposes; and

·     For recordkeeping and compliance, including dispute resolution.

We may disclose this type of information for Everyday Business Purposes to:

·     Vendors and contractors;

·     Government entities; and

·     Other parties within the limits of Everyday Business Purposes.

We may Sell/Share to: We do not sell/share this information.

Unique Identifiers

Such as:

·       Central Registration Depository Numbers;

·       IP Address;

·       System identifiers;

·       Device identifiers; and

·       Advertising ID.

We collect this type of information from your devices, third party digital businesses such as social media platforms, analytics companies, data brokers, advertising partners, and other tech companies that offer digital advertising services (“Third-Party Digital Businesses”), Business Partners, and Vendors.

We use this type of information:

·     To identify you or your device, including to associate you with different devices that you may use;

·     For record-keeping and reporting, including for data matching;

·     For metrics and analytics; and

·     For online ad delivery and personalization.

We may disclose this type of information for Everyday Business Purposes to:

·     Vendors and contractors;

·     Government entities; and/or

·     Other parties within the limits of Everyday Business Purposes.

We may Sell/Share to:

·     Third-Party Digital Businesses; and

·     Business Partners.

Account Access Information

Such as:

·       Usernames and/or passwords; and

·       Account recovery information (such as security questions and answers).

We collect this type of information from you, when you establish an account or change your password.

We use this type of information:

·     To identify and authenticate you;

·     To enable you to engage in transactions with us (such as interacting with us online); and

·     For security and similar purposes.

We may disclose this type of information for Everyday Business Purposes to:

·     Vendors and contractors;

·     Government entities; and

·     Other parties within the limits of Everyday Business Purposes.

We may Sell/Share to: We do not sell/share this information.

Online & Technical Information

Such as:

·       IP Address;

·       Device identifiers;

·       Device characteristics, including precise geolocation data;

·       Server and application logs; and

·       Data from cookies, pixel tags and other online tools.

We collect this type of information from Third-Party Digital Businesses, your computer or devices when you interact with our platforms, websites and applications. For example, when you visit our websites, our server logs record your IP address and other information. We may also receive this information from third parties, including computer security services and advertising partners.

Please read our Cookie and Online Privacy Notice in Section B of this privacy policy to learn more.

We use this type of information:

·     To determine who visits specific pages within our Business Partners’ websites;

·     We Sell Personal Information that we have collected directly from our websites and newsletters to our Business Partners;

·     For system administration, technology management, including optimizing our websites and applications;

·     For information security and cybersecurity purposes, including detecting threats;

·     For other authorized purposes, such as if you consent to our use of precise geolocation data to deliver content to you based on your location;

·     For recordkeeping, including logs and records that are maintained as part of transaction information;

·     To better understand our Business Partners and prospective Business Partners and to enhance our relationship information, including by associating you with different devices and browsers; and

·     For online targeting and advertising purposes.

We may disclose this type of information for Everyday Business Purposes to:

·     Vendors and contractors;

·     Government entities; and

·     Other parties within the limits of Everyday Business Purposes.

We may Sell/Share to:

·     Third-Party Digital Businesses; and

·     Business Partners.

Geolocation Data (such as from your IP Address)

We may collect this type of information from website cookies, tracking pixels, and other tracking technologies on our website as well as from our Business Partners and Third-Party Digital Businesses.

We use this type of information:

·     For system administration, technology management, including optimizing our websites and ns;

·     For information security and cybersecurity purposes, including detecting threats;

·     For other authorized purposes, such as if you consent to our use of precise geolocation data to deliver content to you based on your location;

·     For recordkeeping, including logs and records that are maintained as part of transaction information;

·     To better understand our Business Partners and prospective Business Partners and to enhance our relationship information, including by associating you with different devices and browsers; and

·     For online targeting and advertising purposes.

We may disclose this type of information for Everyday Business Purposes to:

·     Vendors and contractors;

·     Government entities; and

·     Other parties within the limits of Everyday Business Purposes.

We may Sell/Share to:

·     Third-Party Digital Businesses; and

·     Business Partners.

Professional or Employment Information (such as your status as an employee of a registered investment advisor or as a licensed financial advisor).

We may collect this type of information from our Vendors and Business Partners.

We use this type of information:

·     For recordkeeping, including logs and records that are maintained as part of transaction information;

·     To assist our Business Partners in better understanding who visits their websites; and

·     For online targeting and advertising purposes.

We may disclose this type of information for Everyday Business Purposes to:

·     Vendors and contractors;

·     Government entities; and

·     Other parties within the limits of Everyday Business Purposes.

We may Sell/Share to:

·     Business Partners.

Inferences from PI Collected (such as your interest in certain products or services associated with your role as a business professional).

We generate this information internally based on the other types of Personal Information described above.

We use this type of information:

·     To assist our Business Partners in better understanding who visits their websites and what types of financial products such visitors are interested in; and

·     For online targeting and advertising purposes.

We may disclose this type of information for Everyday Business Purposes to:

·     Vendors and contractors;

·     Government entities; and

·     Other parties within the limits of Everyday Business Purposes.

We may Sell/Share to:

·     Business Partners.

Please note that we may also use and disclose information about you that is de-identified or aggregated, as those terms are defined by applicable privacy laws. For example, we may publish reports or create products that contain de-identified, aggregated or statistical data.

Information Security

We take reasonable steps designed to help prevent the loss, misuse and alteration of the information under our control. However, no environment or security procedures or protocols are ever guaranteed to be 100% secure or error-free.

If you have registered at an AdvisorTarget website or a hosted website, we recommend that you do not divulge your password to anyone. We will never ask you for your password in an unsolicited phone call or in an unsolicited email.

Data Retention

We will retain your Personal Information for as long as the information is needed for the purposes listed above and for any additional period that may be required or permitted by law, such as for business, legal, accounting, or reporting requirements or pursuant to Business Partner contract requirements.  The length of time your Personal Information is retained depends on the purpose(s) for which it was collected, how it is used, and the requirements to comply with applicable laws or Business Partner contracts.

Changes to this Privacy Statement

From time to time, we may update this Privacy Statement to reflect new or different privacy practices. The updated Privacy Statement will include the date it was last updated. Additionally, if the changes will materially affect the way we use or disclose previously collected Personal Information, we will notify you about the change.

Other Websites

AdvisorTarget websites may contain links to other websites, including those of our Vendors or Business Partners. While we seek to link only to websites that share our high standards and respect for privacy, we are not responsible for the privacy practices employed by other websites.

B.         AdvisorTarget Cookie and Online Privacy Notice

When you visit our websites, we may collect certain information by automated means, using technologies such as cookies, pixel tags, browser tracking analysis tools, server logs and web beacons.

Cookies

When you visit our websites, we place cookies on your computer. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. You have choices about these cookies.

To learn more about the cookies we place and to exercise your choices, please visit our privacy rights portal at Your Privacy Choices.

In the privacy rights portal, click on the different category headings to find out more and change our default settings according to your preference. You cannot opt-out of our Strictly Necessary Cookies as they are deployed in order to ensure the proper functioning of our website (such as prompting the cookie banner and remembering your settings, to log into your account, to redirect you when you log out, etc.). However, you can opt-out of our use of Performance, Functional and Targeting Cookies.

Other Data Collection Technologies

We may also use Flash Cookies (also known as Local Stored Objects) and similar technologies to personalize and enhance your online experience. We use Flash cookies for security purposes and to help remember settings and preferences. We do not use Flash cookies or similar technologies for behavioral or interest-based advertising purposes.

These technologies also help us provide a customized experience and enable us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the “help” section of your browser to learn about the privacy settings that may be available.

In connection with marketing efforts, we may use pixel tags and web beacons, which are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure responses to our communications and improve our websites and promotions. Information collected using these technologies in our emails may be associated with the recipient’s email address.

For example, we may collect information from the device you use to access our website, including your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address assigned to the device you use to connect to the Internet. An IP address is a unique number that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you visited our websites.

In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without any reference to Personal Information. For example, we use information we collect about all website users to optimize our websites and to understand website traffic patterns. In some cases, we do associate the information we collect using cookies and other technology with your Personal Information.

On some of our websites, AdvisorTarget directly or through third parties uses web analytics tools to provide AdvisorTarget or its Business Partners with information about the use of these websites.

Google Analytics

Google Analytics is a web analytics tool provided by Google, Inc. that helps website owners understand how visitors engage with their website. AdvisorTarget may use Google Analytics to view a variety of reports about how visitors interact with our websites so that we can improve them. Google Analytics uses cookies and other tools, which generate information about your use of our website (including your IP address). This information is transmitted to and stored by Google on servers in the United States. Google uses this information to evaluate your use of our website, report on website activity and provide other services to us. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google may combine this information with other data held by Google pursuant to Google’s privacy policy available on Google’s website. You may refuse the use of cookies by opting-out of our collection of data via Performance, Functional and Targeting Cookies through our privacy rights portal at Your Privacy Choices. For more information on how Google Analytics uses the information it collects, please visit “How Google uses information from sites or apps that use our services”, located at www.google.com/policies/privacy/partners/.

Do Not Track

Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether you intend for these signals to be transmitted, or whether you even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, we currently do not take action in response to these signals.

C.         Additional Information for Residents of California or Texas

This  Privacy Statement provides the information required by the California Consumer Privacy Act (the “CCPA”) and the Texas Data Privacy and Security Act (the “TDPSA”). Please note, if we have collected or received your Personal Information in our capacity as a service provider to a Business Partner with which you have a relationship, that company can assist you with requests related to exercising your privacy rights, as AdvisorTarget cannot fulfill these requests directly. We suggest you reach out to such company to learn more about its privacy practices and to exercise your rights. These companies can authenticate you and provide information about the rights that you may have under CCPA, the TDPSA or other applicable laws.

  1. Your Privacy Rights

The CCPA and TDPSA provides California and Texas residents, respectively, with specific privacy rights:

  • The right to know what Personal Information and sensitive Personal Information we collect;
  • The right to access your Personal Information;
  • The right to correct inaccurate Personal Information;
  • The right to request that we delete your Personal Information;
  • The right to know what categories of Personal Information are sold to third parties and to opt-out of that sale;
  • The right to know what categories of Personal Information are shared with third parties for cross-contextual behavioral targeting and to opt-out that sharing; and
  • The right not to be retaliated against for exercising your privacy rights.

We do not knowingly Sell or Share the PI of consumers under 16. If you think we may have unknowingly collected PI of a consumer under 16 years old, please contact us using one of the methods described below in “How to Contact Us and Our Chief Privacy Officer.”

If you are a California or Texas resident, you may exercise your rights by:

  • Calling our Toll-Free Number: (888) 237-7769;
  • Visiting our privacy rights portal at Your Privacy Choices;
  • Emailing This email address is being protected from spambots. You need JavaScript enabled to view it.;
  • Writing to us at:

AdvisorTarget, LLC
Attn: Chief Privacy Officer
5 Dakota Drive, Suite 300
Lake Success, New York 11042 USA

In order for us to process your request, we will need to obtain certain information from you to verify your identity.  For a report of the specific Personal Information we have processed about you, you must provide us with three of the following pieces of information in order for us to verify your identity:

  • full name;
  • email address; and
  • Central Registration Depository number.

You also must tell us your state of residence and provide us with a signed declaration, under penalty of perjury, that you are who you say you are.

To request a report of the categories of Personal Information we have processed about you, to request that we delete or correct your Personal Information, you must provide us with two of the above-referenced pieces of information in order for us to verify your identity.  Where necessary, we may request additional information about you so that we can verify your identity. Where we did not already hold that information, we will use it only for the purpose of verifying your identity and to process your request.

If you would like to designate an agent, please send an email from your own email address to This email address is being protected from spambots. You need JavaScript enabled to view it. indicating the name and email address of your agent. We will respond to that person’s requests using both your email address and the agent’s email address.

If you are exercising access or deletion rights on behalf of another person, please understand that we will need to verify your authority with the person you seek to represent. Whenever you interact with us on behalf of another individual or entity, such as by providing or accessing Personal Information about another individual, you represent that your interactions and exchanges comply with applicable laws. You shall have sole responsibility for any violation of applicable laws as a result of a failure to obtain any necessary consent from such individual.

We will not retaliate against you if you exercise your rights under the CCPA or TDPSA.

  1. Additional Disclosures Regarding Sensitive Personal Information

AdvisorTarget uses and discloses the following categories of sensitive Personal Information as described in more detail in this Privacy Statement. We do not process any sensitive Personal Information for the purpose of informing characteristics about you.

CATEGORY OF SENSITIVE PERSONAL INFORMATION

PURPOSES FOR USE AND DISCLOSURE

 DISCLOSURES OF THIS SPI

Account log-in credentials

We use and disclose account access information as needed to allow you to access your account, for account security purposes.

 Disclosures for Everyday Business Purposes:

·       Vendors (e.g., data analytics providers, payment processors, and marketing services providers);

·       Other members of our corporate group;

·       Government entities; and/or

·       Other parties within the limits of Everyday Business Purposes.

 

Sale/Share:

We do not sell or share this information.

We do not collect other categories of sensitive Personal Information, such as precise geolocation, biometric identifiers, the contents of mail, email or texts, or non -public information about your race, ethnicity, health, sex life or sexual orientation.

  1. Sale of Personal Information and Sharing of Personal Information for Cross-Contextual Behavioral Targeting; Collection of Personal Information by Third Parties

In certain contexts, AdvisorTarget will Sell Personal Information that it has collected directly from its own websites, newsletters, and enhanced as a result of its business relationships with its Vendors and its Business Partners to other Business Partners. You can opt-out of our Selling your Personal Information by visiting our privacy rights portal at Your Privacy Choices. 

Some AdvisorTarget websites allow Third-Party Digital Businesses to utilize cookies, web beacons or other technologies to deliver ads to you on our sites and to deliver our advertisements to you on other sites. These third parties may collect information about your online activities on our websites, and they may use persistent identifiers to track you over time and across different websites and other online services. You can opt-out of our Selling or Sharing of your data for cross contextual behavior advertising by visiting our privacy rights portal at Your Privacy Choices. 

Our websites also recognize Global Privacy Control (“GPC”) signals and will interpret such signal as a request to opt-out of the sale/sharing of your personal information provided by your browser.

To use an GPC, you can download an internet browser or a plugin to use on your current internet browser and follow the settings to enable the GPC.   We process GPC with respect to Sales and Sharing that may occur in the context of collection of cookie PI by tracking technologies online by Third-Party Digital Businesses, discussed above, and apply it to the specific browser on which you enable GPC. We currently do not, due to technical limitations, process GPC for opt-outs of Sales and Sharing in other contexts (e.g., non-cookie PI).  We do not: (1) charge a fee for use of our service if you have enabled GPC; (2) change your experience with any product or service if you use GPC; or (3) display a notification, pop-up, text, graphic, animation, sound, video, or any interstitial in response to the GPC.

  1. Profiling and Automated Decision-Making

We may use analytics tools to understand how individuals interact with us and our products, such as to assess engagement and for personalization and product development purposes. We also use analytics tools for security and fraud prevention purposes. However, we do not use profiling or automated decision-making tools to make decisions that produce legal or similarly significant legal effects.

  1. Appeals

If you are a Texas resident and wish to appeal our response to your request to exercise your privacy rights, please contact us using any of the methods described in “Your Privacy Rights,” above. After receipt of an appeal, we will inform you of any action taken in response to the appeal, if any, along with a written explanation of the reasons for such action or inaction within the time periods required by the TDPSA.

D.         How to Contact Us and Our Chief Privacy Officer

Please contact us if you have any questions or comments about our privacy practices or this Privacy Statement. You can always reach us via email at This email address is being protected from spambots. You need JavaScript enabled to view it.. You can also reach us via mail at the postal address provided below.

AdvisorTarget, LLC
Attn: Chief Privacy Officer
5 Dakota Drive, Suite 300
Lake Success, New York 11042 USA

Last Modified: May 29, 2024

 

[1] Everyday Business Purposes encompasses the Business Purposes (as defined by California law) and following related purposes for which any Personal Information may be processed:

  • To provide the information, product or service requested by the individual or as reasonably expected given the context in which with the Personal Information was collected (such as customer credentialing, providing customer service and preference management, providing product updates, bug fixes or recalls, and dispute resolution);
  • For identity and credential management, including identity verification and authentication, system and technology administration;
  • To protect the security and integrity of systems, networks, applications and data, including detecting, analyzing and resolving security threats, and collaborating with cybersecurity centers, consortia and law enforcement about imminent threats;
  • For fraud detection and prevention;
  • For legal and regulatory compliance, including all uses and disclosures of Personal Information that are required by law or as reasonably needed for compliance with company policies and procedures, such as: anti-money laundering programs, security and incident response programs, intellectual property protection and anti-piracy programs, and corporate ethics and compliance hotlines;
  • For corporate audit, analysis and reporting;
  • To enforce our contracts and to protect against injury, theft, legal liability, fraud or abuse;
  • To protect people or property, including physical security programs;
  • To de-identify the data or create aggregated datasets, such as for consolidating reporting, research or analytics;
  • To make back-up copies for business continuity and disaster recovery purposes; and
  • For corporate governance, including mergers, acquisitions and divestitures.

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