Effective Date: November 8, 2023
Personal Information We Collect: In connection with providing our Services, we obtain non-public personal information about you, including:
- Information we receive from you or from a third party whom you have authorized to disclose to us information needed to set up your account, such as your name, address, date of birth, Social Security Number, occupation, financial goals, assets and income;
- Information about your transactions with us, our affiliates, or others;
- Information received from credit or service bureaus or other third parties, such as your credit history or employment status as needed for KYC/CIP background checks; and
- Other information we are required to collect by law or regulation in order to provide the Services.
Categories of Parties to Whom We Disclose Personal Information: We will not disclose personal information collected in connection with our Services, except under the following circumstances:
- To entities that perform services for us or function on our behalf, including financial service providers, such as a clearing broker-dealer, plan sponsor, record keeper, investment company, insurance company, or other advisers;
- To consumer reporting agencies;
- To third parties who provide services with client resource management, who assist us with managing your account or who provide marketing, lead generation and other marketing services;
- To your attorney, trustee or anyone else who represents you in a fiduciary capacity or whom you have authorized to take action or receive information about your account;
- To our attorneys, accountants 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; and
- To our affiliates in order to service accounts, improve Services or for other purposes permissible under applicable law and regulation.
How We Use Personal Information: Personal information may be used by us and the third parties listed above for a number of purposes, such as:
- To protect your accounts/non-public information from unauthorized access or identity theft;
- To authenticate identity;
- To process your requests such as securities purchases and sales;
- To establish or maintain an account with an unaffiliated third party, such as a clearing broker-dealer providing services to you and/or SageView;
- To service your accounts, such as by issuing checks and account statements;
- To comply with federal, state, and self-regulatory organization requirements;
- To keep you informed about financial services of interest to you;
- To conduct marketing activity, such as developing marketing strategies, identifying marketing recipients, creating marketing materials and disseminating communications about our services through email, webinar, direct phone call, mail or text/SMS; and
- To monitor activity on our website.
We may also use your personal information for any other reason that we disclose at the time you provide, or when we collect, your information, and other purposes permitted by applicable law.
Limiting Sharing: Federal law gives you the right to limit only: (1) sharing for affiliates’ everyday business purposes – information about your creditworthiness; (2) affiliates from using your information to market to you; and (3) sharing for nonaffiliates to market to you. SageView does not share information with its affiliates, so (1) and (2) above don’t apply to us. To limit our sharing of nonpersonal information to nonaffiliates to market to you, please send an email to Data@Sageviewadvisory.com with your request to opt-out or contact us at (800) 814-8742.
Personal Information Protection: Federal law requires our firm to have an Identity Theft Protection Program (ITPP) that controls reasonably foreseeable risks to customers or to the safety and soundness of our firm from identity theft. We have developed an ITPP to adequately identify and detect potential red-flags to prevent and mitigate identity theft. In addition, we restrict access to nonpublic personal information about you to those individuals who need to know that information to provide products or services to you and perform their respective duties. We maintain physical, electronic, and procedurals security measures that are designed to comply with federal law to safeguard confidential client information.
Categories of Personal Information Collected: SageView may collect the following categories of personal information from you:
- Identifiers, such as name, address, online identifier, IP address, email address, account name, social security number, or other similar identifiers;
- Additional personal information, such as telephone number and financial information;
- Internet or other electronic activity information, such as browsing history and information regarding your interaction with an internet website applicable or advertisement; and
- Professional or employment information.
Categories of Sources of Personal Information: SageView may have collected the categories of personal information listed above either directly from you, from your devices, from our third-party service providers, or from data brokers.
“Sale” or “Sharing” of Personal Information: SageView does not “sell” or “share” (as such terms are defined under the CCPA) your personal information. Accordingly, we have not “sold” or “shared” your personal information to third parties, and we do not have actual knowledge that we “sell” or “share” the personal information of consumers under the age of 16.
CCPA Rights: To the extent that we collect personal information that is subject to the CCPA, your rights as a California resident under the CCPA are described below.
- Right to Know: If you are a California resident, you have the right to know the categories of personal information collected about you, the categories of sources of that information, the business or commercial purposes for which we collect it, the categories of third parties with whom we disclose it, and the specific pieces of Personal Information we have collected about you.
- Right to Delete: If you are a California resident, and subject to certain exemptions, you have the right to request that we delete any personal information that we have collected from you.
- Right to Correct: If you are a California resident, you have the right to correct personal information that we maintain about you.
SageView does not use or disclose “sensitive personal information” (as defined under the CCPA) of California residents outside of the following purposes: (1) performing our service or providing goods; (2) detecting security incidents; (3) resisting malicious, deceptive, fraudulent, or illegal actions; (4) ensuring physical safety; (5) for short-term transient use, including certain non-personalized advertising; (6) maintaining or servicing accounts, providing customer service, verifying customer information, or providing similar services; and (7) verifying and maintaining the quality or safety of a service or product to improve, upgrade, or enhance a service or product. Accordingly, we do not provide the right to limit the use or disclosure of your sensitive personal information under the CCPA.
How to Submit a Request: You may submit a request to exercise your California privacy rights by contacting us at (800) 814-8742, or by completing the form located here. You may also authorize an agent to make such a request by contacting us through our form, disclosing that they are your “authorized agent” and providing your last and first name in connection with the request. Before we can honor your requests, we may confirm that you or your authorized agent are the requesting party. In addition, depending on the type of request and the categories of the information subject to the request, we may request verifying information from the requesting party, such as identifiers already known to or collected by us.