Privacy Policy

InterPrime Advisors LLC and InterPrime Technologies LLC
January, 2019

Your Privacy Is Important

As a user of the InterPrime website and/or all associated websites, mobile applications and other services (collectively, “InterPrime”), your privacy is important to us. This Notice discusses the information we collect about you, how we treat it, with whom we share it, and how we protect it.


In the normal course of business, we collect personal information about you from a variety of sources, including:

  • information from you, such as information we receive from you during registration and on account applications or other forms (such as your name, address, email address, phone numbers, social security number, citizenship status, investment experience and goals, other regulatory disclosures, marital status, employment, assets and income); and
  • information about you, your accounts, and your holdings and transactions that we receive from you or others, such as third-party aggregators, account custodians, brokers, and other financial services firms, banks, or ERISA plan sponsors.

We collect information from you when you send us feedback as well. Some information we collect is not explicitly submitted by the user. Examples of such information include (but are not limited to): usage information, browsing activity, click activity, browser-related information, IP address, requested URL, referring URL, and timestamp.

When We Disclose Your Personal Information

We do not sell information about current or former clients to third parties. We may disclose your personal information where we believe it is necessary or appropriate to:

  • effect, administer, or enforce a transaction that you request or authorize;
  • process or service a financial product or service that you request or authorize;
  • maintain or service your account with us or with another entity;
  • investigate or prevent any actual or potential fraud or other criminal activity; or
  • comply with law or legal process.

We may also disclose personal information for everyday business purposes to: organizations or firms who provide consulting, technology or other services for us and agree to maintain its confidentiality and not use it for any other purpose; others, such as attorneys, trustees, family members, or others who are authorized to represent you, your estate, or a joint or co-owner of your account; or regulatory agencies.

We may also share your personal information if we merge with another company or if we decide to sell or reorganize some part or all of our business, assets or stock (including if we file for bankruptcy or are part of a similar proceeding). You acknowledge that such transfers may occur, and that any acquirer of the part of our business, assets or stock affected may continue to use information about you as set forth in this Privacy Policy.

How We Use Information Collected About You

Your personal and investment information is maintained by InterPrime to provide you services and support, including customized investment services, and to fulfill our legal and regulatory requirements. We also use such information to provide you personalized investment news and information, including forward you articles from our blog and other third party news content. By having more information about you, we are able to customize our services to your particular investment preferences. We may use your brokerage account information in order to rebalance your accounts and keep your accounts in line with the investment preferences that you specified when signing up for the paid service and selecting portfolio(s).

We may also share information you provide with our brokerage partner to create a brokerage account for you, and with other third party service providers where you have expressly authorized us to do so.

Data that does not include personally identifiable information may be used for research purposes. For instance, we may compile data, excluding personally identifiable information, for purposes of demographic analysis and research.  We may use usage information, browsing activity, click-thru activity, browser-related information, IP address, requested URL, referring URL, and timestamp information to help us diagnose problems with our servers, administer our website and services, and otherwise provide the highest possible level of service to you. In addition, we use this data in an aggregated, non-personally identifiable manner to perform statistical analyses of user behavior and characteristics in order to measure interest in and use of the various areas of our website and services.

We keep records of our advisory service, which may include but are not limited to records of the advice that we provide to you, your use of our services, and your communications to us about our services.


Blogs, Forums, and Wikis

If you use a blog, forum, wiki, or other publicly published content product on our site, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums.


Service-related Announcements

We will send you service-related announcements on the rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.


Use of Cookies and Pixels

Like most websites, our sites require cookies to function properly. Cookies are small text files that reside on a user’s computer and identify you as a unique user. Pixels are small code blocks on a website that allow for another server to measure viewing of a webpage and often are used in connection with cookies. We and certain of our third party service providers use cookies and pixels to refine our services, simplify the user experience and in some cases provide targeted advertising and content. For example, the use of cookies allows registered users to enter our sites without explicitly typing in their email address and password every time, and it allows us to personalize your experience. We may also use cookies and pixels to track unregistered uses of InterPrime.  We and third parties may tie personally identifiable information such as your email address to cookies and pixels. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature; however, you should note that cookies might be necessary to provide you certain features (e.g., customized delivery of information).


Third-Party Advertisers

InterPrime contracts with third-party advertising companies to advertise its services on third-party websites and mobile applications. These third-party advertising companies may use cookies, pixels and similar technologies to collect technical and web navigational information, such as device type, browser type, Internet protocol address, and pages visited.

InterPrime and these third-party online advertising companies may use the data collected, along with other information we have about you, to serve relevant ads to you. The advertisements may be relevant to your interests, as determined by your activity on InterPrime and other websites. These are known as “interest-based advertisements.”

You may opt-out of receiving interest-based advertisements from online advertising companies we associate with by going to the following link http://www.networkadvertising.org/managing/opt_out.asp and following the instructions provided.

Third party websites and mobile applications are not subject to our Privacy Policy. You may visit the individual sites for additional information on their privacy practices.


Google Analytics

We use third-party analytics tools, including “Google Analytics”, to collect information about the usage of this site. Google Analytics collect information about how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site, among other information. We use this information to understand user interaction to improve this site.

Google Analytics collects the IP address assigned to you on the date you visit this site, along with other anonymized information (e.g., browser type and type of device used to visit the site), but not your name or other personally identifiable information. Google Analytics’ ability to use and share information about your visits to this site is restricted by their terms of use and privacy policies. We do not combine the information collected through the use of Google Analytics with personally identifiable information.

You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser. You can opt-out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on here.


Recommendations of Certain Third Parties

We may from time to time recommend third-party broker-dealers and/or investment advisors to you. If you indicate your interest in learning more about a recommended broker-dealer or investment advisor, we will request your consent to collect information from you, including personally identifiable information, for communication to them. The communication of such information to the third- party broker-dealer or investment advisor will be subject to their privacy policy.


Security

InterPrime accounts are password-protected. We restrict access to your personal information to our employees and to permitted third-parties who need to know that information to provide products or services for us, or to provide, process, or maintain any security, account, or investment product, service or program for you or your benefit. To protect your personal information from unauthorized access and use, we have adopted administrative, technical, and physical security procedures that comply with federal law. These measures include computer safeguards and secured files and buildings.

We use our reasonable best efforts to protect our users’ information. If you have any questions about our security, then please contact us. We follow generally accepted industry standards to protect the personally identifiable information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet or method of electronic storage is 100% secure.

Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot assure you that personally identifiable information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.

You hereby acknowledge that we are not responsible for any intercepted information sent via the Internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.


Respecting Children’s Privacy

This website is not directed to children, and we do not knowingly solicit information from any child under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without his or her consent, he or she should contact us. Should a child whom we know to be under 13 send personal information to us, we will delete it as soon as possible.


InterPrime is Intended for U.S. Customers

InterPrime is hosted in the United States. This Privacy Policy is intended to comply with privacy laws in the United States and may not comply with all privacy laws in foreign countries.  If you are a non-US user of InterPrime, by using InterPrime and providing us with data, you acknowledge, agree and provide your consent that your personal information may be processed in the United States for the purposes identified in this Privacy Policy. In addition, such data may be stored on servers located outside your resident jurisdiction, which may have less stringent privacy practices than your own. By using InterPrime and providing us with your data, you consent to the transfer of such data and any less stringent privacy practices.


Control of Personal Information

We give you the opportunity to opt-out of receiving communications from us and to view, correct or remove your personal information.  However, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.  To contact us directly regarding cancelling your account or correcting or removing other personal information, please email us at contact@interprime.co.


Modifications to the Privacy Policy

By using InterPrime, you signify your agreement to the terms of our Privacy Policy. If you do not agree with these terms, you should not use InterPrime. We may modify this Privacy Policy at any time. If a material change is made to this Privacy Policy and/or the way we use our users’ personally identifiable information, then we will post a prominent notice of the nature of such change on the first page of this Privacy Policy. You are responsible for reviewing this Privacy Policy periodically to ensure that you are aware of any changes to it. Your continued use of InterPrime indicates your assent to any changes to this Privacy Policy.


Contact

If you have questions, comments, concerns or feedback regarding this Privacy Policy or any other privacy or security concern, please send an e-mail to contact@interprime.co.