Privacy Policy
We Respect Your Privacy
We greatly value the trust and confidence you place in us, and we are committed to protecting your personal data. This Privacy Policy describes how we collect, process, use, share and secure the personal information you provide. It also describes your choices regarding use, access, and correction of your personal information.
Personal Data
This policy applies to personal data we may collect, process, and handle. For purposes of this statement, “personal data” means information that:
is about, or pertains to, a specific individual; and
can be linked either directly or indirectly to that individual.
Generally speaking, we collect and process personal data as follows:
from employees and independent contractors in the context of the employment or contractor relationship,
from clients who wish to engage in advisory services or private placement securities transactions, and
from customers and issuers (parties participating in securities transactions) as necessary to effect transactions and as required by regulatory agency or legal requirements.
Principles Protecting Individuals’ Privacy Notice and Choice
We collect personal data from individuals as follows:
We notify individuals about the personal data we collect from them, how we use it and how to contact us with privacy concerns. All personal data is collected and processed with the express and informed consent of the relevant individuals or is collected and processed pursuant to mandatory legal requirements, including but not limited to those imposed by FINRA and the SEC.
We provide such notice through this policy, our engagement letters or other similar documents, instructions on personal data collection forms, and direct communication with individuals from whom we collect personal data.
Consent for personal data to be collected, used, and/or disclosed in certain ways (including opt-in consent for sensitive data) may be required in order for an individual to obtain or use our services. Such consent is provided through our engagement letters, employment agreements, customer identification forms, subscription agreements and other similar documents.
Data, Security, Integrity and Access
We employ various physical, electronic, and managerial measures, including education and training of our personnel, designed to reasonably protect personal information from loss, misuse or unauthorized access, disclosure, alteration or destruction. Personal data collected or displayed through a website is protected in transit by standard encryption processes. However, we cannot guarantee the security of information on or transmitted via the Internet.
We process personal data only for the limited and specific purpose for which it was originally collected or authorized by the individual. To the extent necessary for such purposes, we take reasonable steps so that personal data is accurate, complete, current, and otherwise reliable with regard to its intended use.
An individual has the right to access personal data we hold about them. An individual may contact us using the information below to correct, amend, or delete information where it is inaccurate. The individual will need to provide sufficient identifying information, such as name, address, and birth date. We may request additional identifying information as a security precaution such as possibly a national identifier (e.g. a Social Security number). In addition, we may limit or deny access to personal information where providing such access would be unreasonably burdensome or expensive in the circumstances, or where the rights of persons other than the individual would be violated. In some circumstances, we may charge a reasonable fee, where warranted, for access to personal information.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Notwithstanding the foregoing, we reserve the right to keep any information in our archives that we deem necessary to comply with our legal and regulatory obligations, resolve disputes and enforce our agreements.
Accountability and Enforcement
You may file a complaint in connection with our processing of your personal data using the contact information below. We will take appropriate steps to address any adverse effects and to promote future compliance. Personnel who violate our privacy policies will be subject to disciplinary action or termination.
Amendment
We may amend this policy from time to time by posting a revised policy on this website. If we amend the policy, the new policy will apply to personal data previously collected only insofar as the rights of the individual affected are not reduced.
For Valkere Academy Products, see Valkere Fulfillment Policy