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This Privacy Policy describes our policy regarding the collection, use, and disclosure of Information (as defined below) when you access and use the Site. By accessing and using the Site, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use, which are incorporated herein by reference. All capitalized terms not defined in this Privacy Policy shall have the meaning assigned to them in the Terms of Use.
In addition to this Privacy Policy, depending on your relationship with us, you may receive and be covered by our Privacy Notice, other privacy disclosures within account opening documents, and other privacy and security rules, as may be applicable.
We reserve the right to amend this Privacy Policy at any time and from time to time. You should check this Privacy Policy each time you use the Site to determine if any changes have been made. If you use the Site after the amended Privacy Policy has been posted, you will be deemed to have agreed to the amended Privacy Policy.
We do not knowingly collect any Personal Information (as defined below) from children under the age of 13 through the Site, which is not intended for this age group. If you are under 13, please do not use the Site or give us any Personal Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide us Personal Information without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us, and we will use commercially reasonable efforts to delete that information from our databases, though there can be no assurance that we are able to do so.
When you access certain restricted areas of the Site and/or use the services of Black Diamond Performance Reporting™ (linked through “MySAM), Betterment for Advisors™, (linked through “SAM Digital”), Fidelity NetBenefits® or Newport Group™ (linked through “SAM Retirement Plans”), or Fidelity Investments® (linked through Fidelity), you will be required to submit a Sign-In and Password. This information is linked to personal data that you provided to us (and which is provided to Black Diamond Performance Reporting™, Betterment for Advisors™, Fidelity NetBenefits®, Newport Group™ and Fidelity Investments®) during the registration process for such services.
In addition, when you sign up for any of our alerts, newsletters, or other communications or contact us via e- mail, you will be required to provide us with personal information about yourself, which may include your name, address, e-mail address, and other personal information. All information that we collect pursuant to this Section is collectively referred to herein as “Personal Information.”
We do not collect any Personal Information from you when you use the Site unless you provide us with the Personal Information voluntarily or authorize us to access it.
As you navigate through a website, certain information that does not identify you personally can be automatically collected without your providing the information. For example, when you visit the Site, we may collect information including but not limited to your IP address, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, and sections of the Site visited.
In addition, we may use cookies to collect certain information. Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect information and to enhance your experience using the Site. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Site may not function properly.
All information that we collect pursuant to this Section is collectively referred to herein as “Non-Personal Information.” The Non-Personal Information and the Personal Information are collectively referred to herein as the Information.
We use such Non-Personal Information to diagnose problems with our servers, report aggregate information, determine the fastest route for your computer to use in connecting to the Site, and administer and improve the Site.
We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. All personal information in our computers is protected from unauthorized access by a secure firewall and databased architecture. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
With respect to your Personal Information, we employ and maintain physical, electronic, and procedural safeguards that comply with applicable law.
SAM will take reasonable measures to dispose of personal information so that it cannot be read or reconstructed for unauthorized use. SAM will determine the appropriate method of disposal on an as needed basis.
We may use the Information to improve the Site and our services to you, to customize the Site to your preferences, to communicate information to you, and for the purposes specified in this Privacy Policy. We may disclose the information that we collect (i) to our affiliated entities that agree to treat it in accordance with this Privacy Policy, (ii) to third-party contractors we use to support our business (e.g., fulfillment services, technical support, delivery services, and financial institutions), in which case we will require such third parties to agree to treat it in accordance with this Privacy Policy, (iii) in the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, or (iii) where required by applicable laws, court orders, law enforcement, regulatory authorities, or government regulations or in the good-faith belief that such action is necessary or advisable to (a) comply with a legal obligation, (b) protect and defend any of our rights or property, (c) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (d) protect against legal liability.
The Site is operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using the Site and/or providing us with any Information, you irrevocably and unconditionally consent to this transfer.
The Site contains links or references to third-party websites. Please be aware that we do not control such other websites and that, in any case, this Privacy Policy does not apply to those websites. As such, we are not responsible for the content or the privacy policies of those third-party websites. We encourage you to read the privacy policy of every website you visit.
If you have any questions, comments, or concerns about this Privacy Policy or the information practices of the Site, please contact us as follows:
Satovsky Asset Management, LLC
232 Madison Avenue, Suite 400
New York, NY 10016
Phone: 212.584.1900
Fax: 212.584.1901
Email: [email protected]
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