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Geller Advisory Group, LLC Privacy Policy Notice
A Guide to How We Use and Protect Client Information Our Pledge to You
The trust of our clients is our most precious asset. Protecting your privacy and safeguarding your personal and financial information is one of our highest priorities. The following Privacy Statement explains how GELLER ADVISORY GROUP, LLC (“GAG”) collects and protects your information.
If you have any questions that this statement does not address, please contact your Client Relationship Manager. By opening a GAG account or by using the GAG Web site, you give your consent to the collection and use of personal information by GAG as explained in this statement. Any dispute over our Privacy Statement is subject to this notice and your proposal and advisor services agreements with GAG. Why do we gather information? There are several very important purposes. They all relate to providing you the optimum advisory client experience. We collect information required to open an account, to transact business effectively and to safeguard your assets or your privacy. But we also continually strive to improve our services and provide you opportunities to use additional products and services you may find of interest. To do this, we gather information to help us assess your needs and preferences. What information do we collect? The information we collect directly from you includes information required to communicate with you, including your name, mailing address, telephone number, e-mail address and fax number; and to identify who you are, including Social Security number; employer name and address. As required by law, to assess your experience in trading, we may also collect your approximate annual income, approximate net worth, approximate worth, and credit reports to assess your financial position. We also collect demographic information when you register through the site or request information on our products, including gender, birth date, education, occupation, etc. The information we collect indirectly from you includes your Internet Protocol (IP) address, browser type, operating system, Internet Service Provider (ISP), time stamps, transactions placed, products or services used, prior and following web site you view, and banner ads you click. We do this through the use of cookies, which are small text files sent from the Web server to your computer. Cookies help us to know you better by providing operational data we can use to aid your interaction with our Web site and improve its navigation and usability. When do we obtain information? You directly provide to us the majority of information we collect. You do this by completing the account application and related documentation, placing a trade, sending us an e-mail for questions or comment, or submitting information in response to a promotion or special offer. Other ways we collect information are by (1) observing your usage of our Web Site, (2) providing products and services to you, and (3) through other sources such as affiliates of GAG. How do we use your personal information? Again, the trust of our clients is our most valued asset. Therefore, we use personal information only as appropriate to provide you quality service and security. For example, GAG may use the information collected from you to verify your identity and contact information. We may also use this information to establish and set up your trading account, issue an account number and a secure password, maintain your portfolio and trading activity, and contact you with account information. This information helps us improve our services to you, customize your browsing experience and inform you about additional products, services or promotions that may be of interest to you. GAG may also use demographic information provided by others on our clients so that we can develop products and services for our clients. Should you close your account with us, GAG will retain your information, but only use it to comply with regulatory requirements. What information does GAG share with affiliates, alliances and partners? GAG may share information with affiliates if the information is required to provide the product or service you have requested or to provide you the opportunity to participate in the products or services our affiliates offer. GAG also forges partnerships and alliances, which may include joint marketing agreements, with other companies who offer high- quality products and services that might be of value to our clients. In order to ensure that these products and services meet your needs and are delivered in a manner that is useful and relevant, GAG may share some information with partners, affiliates and alliances. This allows them to better understand the offers that are most relevant and useful. We may also compare our client lists with those of our partners and affiliates to ensure that they are not sending messages to you if you’ve elected not to be so notified. In our strategic relationships, we will require that it be identified that an offer is being extended because of the relationship with us. The use of your personal information is limited to the purposes identified in our relationship with the partner or affiliate. An affiliate is a company that we own or control or with which there is common ownership with us and our parent company. An example of an affiliate is Geller Group, LLC. We may share with our affiliates information about our transactions and experiences with you such as name, e-mail address, mailing address, date of birth, employment status, and general account and demographic information. This information may be used for internal reporting, and development strategies. We do not share information other than the types of transaction and experience information described above with our affiliates. Do you share the information collected with any other third parties? The cornerstone of our Privacy Statement is the commitment to keep our clients’ personal information confidential. GAG does not sell, license, lease or otherwise disclose your personal information for any reason, except as noted earlier and as described below: To help us improve our services to you, we may engage another business to help us to carry out certain internal functions such as account processing, fulfillment, client service, client satisfaction surveys or other data collection activities relevant to our business. We may also provide a party with client information from our database to help us to analyze and identify client needs and notify clients of product and service offerings. Use of the information shared is strictly limited to the performance of the task we request and for no other purpose. GAG also reserves the right to disclose your personal information to third parties where permitted by law or where required by law to regulatory, law enforcement or other government authorities. We may also disclose your information as necessary to credit reporting or collection agencies, or when necessary to protect our rights or property. Data Security We continually update and improve our security standards and safeguards and procedures to help us protect you against anyone gaining unauthorized access to your information. We are on the alert for new technology to further enhance the security of this information. There are also safeguards in our procedures — when opening new accounts, for example — so that we may properly identify clients. Only those persons who need to do so as part of their job responsibilities are authorized to have access to your information. Our employees are trained in privacy and information security and on their obligations to protect your information. Does our Privacy Statement apply to the sites to which we link? No, we are not responsible for the privacy policies or the content of sites we link to and have no control of the use or protection of information provided by you or collected by those sites. Whenever you elect to link to a co-branded Web site or to a linked Web site, you may be asked to provide registration or other information. Please note that the information you are providing is going to a third party, and you should familiarize yourself with the privacy policy provided by that third party. What steps do we take to protect our clients’ personal information? We have made a significant investment in leading-edge security software, systems, and procedures to offer you a safe and secure trading environment and protect your personal, financial and trading information. While no security system is absolutely impenetrable, we are constantly reviewing, refining and upgrading our security technology, as new tools become available. When you open an account with us, you are issued a unique account number and a personal identification number (PIN). Upon logon, you may also be asked to create a User ID and password to access the Web site. Only a limited number of GAG employees who have a need to know this information will have access to your account number, PIN, User ID, and password. Remember: you are ultimately responsible for maintaining the secrecy of your account number, PIN, User ID, and password. We strongly recommend that you do not disclose this information. On our trading Web site, we also use technology to encrypt information transmitted by or to you through our Web site. What about “cookies” and other tracking devices? We use cookies to assist us in securing your trading activities and to enhance the performance of our Web site. (Cookies are small text files sent from the Web server to your computer.) Cookies used by GAG do not contain any personal information nor do they contain account, PIN, or password information. Cookies also may be placed by third parties when you access their sites through linking from this Web site. We do not have access to these cookies or any information that these cookies may contain. Please contact the third-party site for more information on these cookies. Although we encourage third parties to adhere to appropriate privacy policies and standards, we are not responsible for the actions or policies of such parties. To administer and improve the GAG web site, we may use a third party to track and analyze usage and volume statistical information, including page requests, form requests, and click paths. All data collected for this purpose is owned and used by GAG. The third party may use cookies to track behavior and may set cookies on behalf of GAG. These cookies do not contain any personally identifiable information.
Can I opt out of receiving certain information?
Yes. If you want to elect out of receiving direct communication from GAG, please contact us.
In doing so, you will be identified as a client who does not care to be contacted by us through direct communication for additional product and services offerings or inquires. An opt-out election must be made for each separate account you hold at GAG. This opt out will not apply to communications required to service your account.
Will I be able to review, change or correct my information?
Yes. Keeping your account information accurate and up to date is very important. We provide you with access to your account information in a number of ways. If your account information is ever inaccurate, incomplete, or in need of updating, please contact us at the number on your account statement or other GAG documentation or write to us and we’ll update your information. If you have any questions, or feel that we have not handled information about you properly you may always contact GAG and we will provide an answer or investigate your complaint.
How will I know if there are any changes to this Privacy Statement?
In the event GAG materially changes this Privacy Statement, the revised Privacy Statement will promptly be posted to the web site and we will post a notice on the Web site informing you of such changes. Additionally, this Privacy Statement has an effective date displayed in the lower, right corner indicating when it first came into effect. You should review this Privacy Statement periodically to remain informed of any changes. You agree to accept posting of a revised Privacy Statement electronically on the web site as actual notice to you.
Our Former Customers
Even if you are no longer a GAG customer, our privacy policy will continue to apply to you.
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