Privacy Policy
Introduction – This Privacy Policy describes the ways Integrated Advisors Network, LLC (“Integrated”) and its affiliated firms (collectively, “we,” “us,” “our,” or “Integrated”) collect, use, share, and protect information about you. By accessing or using any of our websites, mobile applications, other online or downloadable products and services, or offline services and tools, including call centers, offline enrollment tools, surveys, and other applications (each a “Service” collectively, the “Services”), you agree to the practices described in this Privacy Policy regarding our collection, use, sharing, and protection of information about you.
We also include specific disclosures for residents of California.
Personal Information We Collect – There are two primary ways we collect information about you: (1) when you voluntarily provide it to us while using the Services; and (2) with automatic technologies connected to the Services. We explain this in further detail below in the sections titled “Information You Provide to Us” and “Information We Automatically Collect.”
Information You Provide to Us – We collect information that you voluntarily provide when using the Services. For example, if you commence a financial planning process with one of our affiliates, we may collect the information you provide or authorize us to collect, such as your name, e-mail address and certain financial information. If you choose to open an account with one of our affiliates, we may also collect other personal information, such as your full legal name, contact information, date of birth, Social Security Number and other information that may be used to identify you.
Information We Automatically Collect – When you visit or use the Services, we may gather certain information about the device or browser you are using via automated means (e.g., cookies and web beacons) including, but not limited to, device identifiers, IP address, browser version and configuration, operating system details, language preferences, and length of visits. Cookies are elements of data that a website can send to your browser when you visit that website. Like most commercial website owners, we may use cookies to help you manage your use of the applicable Services. We may use cookies as follows:
- To recognize you as a regular user;
- To remind us of your identity;
- To customize your website experience and target ads and offers to you;
- To track your progress;
- To measure and analyze website traffic patterns to understand how our users’ habits are similar or different from one another;
- To compile statistics on usage patterns; and
- To conduct other research.
In addition, we use cookies, web beacons, or similar technologies to collect information through data analytics tools like Google Analytics and other third-party tracking pixels to improve your site experience, to serve you better ads on other sites, and to track your activity over time and across websites, as well as across different devices you use to access the Internet.
Many web browsers provide options to allow you to stop accepting new cookies, or to disable existing cookies. Please be aware that if you disable cookies on your browser, you may not be able to use certain features of the Services or other websites and disabling cookies may invalidate opt-outs that rely on cookies to function.
How We Share Information About You – We will not share such information with any affiliated or nonaffiliated third party except:
- When necessary to complete a transaction in a customer account, such as with the clearing firm or account custodians;
- When required to maintain or service a customer account;
- To resolve customer disputes or inquiries;
- With persons acting in a fiduciary or representative capacity on behalf of the customer;
- With rating agencies, persons assessing compliance with industry standards, or to the attorneys, accountants, and auditors of the firm;
- In connection with a sale or merger of the Adviser’s business;
- To protect against or prevent actual or potential fraud, identity theft, unauthorized transactions, claims, or other liability;
- To comply with federal, state, or local laws, rules, and other applicable legal requirements;
- In connection with a written agreement to provide investment management or advisory services when the information is released for the sole purpose of providing the products or services covered by the agreement; and/or
- In any circumstances with the customer’s instruction or consent.
Updating and Correcting Your Personal Information – Keeping information about you up to date is important. If you are a client of an affiliated adviser in the Integrated network, you may update, correct, or delete contact information by contacting your financial professional. If you are a client or a financial professional who has enrolled in online services with Integrated or one of its affiliates, you can access your profile, review contact information that is stored, and revise certain types of information by signing into your online account. To make any other updates, clients should contact their financial professionals, and financial professionals should contact their financial services firm.
Your Choices – As a consumer or customer of an Integrated affiliated investment advisor, you can learn more about how and why we share information about you and your options related to such sharing by reviewing the investment advisor’s Consumer Privacy Notice (“Notice”), available below.
Federal law gives consumers and customers, as those terms are defined in the Gramm-Leach-Bliley Act (“GLBA”), the right to limit some but not all sharing of their information by financial companies like Integrated. As explained in the Notices, you may opt out of sharing by calling the number provided in the Notice and following the prompts. (Please see the “To Limit Our Sharing” section in the Notice for instructions.) Your request will be addressed, but you will not receive a confirmation. Please note that customers will continue to receive annual Notices as required under Federal law; however, you do not need to respond to maintain a previous opt-out designation.
Unsubscribe Information – If you would like to unsubscribe from marketing emails sent by Integated, you can do so by replying “Unsubscribe” to our emails. Please note that even if you opt out of receiving such communications from us, we may continue to send you non-promotional emails, such as communications regarding our ongoing relationship with you.
How We Respond to Do Not Track Signals – Your internet browser may offer what is referred to as a “do not track” configuration that allows your browser to automatically signal your privacy preferences to certain websites that you visit. Industry standards related to this technology continue to evolve, and we have not yet identified a consensus on how to respond to such signals. Therefore, our websites do not currently respond to the “do not track” signals issued by browsers. To learn more about “do not track” signals, you may wish to visit http://www.allaboutdnt.com/.
Links to Affiliate and Non-Affiliate Websites – You should be aware that linked sites may have their own privacy policies or notices that differ from this Privacy Policy. Your use of linked sites is governed by the privacy policies and terms and conditions of those sites, which we strongly suggest you review.
Children’s Privacy – We do not knowingly collect personal information from children under the age of 13 through our Services, and we do not knowingly market to children under the age of 13. If we learn that we have received information directly from a child who is under the age of 13, we will delete the information in accordance with applicable law.
Security – We employ administrative, technical, and physical safeguards to secure personal information. Integrated’s Information Security Program is designed to allow our representatives to use the tools and software we provide with confidence. Although we use reasonable efforts to safeguard information, transmission via the Internet is not completely secure and we cannot guarantee the security of information collected through our Services.
Your California Privacy Rights – The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to know/access, delete, and limit sharing of Personal Information. The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” As a financial services organization, much of the information we collect is exempt from the CCPA because it is covered by federal or state financial privacy laws, such as the Gramm–Leach–Bliley Act and the Fair Credit Reporting Act. In addition, some information we collect may be exempt because it is considered public information (i.e., it is made available by a government entity) or because it is subject to other federal privacy laws, such as the Health Insurance Portability and Accountability Act.
To the extent that we collect Personal Information that is subject to the CCPA, your rights as a California resident to request access and deletion of that information are described below.
We do not sell your Personal Information to third parties. However, as described in this policy, we do allow third parties and service providers to collect Personal Information through the Services and share information with third parties and service providers for business purposes.
Right to Know/Access Information – You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, the categories of third parties with whom we share it, and the specific pieces of Personal Information we have collected about you. To protect our customers’ Personal Information, we are required to verify your identity before we can act on your request to know/access information.
If you have authorized someone else to make requests on your behalf, we require that you provide additional documentation, as described below.
Right to Request Deletion of Information – You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. To protect our customers’ Personal Information, we are required to verify your identity before we can act on your request to delete information. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated.
How to Submit a Request – You may submit a request to exercise your California privacy rights through any one of these means:
- (1) By filling out a Consumer Data Request Form which may be requested by emailing compliance@integratedadvisorsnetwork.com
- (2) By calling us at: 855.729.4222.
Verification Procedures – In order to process your request to know about or delete personal information we collect, disclose, or sell, we must verify your request. We do this by requesting that you provide personal identifiers, such as your name, phone number, and e-mail, that we can match against information we may have collected from you previously. We may also request you to confirm your request using the email or telephone account stated in the request.
Requests by Authorized Agent – You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf. We require that you provide legal documentation confirming the identity and authority of an authorized agent to act on your behalf. Such documentation may include, but is not limited to, a power of attorney, conservatorship or guardianship documentation, letters testamentary, or notarized statements (as may be appropriate under the circumstances). Parents of minor children may be required to submit a birth certificate of the child, to make requests on the child’s behalf.
Changes to this Privacy Policy – If we make changes to this Privacy Policy, we will revise the “Last Updated” date at the top of this page. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the applicable Service. Your use of such Service following these changes means that you accept the revised Privacy Policy.
Contact Us – For any questions you may have regarding this Privacy Policy, other than to opt out (please see the “Your Choices” section above for information on opting out), you have several options for reaching us. You may email us at compliance@ingeratedadvisorsnetwork.com, phone us at 855.729.4222, or write to us at the following address:
Integrated Advisors Network LLC
Attn: Compliance Officer
P.O. Box 25523
Dallas, TX 75225