Effective as of June 30, 2021.
Table of Contents
Personal Information We Collect
Information you provide to us. Personal information you provide to us through the Services may include:
- Contact information, such as your first and last name, email address, phone number, and any information you give us through the contact us function on the website.
- Profile information, such as your username and password and any account preferences for the Services.
- Feedback or correspondence, such as information you provide when you contact us with questions,
feedback, or otherwise correspond with us.
- Usage information, such as information about how you use the Services and interact with us, including information you provide when you use any interactive features of the Services.
- Marketing information, such as your preferences for receiving communications about our products, activities, and publications, and details about how you engage with our communications.
You can read more about your privacy choices for social media networks and other third‐party platforms below.
Information we obtain from other third parties. We may receive personal information about you from third‐party sources, such as marketing partners, publicly‐available sources, and data providers.
Cookies and Other Information Collected by Automated Means
We, our service providers (such as WordPress and Google), and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Services. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model; device identifier; browser type; screen resolution; IP address; the website you visited before browsing to our website; general location information such as city, state or geographic area; and information about your use of and actions on the Services, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.
How We Use Your Personal Information
To operate the Services. We use your personal information to:
- provide, operate, and improve the Services;
- establish and maintain your user profile on the Services;
- communicate with you about the Services, including by sending you announcements, updates, security alerts, and support and administrative messages;
- understand your interests and personalize your experience with the Services;
- provide support and maintenance for the Services; and
- respond to your requests, questions and feedback.
For research and development. We analyze use of the Services to improve the Services and to develop new products and services.
To send you marketing and promotional communications. We may send you marketing communications as permitted by law. You can opt out of our marketing and promotional communications as described below.
To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Services; and (c) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.
With your consent. In some cases we may specifically ask for your consent to collect, use, or share your personal information, such as when required by law.
To create anonymous data. We may create aggregated and other anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.
How We Share Your Personal Information
Service providers. We may share your personal information with third‐party companies and individuals that provide services on our behalf or help us operate the Services (such as customer support, hosting providers such as WordPress, analytics providers such as Google's Tag Manager, email delivery, marketing, and database management services). These third parties may use your personal information only as authorized by their contracts with us.
Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.
Business transfers. We may sell, transfer, or otherwise share some or all of our business or assets, including your personal information, in connection with a (potential) business transaction such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
In this section, we describe the rights and choices available to all users.
Access or update your information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into your account.
Opt out of marketing communications. You may opt out of marketing emails by following the unsubscribe instructions at the bottom of the email. You may continue to receive service-related and other non-marketing emails.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.
Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Services. We will tell you what information you must provide to receive the Services by designating it as required at the time of collection or through other appropriate means.
Other Sites, Mobile Applications, and Services
The Services may contain links to, or content or features from, other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third-party websites, mobile applications, or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use, and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.
The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International Data Transfers
We are headquartered in the United States and may have service providers in other countries, and your personal information may be transferred outside of your state, province, or country to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
The Services are not directed to, and we do not knowingly collect personal information from, anyone under the age of 16. If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it. We encourage parents with concerns to contact us.
Financial Privacy Notice
Financial companies choose how they share your nonpublic personal information. Federal law gives our clients the right to limit some but not all sharing, and it requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
It is our policy not to disclose nonpublic personal information about our clients or former clients to third parties other than as described below.
Personal information we collect. We collect personal information about you in connection with our providing advisory services to you. This information may include your social security number, date of birth and residential address, and may also include other information such as your:
- Assets and income;
- Financial account information and balances;
- Investment experience;
- Transaction history; and
- Wire transfer instructions.
How we collect this information. We collect this information from you through various means, including, but not limited to, when you give us your contact information and you complete our client questionnaire and other forms you give to us, enter into an investment advisory contract with us, tell us where to send money, or make a wire transfer.
How we use this information. All financial companies need to share clients’ personal information to run their everyday business and we use the personal information we collect from you for our everyday business purposes. These purposes may include for example:
- To provide advisory services to you.
- To open an account for you.
- To process a transaction for your account.
- To market products and services to you.
- To respond to court orders and legal investigations.
Disclosure to others. We may provide your personal information to firms that assist us in servicing your account and have a need for such information, such as brokers, custodians, our client relationship management (CRM) and other software vendors and data storage providers, and otherwise as required or permitted by law. We may also disclose such information to any service providers and financial institutions with whom we may have joint marketing arrangements (i.e., a formal agreement between nonaffiliated financial companies that together market financial products or services to you, such as solicitors). We require any such third-party service providers and financial institutions with which we may have joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them. These sharing practices are consistent with Federal privacy and related laws, and you may not limit our use of your personal information for these purposes under such laws. Federal privacy laws only give you the right to limit the certain types of information sharing that we do not engage in (e.g., sharing with our affiliates certain information relating to your transaction history or creditworthiness for their use in marketing to you, or sharing any personal information with nonaffiliates for them to market to you).
How we protect your personal information. To protect your personal information from unauthorized access and use, we use security measures that comply with Federal law.
These measures include computer safeguards and secured files and premises.
In addition, we restrict access to non-public personal information about clients to our employees who need to know that information to provide services to clients.
How to Contact Us
If you have any questions or comments about this Policy or Fairview Capital’s privacy practices, email us at email@example.com. You may also write to us via postal mail at, or call us at (415) 464-4640:
Fairview Capital Investment Management, LLC
300 Drake’s Landing Road, Suite 250
Greenbrae, CA 94904
Attn: Legal – Privacy