Policy Effective Date: Nov 9, 2017
Empire Leads’ number one priority is your trust. Your privacy is essential to earning and keeping that trust. This tenet drives all of the decisions we make, as well as how we gather, use and store any information we acquire from you.
Empire Leads’s servers automatically record certain information (“Non-Identifiable” or “Aggregated Data”) about your use or evaluation of our Service. Similar to other technology platforms and services, Empire Leads records information such as browsing activity, data displayed or clicked on (such as UI elements, ads, and links), and other information (such as browser type, IP address, date and time of access, cookie ID, and referrer URL). Along with cookies, Empire Leads may also use third-party tracking technology, such as Google Analytics, to record similar information regarding you and your activity on the Site.
We collect personal information such as name, address, telephone number and other optional information you may provide, such as your age, investable assets, and risk tolerance, which may include your financial goals and objectives, income information and other financial planning information about your household.
We may collect your e-mail address and/or telephone number should you opt to engage via our website, mobile app, email or dedicated telephone number with our client service team.
We also collect account numbers and login credentials for the accounts (bank or brokerage) you choose to link to our Service, any challenge and/or security questions associated with those accounts and any information contained in those accounts.
If you choose to become a Client, in addition to the information we collect from you as a User, as described above, we will ask you for certain information, including, but not limited to, your full legal name, contact information, birth date, Social Security Number, citizenship, investment objectives, approximate net worth, and other regulatory disclosures that may be necessary and required under Federal and certain statutory law (see our Client Agreement).
Empire Leads offers services, like the Portfolio Review, where Empire Leads acts as an agent to retrieve your financial account information, such as your account balances, transactions and holdings, from financial institutions you designate. Portfolio Review is an optional Service you may utilize by providing financial account credentials, allowing us to securely connect with third-party financial institutions.
By accessing and using the Empire Leads services, including but not limited to, Portfolio Review Service, you expressly authorize and direct Empire Leads, on your behalf, to electronically retrieve your account information maintained by third-party financial institutions with which you have a legally binding customer relationship (“Account Information”). Empire Leads may work with one or more third-party financial service technology providers to access and retrieve your Account Information.
Empire Leads is not responsible for and cannot guarantee the accuracy or timeliness of Account Information we retrieve on your behalf directly, from third-party technology providers, from third-party financial institutions where your accounts are held, or from third-party market data providers used to provide the Services.
Empire Leads stores, processes, and maintains data related to you in order to provide client support, offer new products or services and provide our Service to Clients in accordance with the rules of regulatory bodies such as the Securities and Exchange Commission and FINRA. You may choose not to provide such information to us, but if you choose not to provide such information, you will not be able to become a Client.
We may share the information required to become a Client with our brokerage partner solely for the purpose of allowing our brokerage partner to provide services to you.
Empire Leads may use your Personal Data to communicate with you regarding our Service or to tell you about blog posts or services that we believe will be of interest to you. If you decide at any time that you no longer wish to receive marketing communications from us, please follow the “unsubscribe” instructions provided in the communications. Please note that you cannot opt-out of administrative communications such as regulatory, billing or service notifications.
There are certain circumstances, outlined below, in which we may share your Personal Data without further disclosure to you. From time-to-time, we hire other companies to perform certain business and technology related functions (e.g. mailing information, database maintenance and payment processing). In the case we hire another company to perform a function of this kind, we only provide them with the minimum information they need to perform their specific function. Empire Leads maintains strict physical, electronic and procedural safeguards that comply with federal standards to guard your Non-Public personal information.
Except as required by law or requested by regulatory authorities, Empire Leads agrees to maintain your non-public Personal Data in strict confidence.
You may request deletion of personal information by emailing firstname.lastname@example.org and providing us with enough information to identify your account and prove that you are the owner of the identified account. We will endeavour to make any deletion request effective as soon as reasonably practicable. However, we may retain residual information related to your account, as well as any data related to your trades, in accordance with applicable laws. In no case will we share any individual trading data unless required by regulators or other government bodies.
You may decline to provide personal information to Empire Leads. Declining to provide personal information may disqualify you from Empire Leads services and Site features that require certain personal information.
Empire Leads takes reasonable steps to protect your Personal Data from loss, misuse, and unauthorized access, alteration, disclosure, or destruction. No Internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error free so, please take special care in deciding what information you send to us in this manner.
We do not allow third-party advertising on our Website or Mobile applications.
Empire Leads manages a referral program called “The Empire Leads Invite Program.” The program allows our clients to receive a finders fee in exchange for referring other users who ultimately become a client. Participation in our referral program is free and voluntary for our clients. By participating, you may provide us with certain information about the person to whom you refer our services, such as name and e-mail address. We treat this information like all our other Personal Data.
Empire Leads is not to be used by anyone under the age of 18 and, as such does not knowingly collect Personal Data from anyone under the age of 18. If you are under the age of 18, please do not submit any Personal Data to Empire Leads. If a parent or guardian becomes aware that his or her child under the age of 18 has provided us with personally identifiable information without his or her consent, he or she should contact us at email@example.com and we will delete such information from our files.