Privacy

PRIVACY POLICY 

Promontory Financial Group, LLC and its affiliates ("Promontory" or "we") are committed to protecting the privacy of visitors to our Website and others who request information about Promontory. In such cases we record and distribute personal information within Promontory solely in order to respond to requests for information about Promontory. This privacy policy explains the guidelines we use in protecting your privacy.

Promontory Financial Group, LLC has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program covers only information that is collected through this Web site, www.promontory.com.

TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy Trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at customer-privacy@promontory.com. If you are not satisfied with our response you can contact TRUSTe here.

Safe Harbor 

Consistent with its commitment to protect personal privacy, Promontory complies with the principles set forth in the U.S.-EU Safe Harbor and the U.S.-Swiss Safe Harbor (the “Safe Harbor Privacy Principles”) as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from European Union member countries and Switzerland. Promontory has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Promontory’s certification, please visit www.export.gov/safeharbor.

Collection of Visitor Information

When you visit our Website, we collect and temporarily store information about the Internet connection and the date and time of the visit through the use of cookies. Cookies are small pieces of data which are sent by a website to your web browser and are stored on your computer. We use this information to learn about visits to our Website pages, the information that is accessed, and the frequency of visits. We may use this information to assist us in resolving technical issues. If you are concerned about the use of cookies, you may configure your web browser to either request your specific acceptance of a cookie or disable cookies entirely. Refusing or disabling cookies will not affect your ability to navigate our Website.

We also collect information you provide to us. As a visitor to the Promontory Website, or as one who has otherwise requested information about Promontory, you may choose to provide us with your name, e-mail address, and other contact information (such as your mailing address and telephone number). We will use the information you provide us for the purpose of responding to your request. We reserve the right to collect and use for any lawful purpose any data you enter, aggregate data derived from such data, and usage patterns such as clickstreams.

Third Party Applications

Promontory uses a variety of services hosted by third parties to help enhance and understand the use of our Website. These companies are authorized to use your personal information only as necessary to provide these services to us. These services may use cookies and collect other information sent by your browser as part of a web page request, including your IP address. This information is processed by these third party tools to generate statistical usage information for the Website and individual pages on the Website, including your geographic location and how your browser arrived at the Website. The collection of this information will allow us to better understand and improve the performance, usability, and effectiveness of our Website.

Disclosure of Information

Promontory will not sell or distribute your information to third parties. If you have voluntarily submitted personal information to us through an e-mail, by telephone, or otherwise, Promontory maintains your privacy by ensuring that the information is distributed only within Promontory. This enables us to respond to your requests about our services and our company.

We may also disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

If Promontory is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

User Access and Choice

If your personal information changes, or if you no longer desire our service, you may correct, update, amend, delete/remove, or deactivate it by making the change on our member information page [or by emailing our Customer Support at customer-privacy@promontory.com or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your request to access within 30 days.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or you can contact us at customer-privacy@promontory.com.

Security

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

Links to 3rd Party Sites

Our Site includes links to other Web sites whose privacy practices may differ from those of Promontory. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.

Social Media Widgets

Our Web site includes Social Media Features, such as the Facebook button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Notifications of Changes

If we change our privacy statement, we will post those changes to this privacy statement at www.promontory.com. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Conclusion

We recognize the importance of protecting privacy, and we take our responsibility seriously. If you have any questions about our Privacy Policy, please send an e-mail to customer-privacy@promontory.com.

Promontory Privacy Office
801 17th Street, Suite 1100
Washington, DC 20006

This document was last updated June 6, 2013. 

SAFE HARBOR PRIVACY POLICY

Promontory Financial Group, LLC (“Promontory”) respects individual privacy and values the confidence of its clients, employees, business partners and others. Not only does Promontory strive to collect, receive, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it is also committed to upholding the highest ethical standards in its business practices. This Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles Promontory follows with respect to transfers of client and third-party personal information from the European Economic Area (EEA) (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and from Switzerland to the United States.

Safe Harbor

Consistent with its commitment to protect personal privacy, Promontory complies with the principles set forth in the U.S.-EU Safe Harbor and the U.S.-Swiss Safe Harbor (the “Safe Harbor Privacy Principles”) as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from European Union member countries and Switzerland. Promontory has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Promontory’s certification, please visit www.export.gov/safeharbor.

Scope

This Safe Harbor Privacy Policy (the “Policy”) applies to client and third-party personal information received by Promontory in the United States from the EEA and from Switzerland, in any format, including electronic, paper or verbal other than information collected by Promontory from its employees and consultants.

TRUSTe Certification

Promontory Financial Group, LLC has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability and choice regarding the collection and use of your personal information. This TRUSTe program covers only information that Promontory collects when acting as a data processor on behalf of their clients.

Definitions

For purposes of this Policy, the following definitions shall apply:

  • “Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Promontory or to which Promontory discloses personal information for use on Promontory's behalf.
  • “Client” means any third party that retains Promontory to perform professional services on behalf of such third party.
  • “Promontory” means Promontory Financial Group, LLC its predecessors, successors and affiliates in the United States.
  • “Personal information” means any information or set of information that identifies or could be used by or on behalf of Promontory to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.
  • “Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, Promontory will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

Privacy Principles

The privacy principles in this Policy have been developed based on the Safe Harbor Principles.

NOTICE: Promontory collects personal information directly from individuals in the EEA only when an individual contacts Promontory through Promontory’s website. Promontory’s Privacy Policy is found on its website. Promontory’s Privacy Policy provides information about the purposes for which it collects and uses personal information about such individuals, the choices and means, if any, Promontory offers them for limiting the use and disclosure of personal information about them, and how to contact Promontory. Promontory does not transfer this information collected on Promontory’s website on to third parties. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Promontory.

Where Promontory receives personal information from other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

When acting as a data processor, Promontory collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. Promontory’s contracts with its Clients require compliance with data protection laws, including appropriate notice to customers.

CHOICE: To the extent permitted by the Safe Harbor Agreement, Promontory reserves the right to process personal information in the course of providing professional services to our clients without the knowledge of individuals involved, including any supplementation of the information through publically available sources as Promontory may deem necessary to fulfill its obligations to its clients.

When Promontory collects information directly from individuals through its website, Promontory will not (a) disclose information to a non-agent third party or (b) use information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

DATA INTEGRITY: Promontory will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Promontory will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current. Promontory will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. As for data collected on our website, we will retain your information for as long as your account is active or as needed to provide you services. Promontory will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Transfers To Agents

Promontory may transfer personal information that we process on behalf of our clients to companies acting as Agents that help us provide our service when necessary. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients.

Promontory will obtain assurances from its Agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), being subject to Swiss Federal Act on Data Protection, Safe Harbor certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where Promontory has knowledge that an Agent is using or disclosing personal information in a manner contrary to this Policy, Promontory will take reasonable steps to prevent or stop the use or disclosure.

We may also disclose personal information as required by law, such as to comply with a subpoena, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, to any other third party with your prior consent to do so.

Access And Correction

Upon request, Promontory will grant individuals reasonable access to personal information that it has obtained through requests on its website. In addition, Promontory will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. We will respond to your request to access within 30 days.

When acting as a data processor, Promontory has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to Promontory’s Client (the data controller). To the extent permitted by law, rule or regulation, if the Client requests Promontory to remove the data, we will respond to their request within 30 days.

SECURITY: Promontory will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the Promontory Privacy Office at the address given below. Promontory will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy. For complaints that cannot be resolved between Promontory and the complainant, Promontory has agreed to TRUSTe dispute resolution for disputes involving personal information received by Promontory from the EEA and Switzerland. Individuals who submit a question or concern to Promontory and who do not receive acknowledgment from Promontory of the inquiry or who think their question or concern has not been satisfactorily addressed should then contact the TRUSTe Safe Harbor Dispute Resolution Program online at https://feedback-form.truste.com/watchdog/request TRUSTe will act as a liaison to Promontory to resolve these disputes. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy Trustmark and innovative trust solutions. For information about TRUSTe or the operation of TRUSTe's dispute resolution process, visit TRUSTe on the Internet. The TRUSTe dispute resolution process shall be conducted in English.

Limitation On Application Of Principles

Adherence by Promontory to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations and (c) to the extent expressly permitted by an applicable law, rule or regulation.

Internet Privacy

Promontory sees the Internet and the use of other technology as valuable tools to communicate and interact with employees, business partners and others. Promontory is committed to protecting the privacy of visitors to our Website and others who request information about Promontory and has created a Privacy Policy (the "Privacy Policy") governing the treatment of personal information collected through Website that it operates. With respect to personal information that is transferred from the European Economic Area or Switzerland to the U.S., the Privacy Policy is subordinate to this Policy. However, the Privacy Policy also reflects additional legal requirements and evolving standards with respect to Internet privacy. Promontory's Privacy Policy can be found at http://www.promontory.com/PrivacyPolicy.aspx.

Contact Information

Questions or comments regarding this Policy should be submitted to the Promontory Privacy Office by mail to:

Promontory Privacy Office
801 17th Street, Suite 1100
Washington, DC 20006

Or by e-mail to the Promontory Privacy Office at customer-privacy@promontory.com  

Changes To This Safe Harbor Privacy Policy

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on the Promontory web page (www.promontory.com) prior to the change becoming effective whenever this Safe Harbor Privacy Policy is changed in a material way.

EFFECTIVE DATE: June 6, 2013