SPECTRUM MANAGEMENT GROUP, INC.
February 28, 2019
Spectrum Management Group, Inc. (the “Company” or “Spectrum”) provides investment advisory services to you by means of its own internal operation and unaffiliated third-party service and product providers (for example, the account custodian, which processes the investment transactions for your account). The Company and the product and services providers we use receive and maintain information about you and your business that is related to the services we provide to you. In this regard, federal law requires us to tell you how we collect, share, and protect your personal information.
The safeguarding of client information is an issue we take seriously, and we want to assure all of our clients that whenever information is collected and used, it is done so with discretion. To affirm our continuing commitment to the proper use of client information, we have set forth the following privacy notices and principles, which are designed to guide us in serving the privacy needs of our clients.
RECOGNITION OF CLIENTS’ EXPECTATION OF PRIVACY. At Spectrum, we believe the confidentiality and protection of client information is one of our fundamental responsibilities. Moreover, while information is critical to providing quality services to you, we recognize that one of our most important assets is our clients’ trust. Thus, the safekeeping of client information is a priority for the Company.
CATEGORIES OF INFORMATION SPECTRUM COLLECTS. In order to meet your needs in the course of providing investment advisory services to you, Spectrum may collect the following nonpublic personal information about you:
WHERE DO WE OBTAIN THE INFORMATION. Primarily, the information we have comes directly from you, which you provide on applications, agreements, or other forms. In addition, we maintain records of investments owned by you, account numbers and names of executing and clearing brokers and investment advisers, and information about the transactions and holdings in such accounts. Further, we maintain various correspondence that you provide us, which may include written, telephonic, or electronic communications. Finally, we may receive information from consumer reporting agencies, governmental agencies, employers, or others whom you have authorized to disclose information to us.
- Your name, address, telephone number, social security number or taxpayer ID number, and date of birth;
- Employment status, annual income, total assets, and net worth;
- Accounts at other financial institutions, including lists of investments, account numbers and balances, names of executing and clearing brokers and investment advisers, types of transactions you enter into, parties to the transactions, and investment history;
- Information received from consumer reporting agencies, such as credit reports; and
- Information you have authorized us to receive from government agencies, employers, or others
TO WHOM DO WE DISCLOSE THE INFORMATION. We provide information about current or former clients from the sources described above to parties outside of our firm only as described below:
To other companies as necessary to provide services to you and to process your business. From time to time, we may have relationships with nonaffiliated third parties (such as attorneys, auditors, accountants, brokers, custodians, and other consultants) who, in the ordinary course of providing their services to us, may require access to your information. For example, we process your investment instructions through product and service providers with whom we have business agreements. These service providers are necessary for us to provide our investment advisory services to you. These parties must limit their use of the information to the purposes for which it was provided.
Where required by law or regulation. Examples include responses to a subpoena, court order, or regulatory demand.
As authorized by you. You may direct us, for example, to send information about your investment holdings, account, or other financial information to a third party.
As otherwise authorized or permitted by law. For example, the law permits us to respond to a request for information about you from a consumer-reporting agency.
CONFIDENTIALITY AND SECURITY. We restrict access to information about you to those employees and authorized agents who need to know that information in order to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to maintain the confidentiality of your information.
SPECTRUM MANAGEMENT GROUP
Effective Date: 7/1/2015
- Collects information about you;
- What kinds of information we collect about you;
- How we may use your information;
- How we may share your information with others;
- How we protect your information; and
- The choices you have about the collection and use of your information.
What Are The Spectrum “Services”? This Policy applies to your use of the Site, as well as all websites, webpages, software, services, features, information and/or content associated with the Site (collectively, the “Services”).
Who Is Eligible To Use The Services? Spectrum’s Services are intended for use by adults, and are not directed to minors under the age of 18. Consistent with the Children’s Online Privacy Protection Act of 1998 (COPPA), Spectrum does not knowingly collect personally identifiable information from children under the age of 13 without parental consent. If we learn that personally identifiable information of a child under the age of 13 has been submitted via or appears on or within Services, Spectrum will take all action necessary to comply with our responsibilities under applicable legal requirements, which may include deletion of any such information.
If you are a minor age 18 years or older, you may have the ability to request removal of certain content or information from the Services. If you wish to request the removal of content or information you have posted on the Services, you may do so by contacting Spectrum at email@example.com. Please note that the removal of content or information does not ensure complete or comprehensive removal of the content or information posted.
SPECTRUM’S COLLECTION & USE OF YOUR INFORMATION
What Information Does Spectrum Collect About Me, And How Is It Used? Spectrum may gather various types of information about you when you access or use our Services. Spectrum may collect information about you in a variety of ways, including:
- Information you provide to us, such as when you register for a Spectrum Account, complete our Contact Us form, sign up for an email newsletter, or request information from Spectrum;
- Information we collect about you automatically, such as through analytics, cookies, IP Address, log file, and web beacon information; and
- Information collected from other websites and services, such as information collected via cookies placed on your web browser or mobile device.
We may use the information we collect from and about you in a number of ways, including to:
- Operate, maintain, improve, and provide the Services;
- Provide you with personalized content and information about Spectrum;
- Provide information to you pursuant to a request from you; and
- Provide advertising and marketing, including customized and interest-based advertising;
Types Of Information Spectrum May Collect About You Include:
A. Personally Identifiable Information
We encourage those interested in Spectrum to visit and browse our Site to learn more about Spectrum’s Services. You can access most of the Services without providing Spectrum any personal about yourself. However, please note Spectrum may collect certain Personally Identifiable Information about you through your use of our Services in a number of ways, including information you provide to us to create an account, by filling out an online form, by signing up for our email newsletters, or by providing the information to Spectrum. “Personally Identifiable Information” refers to information about you that, with reasonable efforts, may be used to identify you, such as your: first name, last name, gender, birth date, city, state, zip code, addresses, locations, email address, or phone number. We may combine the Personally Identifiable Information we collect about you with additional information we collect about you or obtain from third-party sources. Spectrum may use this information for marketing and advertising purposes.
In order for us to provide you with certain Services, it may be necessary for Spectrum to obtain and share Personally Identifiable Information with others. You are not required to provide us with Personally Identifiable Information, and you can decline certain transfers of Personally Identifiable Information, if you wish. However, please be aware that if you choose to withhold certain Personally Identifiable Information, Spectrum may not always be able to provide you with certain Services.
B. Spectrum Account Information
In certain circumstances, such as when you become a client of Spectrum, Spectrum may require you to register for an account in order to use and access certain Services (a “Spectrum Account”). Spectrum may collect information about you in connection with your registration for your Spectrum Account, which may include Personally Identifiable Information such as your name, home address, telephone number, email address, and other information.
C. Correspondence Information
We may receive and store information you provide to us, including Personally Identifiable Information. If you send us correspondence via email, the postal service, or other form of communication, we may retain such correspondence and the information provided therein, and may use this information to respond to your inquiry or to provide notifications or other correspondences to you.
D. Newsletters, Correspondence, And Mailing List Information
If you elect to receive our newsletters or other publications, join our mailing lists, or provide your email address to us, we may collect certain contact or demographic information about you, which you agree we may use to send you correspondences about a variety of topics related to Spectrum, such as events, new products, sales, and promotional offers from Spectrum, our affiliates, or our business partners.
By subscribing to our mailing lists, you agree to receive newsletters and other correspondence which may include special offers or incentives from select partners. If you no longer wish to receive such correspondence from Spectrum or our partners, you may opt-out of receiving these communications according to information provided within the correspondence, or by contacting us using the contact information provided below.
E. Analytics & Aggregate Information
We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Services. These tools may collect information sent by your browser or mobile device, including the pages you visit and other information that assists us in improving the Services. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user.
F. Cookies, Web Beacons And Other Tracking Technologies
Like many other websites, software services, and mobile applications, Spectrum may automatically collect certain information and data from your browser or device through the use of “cookies,” “web beacons,” and other tracking technologies. Through these technologies we may collect information about your use of the Services and other online activity, including certain online activity after you leave the Services.
When you use the Site, we may send one or more “cookies,” a small text file containing a string of alphanumeric characters, to your computer that uniquely identifies your browser and lets Spectrum help you log in faster and enhance your navigation through the Services. A cookie may also convey information to us about how you use the Services, for example, the pages you view, the links you click, and other actions you take on the Services, and allow us or our Service Providers to track your usage of the Services over time. Persistent cookies may remain on your device’s hard drive after you close your browser or device and may be used by your device on subsequent use of the Services. Persistent cookies can be removed by following the directions according to your particular device or web browser. Session cookies are temporary and disappear after you close your browser or device. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Site may not function properly if the ability to accept cookies is disabled.
You have many choices with regards to the management of cookies on your devices. All major browsers now allow you to block or delete cookies from your system. We encourage you to learn more about your ability to manage cookies and web beacons by consulting the privacy features of your devices and browsers.
G. Unique Identifiers
When you use or access the Services, we may access, collect, monitor, store on your device, and/or remotely store one or more "Unique Identifiers," such as a universally unique identifier (“UUID”). These Unique Identifiers may be associated with your device, whether or not you establish a Spectrum Account. Unique Identifiers are small data files or similar data structures stored on or associated with your device that uniquely identify your device. A Unique Identifier may be data stored in connection with the device hardware, in connection with the device's operating system or other software, or via data sent to the device by Spectrum. A Unique Identifier may convey information to Spectrum or to a third party partner about how you browse and use the Services and may help us or others provide reports or personalized content and advertisements. A Unique Identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Services. Some features of the Services may not function properly if use or availability of Unique Identifiers is impaired or disabled.
H. Log File Information
I. Do Not Track
Spectrum does not currently employ a process for automatically responding to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms that may provide consumers a choice regarding the collection of Personally Identifiable Information about an individual consumer’s online activities. As is commonly the case with many other mobile applications and websites, third parties (e.g., advertisers) may be able to collect Personally Identifiable Information about your online activities over time and across different websites or online services when you use Services.
J. Location Information
When you access the Services, including visiting the Sites or using any other website or mobile application software provided by Spectrum within the Services, we may access, collect, monitor and/or remotely store “location data,” which may include your address, zip code, GPS coordinates (e.g. latitude and/or longitude), or similar information regarding the location of you or your computer or other device (“Location Information.”) Your Location Information allows us to provide information about Spectrum in your area, including providing information on nearby Spectrum dealers. Your Location Information may also be used to display your location on a map to other Users. Location data may convey to us information about how you browse and use the Services. Some features of the Services, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.
K. Third-Party Advertisements
Spectrum may utilize the services of third-party advertising companies, including Google and others, to serve ads to you when you visit our Site, or to perform remarketing services on other sites across the Internet. These third parties may collect certain information about your use of the Services and may use technology like cookies to store information about your use of the Services to improve the marketing and advertisements provided to you. The information collected may be reported back to us, and we may link this information to information we have collected about you. More information about interest-based advertising and similar practices may be available at http://www.networkadvertising.org/consumer/opt_out.asp.
HOW SPECTRUM MAY SHARE YOUR INFORMATION
How Does Spectrum Share My Information With Others? Spectrum does not share, sell, rent, or otherwise disclose your information to third parties without your consent, except as described in this Agreement. Spectrum may share Personally Identifiable Information or other information about you with third parties for the following purposes and circumstances:
- With Your Authorization: We have your authorization, whether by the terms of this Agreement or as provided through other means;
- To Provide the Services: We need to share your information to provide a product or Service you have requested, including sharing the information with companies or organizations connected or affiliated with Spectrum, such as subsidiaries, sister-companies, and parent companies;
- To Our Business Partners: To third-party business partners or Service Providers (as defined below) for the purpose of providing the Services to you, such as parties who host our servers, analyze our data, provide us with marketing assistance, process credit card payments, and provide customer service;
- Analytics Data & Information: We may share certain service types information, including information obtained through tools such as cookies, log files, device identifiers, location data and clear gifs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with our third-party business partners or Service Providers for the purposes described herein. We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties
- Publicly Available Information: The information to be disclosed is publicly available;
- Consistent With Its Purpose: The disclosure is consistent with the purpose for which the information was obtained.
If Spectrum becomes aware that any authorized party is improperly using or disclosing information, we will take commercially reasonable steps to end or correct such improper use or disclosure.
Spectrum May Also Disclose Your Information For The Following Purposes & Circumstances:
A. To Spectrum Personnel
Spectrum’s personnel and authorized partners may have access to your information as needed to operate the Services the normal course of business.
B. To Our Service Providers
We may share your information, as well as information from data collection tools like cookies, Web Beacons, log files, Unique Identifiers, and location data (such as usage data, referring/exit pages, and URLs, platform types, number of clicks, etc.), with individuals and organizations that help us provide the Services to you ("Service Providers"). We may use such Service Providers to help operate the Services and our business, for example, to host the Services, to send emails and other correspondences to you about the Services, to process payments, to facilitate online job applications, to provide search results, or to provide advertising. Our Service Providers may have access to your information for use for a limited time in connection with these activities.
C. As a Part of Business Transfers
Spectrum may purchase other businesses or their assets, or sell our business assets. Personally Identifiable Information is commonly a business asset involved in such transactions. Please be aware your Personally Identifiable Information and Spectrum Account information may be among the transferred assets in the event Spectrum or all or a portion of its assets are sold or acquired.
D. To Financial Institutions
For certain Services or promotions, Spectrum may make your Personally Identifiable Information available to one or more financial institutions in order to fulfill and carry out the purchase and provision of goods and services requested. By providing your Personally Identifiable Information to us for these purposes, you authorize us to exchange your Personally Identifiable Information with such financial institutions.
E. Pursuant to Lawful Requests
We may be required to disclose user information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. We generally do not reveal information until we have a good faith belief that an information request by law enforcement or private litigants meets applicable legal standards. Additionally, we may share your Spectrum Account or other information when we believe it is necessary to comply with applicable laws, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Services or using the Spectrum name, or to prevent bodily harm. This may include sharing information with other companies, lawyers, agents or government agencies.
F. For the Protection of Spectrum and Others
HOW SPECTRUM PROTECTS YOUR INFORMATION
How Does Spectrum Secure My Information? Spectrum takes reasonable efforts to secure and protect the privacy, accuracy, and reliability of your information and to protect such information from loss, misuse, unauthorized access, disclosure, alteration and destruction. Spectrum implements security measures as we deem appropriate and consistent with industry standards to protect Personally Identifiable Information. However, since no data security protocol is impenetrable, Spectrum cannot guarantee the security of our systems or databases, nor can we guarantee that Personally Identifiable Information we collect about you will not be breached, intercepted, destroyed, accessed, or otherwise disclosed without authorization. As a result, any information you transfer to or from Services is provided at your own risk.
Please do your part to help us keep your information secure. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and Spectrum, at all times. Your privacy settings may also be affected by changes the social media services you connect to Spectrum make to their services. We are not responsible for the functionality, privacy, or security measures of any other organization.
Please be aware that email and other electronic communications are highly susceptible to hacking and other security breaches. When you communicate with Spectrum via email or other electronic means, these communications may not be secure. For that reason, we ask that you do not share sensitive information with us via electronic communication channels without taking precautions to ensure the security of the communication. Spectrum is not responsible for any breaches of data or security resulting from your electronic communications with Spectrum.
Are My Communications With Spectrum Secure? Communications you may have with us via email or postal mail generally should not be considered secure, unless we advise you that specific security measures are in place prior to your sending information. Therefore, we request that you do not send or post sensitive information through these means. You assume the risk that your communications with Spectrum may not be secure.
Should I Secure My Spectrum Account And Passwords? In the event you create a Spectrum Account, your account information will be protected by a password you select. We strongly recommend you choose a strong password and take appropriate steps to ensure your password is not disclosed to any other person. You are responsible for maintaining the confidentiality of your password and Spectrum Account, and are fully responsible for all activities that occur under your password or Spectrum Account. Spectrum specifically reserves the right to terminate your access to Services and any contract you have with Spectrum related to Services in the event it learns or suspects you have disclosed your Spectrum Account or password information to an unauthorized third party.
What If There is a Data Security Incident? In the event that any information under our control is compromised as a result of a breach of security or other data security incident, Spectrum will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with applicable laws and regulations.
YOUR CHOICES ABOUT YOUR INFORMATION
Do I Have Access To The Information Spectrum Has Collected About Me? Spectrum welcomes you to contact us regarding the information we have collected about you via email at firstname.lastname@example.org or using the contact information provided below, including regarding:
- Whether Spectrum is keeping information about you;
- The accuracy of the information Spectrum is keeping;
- To challenge the data that Spectrum is keeping about you;
- How Spectrum is using your information or sharing your information with others;
- To update or delete your information; and
- To opt-out of the collection and use of your information.
When you contact us, please be sure to specify the details of your request. We may require proof of your identity before we provide you with the requested information. Requests to delete or remove your information does not ensure complete or comprehensive removal of the content or information posted and removed information may persist in backup copies for a period of time.
Please note that if you choose to delete your information or opt-out of the collection and use of your information, you understand that certain features or services, including but not limited to access to the Services, may no longer be available to you, and that Spectrum specifically reserves the right to terminate your access to the Services and any contract you have with Spectrum related to the Services.
Can I Opt-Out of Communications from Spectrum? You may unsubscribe from email communications from us by clicking on the "unsubscribe” link provided within the communication. You may not, however, opt-out of Services-related communications, for example, account verification, purchase and billing confirmations and reminders, changes or updates to features of the Services, or technical and security notices.
How Long Does Spectrum Keep My Information? We may store the information we collect about you indefinitely, but information generally will be retained only for as long as necessary to fulfill the purposes for which the information was collected, or as otherwise required by law. Following termination or deactivation of your Spectrum Account, Spectrum may retain your information and content for a commercially reasonable time for backup, archival, and audit purposes.
ADDITIONAL PROVISIONS REGARDING SPECTRUM’S SERVICES & YOUR INFORMATION
Please be aware that third party websites may be able to link certain information about your site visit to information they have may have collected or been provided about you. However, we are not responsible for the privacy practices of any other site, and we are not liable for their use, or misuse, of your information. We encourage you to carefully read the privacy policies of any other websites you may visit to better understand their privacy practices and associated risks, and to contact them with any questions.
Does Spectrum Warranty Information It Provides Via The Services? No. Access to the information provided by the Services is provided by Spectrum as a service to its customers, website visitors, and users of its Services, without warranty of any kind. References herein to any product, process, or service do not constitute or imply endorsement or recommendation by Spectrum. While Spectrum makes every effort to present accurate and reliable information on the Site, Spectrum does not approve or certify such information and does not guarantee the accuracy, completeness, efficacy, timeliness, or sequencing of such information. Your use of such information is voluntary, and reliance on it should only be undertaken after an independent review of its applicability, accuracy, completeness, efficacy, and timeliness with regard to your specific needs and uses. Spectrum (including its employees and agents) is not responsible for, and expressly disclaims all liability for, damages of any kind arising out of use, reference to or reliance on the information available through the Services. No approvals, recommendations, endorsements, guarantees, or warranties, including, but not limited to, any express or implied warranties of merchantability or fitness for any particular use or purpose of products or services named through the Services are made by Spectrum.
Where Is My Information Transferred Or Stored? Please note information Spectrum collects about you may be transferred, processed and/or accessed by us in the United States, or another country where we, or our Service Providers, operate. Please be aware Personally Identifiable Information may be transferred to, and maintained on, computers located outside of your state or country where the privacy laws may differ from and may not be as protective as those where you live. If you are located outside the United States and choose to allow us to collect information about you, please be aware that Spectrum may transfer your Personally Identifiable Information to the United States and process and store it there. By allowing collection of your Personally Identifiable Information, you consent to having your personal data transferred to, processed, and stored in the United States.
How Can I Contact Spectrum? Spectrum welcomes you to contact us regarding whether Spectrum is keeping information about you, the information Spectrum is keeping, how Spectrum is using your information or sharing your information with others, to update or delete your information, or to opt-out of the collection and use of your information. The Services are offered by Spectrum Management Group, Inc., which maintains a business address at 600 East 96th Street, Suite 130, Indianapolis, IN 46240. You may contact Spectrum at email@example.com.