Effective Date: July 10, 2013
If you have questions about this policy, please feel free to contact us at:
eVALUEator Services, L.L.C.
1055 Maitland Center Commons
Maitland FL 32751 USA
Toll-Free: (888) 469-3863 (U.S. Only)
Fax: (407) 982-2434
1. Information We Collect
In describing our collection, use, and sharing of information in this Policy, we refer to our collection and use of "Personal Information." "Personal Information," as used in this Policy, is personally identifiable information, which is information that directly identifies an individual, such as first and last name, mailing address, email address, billing information, IP addresses, demographics, passwords or other online contact information, or telephone number. We collect Personal Information, as well as non-personally identifiable information on eVALUEator Sites and/or Services.
We collect Personal Information in two ways. First, we collect information you provide to us in optional, voluntary submissions, such as in registration forms, and requests for mutual fund or stock reports. Second, some Personal Information may be collected automatically. This is described below in "Passive Data Collection."
We may also obtain information, including Personal Information, from third party sources. If we directly combine information from third parties with Personal Information that we have collected, we will treat the combined information as Personal Information and handle it in accordance with this Policy. In addition, please note that we may solicit third parties to collect Personal Information on our behalf and in such cases we instruct those third parties to comply with this Policy and all applicable data protection laws.
You are under no obligation to provide, and can decline to provide, any requested information at any time. However, if you decline to provide personal information that is reasonably necessary to participate in certain activities, you may not be able to participate in those activities on certain Sites and/or Services.
Passive Data Collection
We may receive passively-collected information through a variety of methods including but not limited to:
We may use a variety of methods, including "cookies" to collect information.
What is a cookie?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device. You can find more information about cookies at: www.allaboutcookies.org and http://www.youronlinechoices.com/uk/.
For a video about cookies visit www.google.co.uk/goodtoknow/data-on-the-web/cookies
Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that advertisements you see online are more relevant to you and your interests.
The cookies used on our Sites and/or Services have been categorized based on the categories found in the ICC UK Cookie guide. A list of all the cookies used on our Sites and/or Services by category is set out below.
eVALUEator collects cookies on our Sites and/or Services to capture information about page visits (e.g. “performance cookies.”) This information is anonymous and eVALUEator uses this information only internally - to deliver the most effective content to our visitors. Information from the cookie is used to gauge page popularity, analyze traffic patterns on our Sites and/or Services and guide development of other improvements to our Sites and/or Services.
Targeting, Performance, and Functionality Cookies
In our email programs, eVALUEator employs some tracking methods (e.g. “targeting, performance, and functionality cookies”). We track “opens” via a tracking pixel in the email - meaning we track who opens our e-mail messages and when you open our e-mail messages; and we track “clicks” via encoded URLs -meaning we track whether you click on the links contained in our e-mail messages. This information is used internally only to help us deliver relevant messaging, and is not shared with any third parties.
Functionality and Necessary Cookies
Opting Out of Cookies
You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. You may also change your cookie settings through preference options in our Sites and/or Services, where applicable. We will indicate that upon selecting your preferences, that we will use a cookie to remember your preferences.
If you choose to provide Personal Information about yourself, eVALUEator will use this information to communicate directly with you. eVALUEator will not sell, rent or otherwise disclose that information to third parties unless such disclosure is necessary for the purposes set forth in this Policy, by law or a policy or notice contained or associated with a specific Site(s) and/or Service(s).
eVALUEator will provide your info to your personal financial advisor or the financial advisor of your choice, or, unless you opt out by not completing the online request, eVALUEator will provide your information to a financial advisor in your general geographic area to deliver the free report you requested. If you choose to opt out by not completing the online request, the report you desire to receive will be available by emailing your request to eVALUEator Services at email@example.com.
We use analytics tools and other third party technologies, such as Google Analytics and DoubleClick Cookies, to collect non-personal information in the form of various usage and user metrics when you use our online Sites and/or Services. These tools and technologies collect and analyze certain types of information, including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage and purchase history, MAC Address, mobile unique device ID, and other similar information.
The third party analytics companies who collect information on our Sites and/or Services and other online products and/or services may combine the information collected with other information they have independently collected from other websites and/or other online or mobile products and services relating to your activities across their network of websites as well as online and/or mobile products and services. Many of these companies collect and use information under their own privacy policies.
In addition to our use of technologies as described herein, we may permit certain third party companies to help us tailor advertising that we think may be of interest to you based on your use of eVALUEator Sites and/or Services and to otherwise collect and use data about your use of eVALUEator Sites and/or Services. For more information about this practice, please see the "Third Party Advertising Technologies" section below.
You may opt out of the DoubleClick cookie by visiting the Google advertising opt-out page or you may opt out of Google Analytics by visiting the Google Analytics opt-out page.
Google has additional information available about their Remarketing Privacy Guidelines, Policies, and Restrictions.
2. How We Use Information
Generally, we use Personal Information to establish and enhance our relationship with our users through four main categories: (1) Communication; (2) Optimization; (3) Advertising; and (4) Sharing Features. Below, we provide some specific examples of how we use the Personal Information and other information we collect.
Communication and Responding to Requests
We use your information, including Personal Information to provide you with customer support, respond to users' requests, send newsletters and updates, send special offers and advertisements, seek your opinions and feedback, and connect users to eVALUEator Sites and/or Services.
We use user information, including Personal Information, behavioral metrics, and other non-personally identifiable information to operate, provide, improve, and maintain our Sites and Services, to develop new products and services, to prevent abuse and fraud, to personalize and display advertisements and other content for you, and for other administrative and internal business purposes.
3. When We Disclose Personal Information
We do not share Personal Information with third parties except in the limited circumstances described in this Policy.
We may provide Personal Information to third parties for their use in performing internal business functions (e.g., payment processing, customer service, maintenance, security, data analysis, email transmission, beta testing, or data hosting) on our behalf. Additionally, some third party service providers may collect information, including Personal Information, on our behalf. Whenever possible, we require such third-parties to only collect and use Personal Information in accordance with this Policy, to maintain the confidentiality, security, and integrity of such Personal Information, and for no purpose other than providing us with our requested services.
Change of Ownership
Information about our users, including Personal Information, may be disclosed as part of any bankruptcy, merger, sale, transfer of company assets, acquisition, or similar transaction. In the event of such a transaction in which your Personal Information would be transferred to a third party, we will make reasonable efforts to notify you. For example, we will post a notice of the transfer of Personal Information on our Sites and/or Services and, if we have your email address, we will send notice of the transfer of Personal Information to that email address.
If you use a forum, blog, channel, bulletin board, chat room, user commenting features, or other interactive sharing or social features that may be offered through any of our Sites and/or Services, you should be aware that any Personal Information you submit, display, or publish there is considered publicly available and can be read, collected, used, and disclosed by other users of those features, by us, and other third parties without restriction, except to the extent limited access features are available, if any. To request removal of your personal information from our blog, sharing service or community forum, for example, contact us at the information provided in this Policy. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
4. Third Party Advertising Technologies
5. Children Under 13
We do not knowingly seek or collect Personal Information from users under the age of 13. Children under 13 years old are not allowed to request a free report without a parent’s or guardian's express consent. We recommend that minors over the age of 13 ask their parents for permission before sending any information about themselves to anyone over the Internet.
If you are a minor, please do not send any Personal Information about yourself to us. In the event that we learn that we have collected personal information from a child under the age of 13 without parental consent, we will delete that information as quickly as possible. If you believe that a minor may have provided us Personal Information, please contact us at firstname.lastname@example.org.
Users under 13 years of age, your continued use of the Site and/or Service will be considered by eVALUEator as confirmation that your parent or guardian has expressly consented to the handling of your personal information as described in this Policy as further indicated in the opening paragraph of this Policy.
6. Your Choices
Submitting Personal Information
If you do not want to submit Personal Information that is necessary to provide or use our Sites and/or Services or to fulfill your request, you will not be able to access and/or participate in certain eVALUEator Sites and/or Services. For example, you will not be able to request a free moral mutual fund or stock report. In addition, your refusal to submit Personal Information may limit our ability to respond to your customer support inquiry in a timely fashion.
If you want to remove yourself from individual communications, including marketing promotions, advertisements, updates and email newsletters, simply click the unsubscribe link in the communication or access your Account Settings page when logged in. You also acknowledge and agree that there may be instances where we may elect to notify you about administrative notices regarding your account with us, such as to inform you about changes to our terms, conditions, and policies, that your account may be expiring, or to provide you with other relevant administrative information about your account. Because this information is important to your interaction with us, you may not opt out of receiving these communications.
If you submit Personal Information, you may request deletion of your personal information with us at any time by sending your request to email@example.com. If you delete your Personal Information and any and all other account related information including, but not limited to, user profile data, and any other data or content specifically associated with your account are also permanently deleted. Deletion of your data may take up to 30 days from accessible systems and up to 90 days from backup systems.
We take reasonable measures, including the implementation and maintenance of physical, electronic, and managerial procedures, in an effort to assure the security, integrity, and accuracy of all Personal Information that we collect. Our efforts include procedures designed to avoid unauthorized access, alteration, misuse or disclosure of Personal Information.
If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the eVALUEator Sites and/or Services covered by this Policy and providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your account information and usage.
8. Data Integrity and Data Retention
We collect and use Personal Information in accordance with this Policy and only for the purposes stated in this Policy and/or at the time we request such Personal Information from our users, or for such purposes to which a user may otherwise consent. We do not use or share our users' Personal Information in a way that is incompatible with the purposes for which such Personal Information was requested and authorized for use by us. We retain Personal Information for no longer than is commercially useful to carry out our business purposes, or as we believe may be legally required. When Personal Information is deleted or updated by you, it may take up to 30 days from accessible systems, and up to 90 days from backup systems, for us to delete such Personal Information.
9. Access to Personal Information
If you wish to obtain a report of the Personal Information eVALUEator has about you, please send us a written request at the address set forth in this Policy.
12. Privacy Rights
13. Changes and Updates to This Policy
We may update this Policy from time to time. If we do, we will update the "effective date" at the top of the Policy. If we make material changes to how we use Personal Information, we will attempt to notify you of the change and to give you the opportunity to exercise choice as to how your Personal Information is used. We will post the updated Policy on the affected Sites and/or Service, and if we have your email address, we will send notice of the update to that email address.
We encourage you to review this Policy periodically to stay informed about our collection, use and disclosure of Personal Information. Your continued use of our Sites and/or Services or any other content, products or other services covered by this Policy constitutes your agreement to this Policy and any updates.
14. International Users & U.S.-EU Switzerland Safe Harbor
eVALUEator Sites and/or Services may be hosted in the United States. If you utilize our Sites and/or Services from the European Union or Switzerland, or any other region with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal data outside of those jurisdictions to the United States. The United States does not have the same data protection laws as the European Union, Switzerland and other regions. By providing Personal Information under this Policy, you consent to the use of your Personal Information in accordance with this Policy and the transfer of your Personal Information to the United States.
eVALUEator is committed to complying with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework 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. eVALUEator has certified that it is committed to adhere 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 eVALUEator’s certification, please visit http://www.export.gov/safeharbor/.
16. No Error Free Performance