303 Vintage Park Drive
Last Updated: August 2018
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Protecting Your Personal Information is Important
What Type and Sources of Information We Collect
Categories of Personal Information We Collect
What Personal Information Do We Collect When You Visit our Site?
How is your Personal Information Used?
What Information We Disclose
Limits on Sharing
Lawful Basis for Processing
Will your Personal Information be Kept Accurate, Complete and Up to Date?
Security of our Clients’ Information
Retention of Personal Information
Information about Children
Do We Use “Cookies” or Obtain Personal Information by Automated Means?
Who Can You Contact at NCM?
Additional Information about Cookies
How do We Respond to Do Not Track Signals?
Maintaining your trust and confidence is among our highest priorities. We recognize that protecting the privacy and security of our clients is an important responsibility. That's why we at Neumann Capital Management, LLC want you to understand how we protect your privacy when we collect and use Information about you, and the steps that we take to safeguard that Information.
Like most industries today, the financial services industry continues to be shaped by technology, which is literally changing the way we do business. To be successful in this environment, we must continue to ensure that our clients are confident that we will manage their financial affairs expertly and confidentially.
To affirm our continued commitment to the proper use of client information and protecting your privacy, we have set forth the following privacy policies.
What Type and Sources of Information We Collect
We collect certain personal information that may directly, or indirectly, identify you, including nonpublic personal identifying information (“Personal Information”) from information that you provide on applications or other forms as well as communications (electronic, telephone, written or in person) with you or your authorized representatives (such as your attorney, accountant, etc.). We also collect information about your brokerage accounts and transactions.
The types of Personal Information we collect and share depends on the service you have with us. This information can include:
When you visit our Site, we may collect information from you when you access your account through our “Client Center” which includes your login information. We do not collect any other personal information on our Site.
We will only use your Personal Information with the purpose of providing you with our investment management and financial planning services. We will use your Personal Information to:
Where required by applicable law, we obtain consent to process Personal Information. In the event that we use Personal Information we collect for other purposes not identified above where direct client consent is required under applicable rules, laws and/or regulations we will provide specific notice at the time we collect such Personal Information.
All financial companies need to share client’s personal information to run their everyday business. We do not disclose the nonpublic personal information we collect about our clients to anyone except:
In the section below pursuant to U.S. Federal Laws, we list the reasons financial companies can share their customers’ personal information; the reasons NCM chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information
Does NCM share?
Can you limit this sharing?
For our everyday business purposes— such as to process your transactions, maintain your account(s) or respond to court orders and legal investigations
For our marketing purposes— to offer our products and services to you
For joint marketing with affiliates
For joint marketing with non-affiliates
For our affiliates’ everyday business purposes—
information about your transactions, accounts, etc.
For our non-affiliates’ everyday business purposes— information about your transactions, accounts, etc., as necessary
For our affiliates to market to you
For our non-affiliates to market to you
To the extent U.S. Federal laws apply to your personal information, you have the right to limit only:
U.S. state laws and individual companies may give you additional rights to limit sharing.
NCM may have one or more of the following lawful bases to process your personal information:
To the extent permitted by the applicable law of your jurisdiction, in relation to your personal information, you may request:
In addition to the foregoing, if you are located in the European Economic Area (“EEA"), to the extent permitted by applicable law, in relation to your personal information, you may request:
To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to your information.
To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.
We will endeavor to ensure your personal information is kept accurate, complete, up to date and relevant. Please let us know if any of your details change. If you feel your personal information is not accurate, complete or up to date, please notify us and we will take reasonable steps to ensure it is corrected. You can contact us using the details listed below.
NCM updates and improves security standards and procedures to guard against anyone gaining unauthorized access to your Information, including through the Internet.
We restrict access to your nonpublic personal information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your nonpublic personal information.
As our Site is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
Links to Third-Party Websites. As a convenience to you, NCM may provide hyperlinks to websites operated by third parties. When you select these hyperlinks you will be leaving our Site. NCM has no control over third party websites, their content, or security. Accordingly, when you access these third-party websites it is at your own risk. We encourage you to read the associated privacy policies by such third-party websites to learn more about their data privacy management practices. NCM may, in its sole discretion, block links to our Site and content without prior notice.
To the extent permitted by applicable law, we retain your personal information for the period necessary to serve the purposes for which we obtained it. We may also retain your personal information beyond such period in accordance with applicable laws, regulations, or another lawful basis, including but not limited to, compliance with our contractual obligations, legal obligations, regulatory obligations, legal claims, or another legitimate interest.
The Site is not directed to children under the age of 18 years. By using this Site, you represent and warrant that you are at least 18 years old.
In accordance with the Children’s Online Protection Act (“COPA”), we do not knowingly solicit or collect personal information on this Site from children under the age of 13 without prior verifiable parental consent.
If you are located in the European Economic Area (“EEA"), we will comply with applicable legal requirements regarding the provision of appropriate safeguards for the transfer of personal information to recipients in countries for which the European Commission has not issued an adequacy decision.
We do not use “cookies” on our Site.
Cookies are small text files that are stored in your computer's memory and hard drive when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website. For example, cookies can be used to remember your preferences or count the number of website visitors.
For more information about cookies, please see the Appendix below.
As identified under applicable law, the data controller for this Site is NCM located at the address below.
Who Can You Contact at NCM?
Attention: Daniel J. Neumann, CFA
Neumann Capital Management, LLC
303 Vintage Park Drive, Suite 100
Foster City, CA 94404
Phone: (650) 548-9200
E-mail: [email protected]
Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies.
Nonaffiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies.
Joint Marketing: A formal agreement between nonaffiliated financial companies that together market financial services to you.
Analytical purposes: Analytical cookies allow a website to recognize, measure and track website visitors. This helps the website host improve and develop the way a website works, for example, by determining whether website visitors can find information easily, or by identifying the aspects of the site that are of the most interest to them.
Usage preferences: Some of the cookies on a website are activated when visitors make a choice about their usage of the site. A website then ‘remembers' the settings preferences of the user concerned. This allows the website host to tailor aspects of the site to the individual user.
Terms and conditions: Some website cookies record when a website visitor has seen a policy, such as this one, or provided consent, such as consent to the terms and conditions on the website. This helps to improve the user's experience on the website – for example, it avoids a user from repeatedly being asked to consent to the same terms.
Functional purposes: Functional purpose cookies store information that is needed by certain web applications to process and operate. For example, where transactions or requests within an application involve multiple workflow stages, cookies are used to store the information from each stage temporarily, in order to facilitate completion of the overall transaction or request.
Withdrawing your Consent/Amending Internet Browser Settings to Disable Cookies. You may withdraw your consent from a website that tracks cookies at any time by adjusting your internet browser settings to delete all cookies. If you do this, however, you may have to manually adjust some your internet browser preferences every time you visit a site and some services and functionalities may not work. Specifically, you can use your web browser to:
For more information about cookies and how to disable them please visit www.aboutcookies.org or www.allaboutcookies.org, or you may consult the vendor documentation for your specific software.
We do not track users across time or over multiple websites, we do not receive, or respond to, browser do-not-track signals or other similar mechanisms. However, as noted above, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.
Amending your internet browser’s Do Not Track signal: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers and is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services.
To learn more about setting up a Do Not Track signal, please visit https://allaboutdnt.com/.