Your privacy is important to us. In the course of serving you, whether as an individual client or a participant in a program offered through a Corporate Partner, The Ayco Company, L.P. (“Ayco”) and Mercer Allied Company, L.P. (“Mercer”) may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you and we recognize that you expect us to treat your information appropriately.
We collect Personal Information when you voluntarily provide it to us, either directly or through a third party acting upon your instruction. Examples of circumstances in which you may provide us with your Personal Information include when you (i) receive Services; (ii) apply for a life insurance product; (iii) seek to open an Account; (iv) answer questions to determine what Services we might offer you; (v) complete a survey or otherwise provide feedback regarding the Services; or (vi) contact us with questions.
The Personal Information we may collect from you includes, but is not limited to, the following:
We may combine the Personal Information we collect from you with information we receive about you from other sources, such as your employer, address verification services and third-party providers of demographic and fraud prevention information. When you interact with the Site on a social media platform, we may collect the Personal Information that you make available to us relating to that platform, including your account ID or username and other information included in your posts.
We may use your Personal Information as follows:
We may share your Personal Information with:
In the event that you access the Services as brought to you by a third party through a co-branded URL, your e-mail address used to access the Services may be provided to that third party.
We do not share your Personal Information with non-affiliates so they can market to you.
We may also use and disclose your Personal Information as we believe to be necessary or appropriate:
(a) to comply with applicable law, to respond to requests from public and government authorities, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions and contractual rights; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others.
In addition, we may transfer Personal Information to a third party in the event of a merger, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other sale or transfer of any or all of our business, assets, or stock, and during negotiations for the same.
We may aggregate your Personal Information in a manner that no longer reveals your specific identity. We may use and disclose aggregated information for any purpose.
If the Personal Information on file for you changes, or if you no longer desire our Services, you may correct, update, or amend your Personal Information on the Site, by e-mailing Customer Support at email@example.com, or with the assistance of your financial advisor team. Please note that we may need to retain certain information for recordkeeping purposes and/or complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.
If you decide at any time that you no longer wish to receive marketing e-mails from us, please follow the “unsubscribe” instructions provided in such e-mails. Please note that you cannot opt out of administrative e-mails, such as regulatory, billing, or service notifications.
You may stop the receipt of push notifications on your mobile device through your device settings.
When you use our Site, we automatically record information such as browsing activity and data displayed or clicked on (such as user interface elements, ads, and links) and collect other information such as the type of device you use, browser type, operating system version, IP address, and date and time of access.
We use certain technologies, such as cookies, web beacons, and similar technologies, to collect information automatically from you when you use our Site. We may use these technologies to, for example, record your preferences, track your use our Site across multiple devices, measure exposure to our online advertisements, monitor traffic, analyze use of our Site, for security purposes, to display information more effectively, to personalize your experience, and to improve the Site.
You have choices to limit some tracking mechanisms. Many web browsers automatically accept cookies, but you may be able to modify your browser’s settings to decline cookies. If you choose to decline cookies, certain features may not function properly or may not remain accessible to you. In addition, you may also render some web beacons unusable by rejecting or removing their associated cookies.
We may also use information collected automatically from a particular browser, device, or application to recognize you on another browser, device, or application linked to you, for fraud prevention and other purposes.
Log File Information
Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version. We use this information to ensure that the Site functions properly.
Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses our Site, along with the time of the visit and the pages visited. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering our Site. We may also derive your approximate location from your IP address.
Cookies are small text files that may be placed on your device when you visit our Site or when you view advertisements that we have placed on other websites. Cookies allow your browser to remember some specific information which the web server can later retrieve and use. When you quit your browser, some cookies are stored in your computer’s memory, while some expire or disappear.
Tags, Pixels, Web Beacons, Clear GIFs
A web beacon, also known as an Internet tag, pixel tag, or clear GIF, is typically a one-pixel, transparent image located on a webpage or in an e-mail. These may be used when you are served with advertisements, when you interact with advertisements outside of our online services, or when you interact with our communications. They are generally used to transmit information back to a web server, and they help us measure the success of our marketing campaigns and compile statistics about usage of our Site.
If you choose to opt-out, a cookie will be placed on your browser or device indicating your decision. This cookie is specific to a particular device and browser, so if you use different browsers or devices, you will need to opt-out on each. In addition, because the opt-out is facilitated via cookies, if you clear your cookies you will need to opt-out again.
We use the Google Maps API to help pre-fill in address information. To learn about Google’s privacy practices, click http://www.google.com/policies/privacy.
We do not respond to browser do-not-track signals at this time.
We take the security of your Personal Information seriously. We seek to limit access to your Personal Information to authorized employees, agents, contractors, or vendors. We also maintain physical, electronic, and procedural safeguards designed to protect the information against loss, misuse, damage, or modification, and unauthorized access or disclosure while in our possession. No data transmission or storage system can, however, be guaranteed to be fully secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.
Social Media and Links to Other Web Sites and Apps
Our Services are not directed to and may not be used by anyone under the age of 21 and, as such, we do not knowingly collect Personal Information from anyone under the age of 21. If you are under the age of 21, please do not submit any Personal Information to Ayco or Mercer or use our Site. If a parent or guardian becomes aware that his or her child under the age of 21 has provided us with Personal Information, he or she should contact us at firstname.lastname@example.org, and we will, subject to our recordkeeping obligations under the Investment Advisers Act of 1940 and other applicable law, delete such information from our files.
Our Services and Site are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States. You must be an individual of at least twenty-one (21) years of age and reside in the United States, on a United States military base, or in a United States Territory in order to use our Services and Site. If you use our Services or Site outside of the United States, you understand and consent to the transfer of your Personal Information to, and the collection, processing, and storage of your personal information in, the United States and elsewhere. The laws in the United States and these countries regarding Personal Information may be different from the laws of your country.
For CA clients: In accordance with California law, we will not share information we collect about California residents with non-affiliates unless the law allows. For example, we may share information with your consent or to service your accounts. We will limit sharing among our companies to the extent required by California law.
For NV clients: We are providing you with this notice pursuant to state law. If you prefer not to receive marketing calls from us, you may be placed on our internal Do Not Call List by calling 1-866-325-2215. You may also contact the Nevada Attorney General’s Office: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington Street, Suite 3900, Las Vegas, NV 89101; telephone number: 1-702-486-3132; e-mail: BCPINFO@ag.state.nv.us.
For VT clients: We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law.