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Protecting the privacy of our members is very important to us at Fieldpoint Private and each of our affiliates. As a provider of financial services, the collection and use of personal information is fundamental to day-to-day operations. We strongly believe in protecting the confidentially and security of the information by whatever means possible. This policy describes how we handle and protect the information we receive from and about our members.
Why We Collect Information: We collect and use nonpublic personal information only for business purposes in order to serve the needs of our members. These business purposes include activities such as evaluating a request for a loan, opening a private banking deposit account, authenticating and executing member-requested transactions, and servicing members’ investment management needs. We may also use member information to inform you of other products or services that may be of interest to members.
What Information We Collect: We collect nonpublic information about you from the following sources: Information we receive from you on applications or other forms, information about your transactions with us, or others and information we receive from consumer reporting agencies.
How We Protect Information: We treat all information in a highly confidential manner. Fieldpoint Private Colleagues are required to protect the confidentiality of all information. Our Professional staff may access information only when there is an appropriate reason to do so, such as to support member servicing. Our Internet Banking Product uses industry-approved security technology such as passwords, firewalls and encryption, to protect member information from tampering. We also maintain physical, electronic and procedural safeguards to protect information and these safeguards comply with or exceed applicable laws. Everyone servicing your relationship and accounts is required to comply with established policies of Fieldpoint Private. We do not disclose any nonpublic personal information about you to anyone, except as required by law.
Information We Share: We do not disclose any nonpublic information about our members or former members to anyone, except as permitted by law.
Correction of Information: If you notify us that any information is incorrect, we will review it promptly and make all appropriate corrections to our records.
Further Information: Federal law establishes privacy standards and requires Fieldpoint Private to provide our privacy notice to members each year. If you have any questions about our privacy practices you may write us at Fieldpoint Private, One Greenwich Plaza, Suite A, Second Floor, Greenwich, CT 06830.
Online Security Statement: Member Information security is a top priority at Fieldpoint Private. Fieldpoint Private has built a secure network architecture utilizing well-vetted technology. Our firm will continue to adopt new technologies to ensure confidentiality, flexibility, and a superior member experience.
We want your online banking experience and usage of the Fieldpoint Private website to be safe while easy to navigate. Secure systems are a combination of technology, policies and people. Our architecture utilizes a multi-layered approach to information security, providing safeguards and privacy throughout the process.
Fieldpoint Private built a site offering multifactor authentication, data integrity, complete transactional privacy, and above all, resistance to all forms of hacking attempts. Layered security means that, rather than relying on a single security measure, Fieldpoint Private uses layers of technology within the security architecture to distance harmful intrusions as far as possible from the core of sensitive information and resources.
The first layer of security is our members. Please be aware of several straight forward security tips when using any internet site containing sensitive information:
• Please use a strong password. Choose passwords that are difficult for others to guess and use a different password for each of your online accounts. Use both letters and numbers and a combination of lower case and capital letters.
•Change your online banking passwords often. You can do this quickly and easily by signing on and going to the designated area.
• Make sure your home computer has the most current anti-virus software. Anti-virus software needs frequent updates to guard against new viruses. We recommend that you use a program that automatically updates your virus protection on a regular basis.
• Install a personal firewall to help prevent unauthorized access to your home computer. This is important if you are connected to the internet via a cable modem or a digital subscriber line (DSL) modem.
• When your computer is not in use, please shut it down or disconnect from the internet.
Act quickly if you detect fraud. If you believe someone is trying got commit fraud and/or you think you may have provided personal or account information in response to a fraudulent email or web site, report the incident immediately, change your passwords.
General Data Protection Regulation (GDPR)
Privacy Notice for EEA Residents
This Privacy Notice describes how Fieldpoint Private (the firm”) collects and secures the personal data of individuals domiciled in the European Economic Area (EEA). The information in this Notice is provided to the extent that the European Union’s General Data Protection Regulation (“GDPR”) applies to your business with Fieldpoint Private.
Please note that Fieldpoint Private’s data collection and retention procedures are subject to U.S. laws and banking and securities regulations. As a result, your rights under the GDPR may be limited by those laws and regulations.
Basis for and Purpose of Data Processing
Fieldpoint Private collects and processes your personal data when such processing is required for the performance of our contract with you. The firm also processes your personal data to comply with applicable U.S. laws and regulations.
Personal Data Obtained from Outside Sources
Fieldpoint Private obtains personal information about you from other sources to enable us to confirm your identity and financial history. These sources may include paid third-party service providers and publicly accessible data.
Recipients of Personal Data
Fieldpoint Private shares your personal data with third-party service providers to help conduct business on your behalf. These arrangements are subject to due diligence and ongoing oversight to ensure that these service providers have adequate data protection procedures in place. Fieldpoint Private’s service providers may include:
Investment management firms;
Audit, accounting or recordkeeping services;
Clearing and custody firms;
Credit bureaus, background-check providers and legal data services;
Prospectus/corporate action mailing service;
Other vendors as necessary.
How Long Does Fieldpoint Private Retain Your Personal Data?
Fieldpoint Private processes and retains your personal data for at least the duration of our contract with you. Note that the firm will preserve some data longer to comply with U.S. law and the rules of the banking and securities regulatory authorities who oversee our activities.
Your GDPR Rights
Under GDPR, you have fundamental rights regarding your personal data, and you may exercise those rights — subject to other banking and securities laws or regulations that Fieldpoint Private must observe. These rights include:
Right to be informed. You have the right to be informed that a file of your personal information is being collected, retained and processed by Fieldpoint Private.
Access. You have the right to obtain free access to your personal data.
Rectification. You have the right to ask that incorrect or incomplete personal data be corrected.
Erasure. You have the right to request that personal data be erased, subject to applicable legal and regulatory
Restriction on processing. You have the right to request the restriction of the processing of your personal data in specific cases.
Objection to processing. You have the right to object to the processing of your personal data for marketing purposes or based on your own circumstances.
You have the right to receive your personal data in a machine-readable format and to transmit it to another controller.
Rights for California Residents
If you are a California resident, you may have certain rights under the California Consumer Privacy Act (Cal. Civ. Code §1798.100 et seq.) (“CCPA”) regarding your personal information. These include:
The right to know about the personal information a business collects about them and how it is used and shared;
The right to delete personal information collected from them (with some exceptions);
The right to opt-out of the sale of their personal information; and
The right to non-discrimination for exercising their CCPA rights.
To exercise your rights, you may call Fieldpoint Private at 1-800-288-5513, or e-mail us at:
Point of Collection Notice
Personal Information We Collect
Fieldpoint Private collects personal information from clients, employees, job applicants, directors and vendors, among others. This information includes, but is not limited to:
Personal identifiers. Examples include your full name, date of birth, marital status, spouse’s name, residential address, mailing address, e-mail address, telephone number, online identifiers, driver’s license, Social Security number, passport information or other government issued identification;
Financial data: Including your investment experience, as well as specific information about banking or investment products or services previously purchased such as mortgages or insurance;
Characteristics of protected classifications under federal or California law: Examples include age and gender;
Internet or other network activity information: Such as your IP address, information regarding your interaction with our websites and applications, biometric information (such as voice authentication and call recording);
Publicly available information from the internet including social media sites;
Professional or employment-related information;
Education and professional certifications;
Inferences that we draw from the information collect.
Sources for the Personal Information We Collect
We gather personal information from the following of sources, among others:
Directly from you or from those acting on your behalf. Examples include account forms, loan applications, job applications, vendor service agreements, or information requests that you complete online, by telephone, on paper or verbally.
Data that you choose to make public on the internet via social media sites.
Third-party vendors such as credit services or background-check services.
Publicly available data from law enforcement agencies, court records or other government entities.
Data automatically collected from internet or other network activity regarding your use of our websites and applications. We also may collect information from your interactions with third-party systems that we give you access to as a client, including banking, trading or custodial services.
Uses for the Personal Information We Collect
For clients, we use the personal information we collect primarily to conduct our investment management and banking activities on your behalf. We also may use your personal information to verify your identity, personalize the services and communications we provide and as an aid in developing new products and services. For employees, job applicants, vendors or firm directors, we use personal information to evaluate your background in connection with your current or potential responsibilities at the firm. In addition, we use personal information to administer such services as payroll, benefits or accounts payable.
The firm may provide your personal information to regulators and law enforcement agencies when required.
Third Parties We May Share Your Personal Information With
We may share your Personal Information with the following third parties, among others:
Vendors that facilitate our ability to provide you with our banking and wealth management services. These may include, but are not limited to, banking service vendors, payment facilitators such as ACH and Fedwire, clearing firms, custodians, mutual funds, insurance companies or private placement sponsors. Background-check services, payroll providers, benefit providers. Government, legal or regulatory entities, law enforcement agencies, other entities in connection with legal
Sale of Personal Information and Opting Out
Fieldpoint Private does not sell your Personal Information as outlined in the CCPA, so we do not provide an opt-out option.
Limits to Your Rights under CCPA
Note that the CCPA includes certain exemptions that may apply to our use or collection of your Personal Information and some of your information may be excluded from a request to receive or delete your Personal Information. Additionally, certain Personal information that we must collect or that we are required to retain to remain in compliance with other regulations than the CCPA is may be excluded from your rights under the CCPA.
Changes to this Policy
We may change or update this disclosure as regulations or our practices change and will post the revised disclosure here.