Last updated: December 2022
When we use the term “personal information” in this Notice, we are referring to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, such as your real name, alias, postal address, unique personal identifier, online identifier Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Personal information does not include publicly available information and other information that is regulated by certain applicable laws that are exempted from the requirements of the CCPA.
This Notice and the CCPA do not apply to personal information we collect as part of our current or former client relationship with you pursuant to other privacy laws, such as the Gramm-Leach-Bliley Act, Regulation S-P, and Fair Credit Reporting Act. Therefore, depending on your relationship with us, the CCPA, and this section, may not apply to your personal information, even if you are a California resident. For information about how we use and disclose your financial information subject to those laws, and your rights with respect to your financial information subject to those laws, please see our Privacy Notice & Practices.
If you are a job applicant or employee, please see our job applicant or employee Privacy Notice regarding the collection of personal information that was provided to you.
1. Your Rights and Choices Under the CCPA
Right to Know
You have the right to request that we provide certain information to you about our collection of your personal information. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:
The categories of personal information we have collected about you
The categories of sources from which we have collected your personal information
Our business or commercial purpose(s) for collecting or selling your personal information
The categories of third parties with whom we have shared your personal information
The specific pieces of personal information we have collected about you
You have the right to request that we provide certain information to you about our disclosures and sales of your personal information. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:
The categories of personal information we have collected from you
The categories of personal information we have sold about you and the categories of third parties to whom we sold such information, by category or categories of personal information for each category of third parties to whom the personal information was sold
The categories of personal information that we disclosed about you for a business purpose
We have not, and do not, sell personal information. You may only make a verifiable “Right to Know” request twice within a 12-month period.
Right to Delete
You have the right at any time to request that we delete your personal information; however, in some cases we cannot delete all or some of your personal information as required or permitted by applicable laws.
Right to Correct
You have the right to request that we correct inaccurate personal information we maintain about you. In some cases, however, we may deny requests to correct inaccurate personal information. Alternatively, we may delete such personal information.
Right to Nondiscrimination
We will not discriminate against you for exercising your rights under the CCPA, such as by denying you products and services, charging you different rates or prices (including use of discounts or penalties), or suggesting or providing a different level of service or quality of products to you. We may, however, charge a different price or provide a different level or quality of products and services if the price or difference is directly related to the value provided to you by your personal information.
We may, from time to time, offer you financial incentives, including payments to you as compensation, for collecting or deleting your personal information. We also may offer a different price, rate, level, or quality of goods or services if that price or difference is directly related to the value provided to you by your personal information.
2. Information We Collect and How Long We Retain It
As required under any applicable legal, regulatory, accounting, or reporting requirements;
Based on the agreement you have with us; or
To resolve disputes or enforce our agreements.
Please note: As a broker-dealer and investment adviser subject to securities and insurance laws and regulations, we are required to maintain records for various time periods pursuant to such laws and regulations, and such records include personal information regarding individuals.
|Category of Information
|Name, address, Internet Protocol (IP) address, email address, job title, device identifiers, account name, or other similar identifiers
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
|Name, postal address, or phone number (Some personal information included in this category may overlap with other categories.)
|Characteristics of protected classifications under California law
|Gender and age
|Internet or other similar network activity
|Browsing history, search history, information on a consumer’s interaction with a website, application, communication (such as email), or advertisement
|General investing background, investment interests and experience, information about current firm, and approximate assets under management
|Professional or employment-related information
|Information about current and past employment
|Sensitive personal information
|Social security number, driver’s license number, financial account numbers, and biometric information (e.g., fingerprints)
|Inferences drawn from other personal information
|Inference drawn from the information above and profiles reflecting preferences and characteristics
3. Our Sources for Personal Information
We collect personal information from you when you provide it to us, when you use our Services, and when you interact with us. If you use third-party account aggregation services through our Services, such as Plaid, we may have access to information provided by such third party. We also automatically collect some information when you visit our site and may collect information from public record sources, such as federal, state, or local governments.
4. Our Business Purposes for Collecting Personal Information
In general, we collect information and personal information so we can provide our Services, operate our business, and provide information that consumers request from us. This includes, but is not limited to, the following:
Provide information, products, or services you request
Verify your identity when accessing our Services
Compare information for accuracy and verify our records
Detect and prevent fraud, security or technical issues, or criminal activities
Operate, improve, maintain, and protect our Services
Provide technical and other support
Send updates, marketing communications, and other information about Commonwealth, our Representatives, and Services
Send you notices and alerts
Facilitate your subscription to our blog
Conduct research, analytics, and monitor and analyze trends and usage
Contact you and respond to your inquiries
Send you email newsletters
Register you for an account in our online services
Enhance or improve user experience, our business, and our Services, including the safety and security thereof
Personalize our Services to you
As necessary to comply with any applicable law, regulation, subpoena, legal process, or governmental request
Enforce contracts, our Terms of Service, and User Agreement(s), including investigation of potential violations thereof
Protect against harm to the rights, property, or safety of Commonwealth, our users, or the public as required or permitted by law
We do not engage in automated decision-making using your personal information.
5. Sharing Personal Information
Our service providers and subcontractors
Our affiliates and subsidiaries
Third parties to whom you authorize us to disclose your personal information
To comply with a legal requirement, judicial proceeding, court order, or legal process
To investigate a possible crime, such as fraud or identity theft
In connection with the sale, purchase, merger, reorganization, liquidation, or dissolution of Commonwealth, or steps taken in anticipation of such events (e.g., due diligence in a transaction)
When we believe it is necessary to protect the rights, property, or safety of Commonwealth or other persons
As otherwise required or permitted by law, including any contractual obligations of Commonwealth
6. Making Requests
To submit a request to exercise your Right to Know, Right to Delete, or Right to Correct rights provided in this Notice, please email firstname.lastname@example.org or call us at 866.212.6513. Please be prepared to provide your first and last name, your email address, your phone number, your relationship to Commonwealth, and the type of request. We will evaluate the request and take action where required to do so.
Depending on the nature of your request, we may have to verify your identity when you contact us. We may do this by asking you to:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized agent
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you.
We endeavor to respond to your request as soon as we can. If we are not able to respond to your request within 45 days, we will let you know that we may require additional time (up to 90 total days).
You may also use an authorized agent to exercise your rights on your behalf. If you wish to use an authorized agent, we require that your authorized agent provide written proof to us that they are authorized to act on your behalf, and we may also require your authorized agent to verify their identity.
7. Changes to This Notice
We may change or update this Notice from time to time. When we do, we will post the revised Notice on this page with a new Last Updated date.