Personal Information We Collect
We may collect personal information directly from you, from third-party sources, and indirectly through your use of the websites, online, mobile, and other electronic services (collectively, “digital channels”).
We collect the following categories of personal information:
- Identifiers such as account and contact information, including your name, email address, government identifier, user ID, password, telephone number, mailing address, device identifiers, and IP address.
- Financial information that you provide to us at the time of account creation through our online or mobile account creation process.
- Transactional information, including records of products, services, and resources obtained or considered, feedback you may provide, and the contents of your communications with us.
- Demographic information such as your age and gender.
- Internet activity, including, but not limited to your , browsing history, search history, information about how you interact with or access the digital channels, information about your device and network connection, including make and model of the device, software and firmware versions, operating systems, browser type and version.
- Geolocation data about the approximate physical location of your device or network connection.
- Professional and employment-related information.
- Education information.
- Video and photos captured via devices in and around our offices.
- Inferences drawn from any of the above-listed categories of information.
We collect the information directly from you, from your legal representatives, from social media platforms, from government resources, from credit reference agencies, and from your financial advisors or other entities that you are associated with.
For What Purposes Do We Use Your Personal Information
We may use or disclose the information we collect to:
- Verify your identity and authenticate you during online sessions
- Provide and manage the digital channels
- Provide you with services and offers compatible with your device and relevant to your region
- Determine eligibility of your device
- Protect against fraud, security threats, and otherwise manage risks
- Communicate with you regarding products and services that may be of interest, including displaying targeted and relevant advertising, and offering you special promotions
- Evaluate and improve our websites, online apps, mobile apps, and other electronic offerings
- Tailor our services and otherwise enhance the online customer experience to better meet your needs through digital channels
- Perform analytics and measure the effectiveness of our digital channels, including obtaining insight into how to improve the design, content and navigation of our digital channels
- Satisfy legal or regulatory requirements
We may use information for any purpose if the information does not reasonably identify you. For example, we may prepare aggregated reports about how visitors tend to interact with the digital channels for research about the use of the digital channels and how they could be improved.
Use of Web Tools
- If you do not accept any category of cookies, you may continue to browse our website; however, please be aware that certain features of our website may not function properly without cookies. You should note that if you would like certain services, you will be required to accept cookies to maintain session integrity and enhanced security. Additional resources that may assist you in managing cookies used for advertising include the Digital Advertising Alliance (DAA): https://youradchoices.com/.
- If you refuse a cookie when using the digital channels, or if you delete cookies, you may experience some inconvenience in your use of the digital channels. For example, you may not be able to sign in and access your account, or we may not be able to recognize you, your device, or your online preferences.
- Tagging: Tagging software is customized code on our website that is designed to monitor user activity on our website to help us present users with content relevant to their use of our website.
- Web Beacons: Web beacons are small and transparent images embedded in web pages and e-mail communications that, when combined with cookies, help provide us with information about the use and effectiveness of a website or e-mail communication. As an example, we may include web beacons within e-mail communications to receive confirmation of receipt of an e-mail communication or clicks on links within our website.
How We Share Personal Information
We may share any of the personal information we collect with certain individuals and entities in connection with digital channels performed for, or in association with, us. These individuals and entities include:
- Third-party service providers for servicing purposes;
- Your financial advisor;
- Your legal, accounting and tax representatives;
- Your financial institutions, including custodians and broker-dealers; and
- Our affiliates.
We may disclose personal information with your consent or in response to demands, orders, or lawful requests from courts or other government authorities, including in connection with actions brought by third parties pursuant to subpoena or other legal process. We may also use or disclose personal information if we deem it reasonably necessary to protect the rights or property of CI, including the digital channels, customers, or others, for example in response to a denial of service attack or the introduction of malicious software to the digital channels.
In addition, we may share information about you to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our business, or a sale, liquidation, or transfer of some or all of our assets.
Your Privacy Rights
You may be entitled to request access to the personal information we collect, use, and disclose about you and to request deletion of your personal information. You may also contact us to update your personal information. If you would like to exercise any of these rights, you may do so by emailing [email protected]. Once we receive your request, we will ask for your name, email address, postal address, telephone number, and account number(s) (if available) to verify your identity. You may also submit a request via an authorized agent. If you do so, we may take steps to verify your identity and the authority of the authorized agent. Authorized agents should email requests to [email protected]. If you are a California resident, you have the right to not be discriminated against by virtue of exercising your rights to request access to or deletion of your personal information, though we may provide different levels of service as reasonably related to the value of your personal information.
Our Security Measures
We take our responsibility to safeguard customer information very seriously. To protect certain communications between your computer and our servers, we use a technology solution called “Secure Sockets Layer” (SSL). SSL ensures that the information transmitted is encrypted. In addition, we use the concept of “defense in depth,” in our cybersecurity program that has many layers, from employee awareness to having firewalls at the very edge of our network. However, no system can be completely secure, and we cannot and do not guarantee the security of the information you provide to us.
Your Security Measures
Do not respond to text messages, pop-ups, emails, or other internet requests that ask you to reveal personal information about yourself or your account when using the digital channels. We will never send you unsolicited messages or emails asking for your password, credit card, account numbers, etc. We will never ask you to validate or restore your account or access to the digital channels through unsolicited messages or emails.
This policy is effective from March 7, 2022.
How to Contact Us
If you have any questions or concerns about our privacy practices, the privacy of your personal information, or you want to change your privacy preferences, please email us at [email protected]. We are committed to helping resolve your questions or concerns.