PRIVACY POLICIES

 

Understand how we use and protect customer information.
 

PRIVACY POLICY FOR INDIVIDUALS
This policy is effective as of May 05, 2015 This Privacy Policy is provided to you on behalf of Factorial Financial, LLC. d/b/a Factorial Financial. This policy applies to consumers who have, or have had, a customer relationship with Factorial Financial. For purposes of this Privacy Policy, “Personal Information” is data specifically about you, which you typically provide on a voluntary basis. Personal Information does not include aggregate or combined information, which is data related to you but does not identify you specifically. Please read the following information carefully to understand Factorial Financial’s policies about protection and use of Personal Information.

 

The types of Personal Information we collect and share depend on the product or service you have with us. Information Collection We collect and maintain certain information from you, including Personal Information, in connection with opening and servicing your account. In the course of serving you, we collect certain Personal Information about you from a variety of sources, such as: • Information you provide to us on applications or forms, including our websites, such as your name, address, Social Security number, birth date, assets, and income; • Information we receive from an outside company, such as a credit bureau, regarding your creditworthiness and credit history if you apply for credit products; or • Information about your transactions or experiences with Factorial Financial, including interactions with our customer service staff.

 

Information Use and Disclosure Factorial Financial: The Personal Information we collect is used to service your accounts and help you meet your financial goals. Personal Information may be used or shared within Factorial Financial for a number of purposes, such as: • For our everyday business purposes, such as to process your transactions and maintain your account(s); • To protect your account(s) from unauthorized access or identity theft; • To process your requests, such as tax planning and preparation, accounting services, trading securities or insurance purchases; • To service your account(s) by issuing checks, account statements, performance reports and other account servicing functions; • To provide you with customer service by responding to questions and requests you may have regarding your account(s) or the services provided through Factorial Financial, notifying you of updates or contacting you otherwise when necessary; • To provide you information about financial services and products that can help you meet your needs now and in the future, and to determine your eligibility to receive such products and services offered through Factorial Financial; and • To improve the products and services offered through Factorial Financial, including internal market research or studies or to ask you to participate in surveys.

 

With affiliated Parties, HDVest: We share Personal Information with affiliated third party such us HDVest providing services for us when they are acting on our behalf. We may disclose all of the Personal Information we collect, as described above, with non-affiliated third parties that are acting on our or your behalf or are providing services for us, including: • Companies that perform services for us, such as HDVest clearing firm (First Clearing, LLC), data processors, technical systems consultants and programmers, check printers, data aggregators, marketers, and mail fulfillment; • Wells Fargo & Company and its affiliated companies (“Wells Fargo”) for the purpose of servicing your account through these systems or providing you information about your accounts (e.g., consolidated statements); • Others as permitted or required by law such as government entities, in responding to regulatory inquiries, subpoenas and other legal processes or requests for information by authorities, and those with whom you have requested or authorized us to share information; • Others in connection with an acquisition, merger, restructuring, sale or other transfer involving all or any portion of Factorial Financial; and • Others to protect your safety and the safety of others, to assist us in fraud prevention or investigation, or if we determine a website or policy violation has occurred, or to enforce Factorial Financial’s rights and property. It is important to note that when we do share Personal Information with outside companies that are performing services on our behalf, we do so only after that company has contractually agreed to maintain the confidentiality of the Personal Information, and to limit its use to the agreed-upon purpose.

 

We do not share Personal Information with non-affiliated parties for the purpose of those companies marketing their own products and services to you. Your Factorial Financial Advisor will obtain confidential information about you during the course of servicing your Factorial Financial accounts, and will retain that confidential information after leaving Factorial Financial. That information remains subject to contractual and regulatory restrictions that prohibit the use or disclosure of the information (except as permitted or required by law) without your explicit consent.

INFORMATION PROTECTION
We are committed to protecting customer information. The security and integrity of customer information is protected through procedures and technology designed for this purpose. For example: •We limit employee access to customer information to those who need to know this information in order to service customer relationships; •We have adopted an employee code of conduct, which includes standards to protect customer confidentiality; •We require independent contractors and outside companies who work with us to adhere to privacy standards through their contracts with us; •We maintain policies and procedures covering the proper physical security of workplaces and records;•We protect against unauthorized access or alterations to customer data through standard technological means (such as backup files, virus detection, firewalls, and other computer software and hardware); and •We comply with federal standards for physical, electronic and procedural protection of customer information.

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The policies and practices described in this disclosure are subject to change, but we will communicate any significant changes to you as required by applicable law. These disclosures replace all previous notices or statements regarding this matter. Factorial Financial is Committed to Your Privacy Respect for our customers’ privacy has long been valued at Factorial Financial. Not only is it what our customers expect, it’s the right way to do business. The trust of our customers is our most valuable asset and the reason we are in business. This trust is built, in part, upon our handling of your Personal Information. In an age of electronic commerce and communication, the need for a strong commitment to the protection of consumer information is critical. Although technology has changed the way information is gathered, used and stored, the importance of preserving the confidentiality of information remains a core value to Factorial Financial. Factorial Financial considers privacy and security to be essential for all our customers, including users of our online services. For a detailed discussion of the privacy practices applicable to users of the Factorial Financial website, users are encouraged to review the privacy policy governing the online collection of information at the link for Online Privacy Policy on www.factorialfinancial.com.

 

Tips to Help Protect Your Account Information Assistance to Victims of Identity Theft If you suspect that someone has had unauthorized access to your account with us, please notify us immediately so we can take action to protect you. Call Factorial Financial Management at (301) 503-5623. In addition, if you suspect that someone has had unauthorized access to your accounts, or access to your personal identifying information such as your Social Security number or credit card information, you should report the crime to your local law enforcement agency and to the Federal Trade Commission (FTC). To speak with a trained FTC telephone counselor, call toll-free at (877) IDTHEFT or (877) 438-4338. Or, visit www.ftc.gov/idtheft for additional consumer education materials.
 

ONLINE AND MOBILE PRIVACY POLICY

Factorial Financial Online & Mobile Privacy Policy: This Privacy Policy is effective as of May 05, 2015. Scope and Overview of Policy This Online and Mobile Privacy Policy (“Policy”) applies to your interaction with Factorial Financial, LLC. d/b/a Factorial Financial, at any online or mobile site or application that we own and control (“Site”), unless a different online and/or mobile policy is posted at a particular site, or is made available to you and by its terms supplants this Policy.

 

Other privacy policies may also apply in addition to the terms of this Policy. As examples, certain additional Factorial Financial privacy related policies and notices are posted on the “Privacy” section of www.factorialfinancial.com. These include the Factorial Financial Privacy Policy for Individuals. Please note that where we have another type of presence on a site owned by a third party, such as a page or handle on a social media site, that third party’s privacy policy and terms of use, rather than this Policy, will govern, unless specifically stated otherwise.

 

For purposes of this Privacy Policy, “Personal Information” is data specifically about you, which you typically provide on a voluntary basis. Personal Information does not include aggregate or combined information, which is data related to you but does not identify you specifically. By using the Sites or related services, you consent to Factorial Financial’s collection, use and sharing of the data as described in this Privacy Policy. Visitors Factorial Financial provides information about Factorial Financial through the Sites. If the information you are interested in is not available on the Sites, you may request further information by completing one of the available on-line request pages (such as “Contact Factorial Financial”,). The information you provide through the form will solely be used to contact you regarding your request for information.

 

Users when you register for an online service on the Sites, the Sites may request information, such as your name, address, birth date, e-mail address or your account number. This information allows you to perform certain tasks (for example, correspond with us or review your accounts) and it allows us to provide the information you requested. Automated Data In addition to the information you provide, Factorial Financial may also automatically collect information about your computer or your activity. For example, we may record how many times you click on a hyperlink, determine whether you visited the Sites from a particular Internet link or advertisement, or track your path through the Sites. This automatic data (“Automatic Data”) collection may include but may not be limited to information collected by cookies, IP addresses, log data, browser data, and transparent GIFs. None of the Automatic Data is deemed to be Personal Information.

 

Factorial Financial may aggregate the Automatic Data it collects from its various users (which does not include your Personal Information) and share it with or sell it to Factorial Financial’s affiliates, business partners, and other third parties. The Automatic Data may be used by Factorial Financial or the third parties for research purposes (including to help Factorial Financial improve its products), among other uses. Protecting Children's Privacy Online we do not seek to nor knowingly collect or use Personal Information from children under 13 on the Site. No part of the Site is structured to attract anyone under 13. If a child has provided us with Personal Information, a parent or guardian of that child may contact us to have the information deleted from our records. To do so, contact Factorial Financial through the information provided in the “Contact Us” section below. For more information about the Children's Online Privacy Protection Act (COPPA), visit the FTC website: www.ftc.gov. Links to non-Factorial Financial websites The Sites may contain links to websites controlled or offered by third parties (i.e., non-affiliates of Factorial Financial).

 

Factorial Financial hereby disclaims liability for any other company's website content, products, privacy policies, or security. In the event you choose to use the services available at a linked website, you agree to read and adhere to the policies and terms of use applicable to that website. In addition, any advice, opinions, or recommendations provided by the linked website are those of the website’s providers and not of Factorial Financial. Your participation in any linked website, including payment for and the delivery of goods or services, is based solely on the agreement, if any, between you the linked website’s provider. The fact that Factorial Financial has provided a link to such websites is not to be interpreted as an endorsement of their content. If it is necessary to make changes to our online privacy policies, we will update this Privacy Policy with the changes and new effective date.

 

Factorial Financial may, but is under no obligation to, provide you notice of such modifications to this Privacy Policy via email or other communication. Your continued use of the Sites following the posting of changes to this Privacy Policy means that you accept the changes and our use of your Personal Information in accordance with the revised policy. Opting Out You cannot opt out of receiving required administrative or legal communications. We do not share your Personal Information with affiliated or unaffiliated third parties for their marketing purposes.

 

California Residents: Your California Privacy Rights If you are a California resident, you may have the right to request and receive certain information about our disclosure of your Personal Information to third parties for their direct marketing purposes, and your choices with respect to such disclosures. Because it is our policy not to share your Personal Information with third parties unless you are first given the opportunity to opt-out from such sharing, we are exempt from having to meet this requirement.

 

If you still wish to learn more about our compliance with this requirement, please contact us using the information provided in the “Contact Us” section below. Contact Us For questions regarding this Privacy Policy, please contact Factorial Financial at: By Postal Mail: 19929 Wheelwright Drive, Montgomery Village, MD 20886. By Phone: Call Factorial Financial at (301) 503-5623, and ask. By E-mail: contact@factorialfinancial.com.