- use our financial advisory services or are eligible to access them as an employee benefit (“Client Services”);
- visit our physical locations;
- interact with us in a business-to-business capacity;
For personal information that we handle pursuant to the federal Gramm-Leach-Bliley Act, please see the GLBA Financial Notice.
California residents: we provide important information about our collection, use, and disclosure of your personal information and privacy rights in our California privacy notice.
TABLE OF CONTENTS
- Personal information we collect
- How we use your personal information
- How we share your personal information
- Your choices
- Other sites and services
- International data transfer
- How to contact us
- California privacy notice
PERSONAL INFORMATION WE COLLECT
Information you provide to us. Personal information you may provide to us through the Service or otherwise, or that we obtain from your employer, includes:
- Contact data, such as your first and last name, email and mailing addresses, residence, postal code, phone number, professional title and company name.
- Profile data, such as your username and password that you set to establish an online account with us, age or date of birth, gender, biographic details, interests, education-related information and preferences, intended time of retirement, and information that may be related to a service, account or an event you register for.
- Identity data, such as a national identification number (e.g., Social Security number where permitted, tax identification number, passport number), state or local identification number (e.g., driver’s license or state ID number), and an image of the relevant identification card.
- Communications that we exchange when you contact us with questions, feedback, or otherwise using any channel, including social media.
- Financial data, such as your income, economic or financial status, financial institution, financial account details, investment holdings and preferences, investment changes, account balances and contributions, assets and ability to invest.
- Payment and transactional data, such as the information needed to complete your orders on or through the Service (including name, contact information, credit card information, and billing information), and information about payments to and from you and other details of products or services you have purchased from us, and information that you provide us in subscription agreements, investor questionnaires or other documents prepared in connection with the Client Service.
- Marketing data, such as your preferences for receiving communications about our products, activities, events and publications, and details about how you engage with our communications.
- Research data that we collect if you participate in our research activities such as interviews and focus groups, which may include demographic information, your responses and feedback to our questions, and audio and video recordings of your interactions with us.
- Familial data, such as marital status and information about your family members that you may provide to us (e.g., name, gender, age and date of birth).
Data from other sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
- Data providers, such as information services (e.g., data appending services) and data licensors who may provide us with additional information about you such as contact information, demographic information, and interests and preferences.
- Public sources, such as social media platforms and public records.
- Business partners, such as joint marketing partners and event co-sponsors.
- Our clients, such as your employer when it engages us to provide Client Services as a benefit to its employees, who may provide us with contact information as well as demographic and employment-related information.
Data collected automatically. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your activity over time on the Sites and other online services, such as:
- Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, the website you visited before browsing to our website, and general location information such as city, state or geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access.
Cookies and similar technologies. Like many online services, we use the following technologies:
- Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
- Flash cookies, or locally stored objects, which are used on websites for purposes similar to cookies but allow storage of a larger amount of data.
- Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
Information about others. Users of the Service may have the opportunity to refer friends or other contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.
HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information for the following purposes:
Service delivery. We use your personal information to:
- provide, operate and improve the Service;
- execute your transactions;
- establish and maintain your user profile on the Service;
- enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
- communicate with you or your employer about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
- understand your needs and interests, and personalize your experience with the Service and our communications;
- provide support for the Service; and
- respond to your requests, questions and feedback.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Marketing and advertising. We and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
- Direct marketing. We may send you IRP or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
Compliance and operations. We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements and internal policies;
- enforce the terms and conditions that govern the Service; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
Cookies and similar technologies. The Service employs Cookies and similar technologies to facilitate the purposes for which we use personal information:
- Service delivery and operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password-protected areas of the Service, and to enhance the performance and functionality of our services.
- Interest-based advertising. To facilitate interest-based advertising as described above.
- Research and development. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails and advertisements. For example, we use Google Analytics cookies for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.
HOW WE SHARE YOUR PERSONAL INFORMATION
Affiliates. We may share personal information about you with our affiliated companies for everyday business purposes, however, our affiliated companies are not permitted to use this information to market their products or services to you. Additionally, we do not share information with our affiliated companies regarding your creditworthiness.
Please see our Privacy Notice for more information on how your information may be shared.
Service providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business (such as IT, hosting, investment trading, customer relationship management and support, print and mail fulfillment, data management, event registration, email delivery, marketing, website analytics, and event management services).
Service-related third parties. Brokers, custodians, administrators, investment funds and their respective managers and other non-affiliated third parties as necessary to provide the Service.
Advertising partners. Third party advertising companies that collect information about your activity on the Site and other online services to help us advertise our services, and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms.
Professional advisors. Professional advisors, such as lawyers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and operations purposes described above.
Business transferees. Relevant participants in business transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, IRP or our affiliates (including, in connection with a bankruptcy or similar proceedings).
You have the following choices with respect to your personal information.
Access or update your information. If you have registered for an account with us, you may review and update certain account information by logging into the account.
Opt-out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. You may continue to receive service-related and other non-marketing emails.
If you receive text messages from us, you may opt out of receiving further text messages from us by replying STOP to our message.
Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. We use Google Analytics to help us understand user activity on the Service. You can learn more about Google Analytics cookies at https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage and about how Google protects your data at http://www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our sites by downloading and installing a browser plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.
Advertising choices. You can limit use of your information for interest-based advertising by:
- Browser settings. Blocking third party cookies in your browser settings.
- Privacy browsers/plug-ins. By using privacy browsers such as Brave or ad-blocking browser plug-ins such as Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third-party cookies/trackers.
- Platform settings. Google and Facebook offer opt-out features that let you opt out of use of your information for interest-based advertising:
- Ad industry tools. Opting out of interest-based ads from companies participating in the following industry opt-out programs:
- Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
- Digital Advertising Alliance: optout.aboutads.info
- AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
- Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
You will need to apply these opt-out settings on each device from which you wish to opt out.
Do Not Track. Some internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information requested, we may not be able to provide those services.
OTHER SITES AND SERVICES
The Service may contain links to websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on webpages or in mobile applications or other online services that are not associated with us. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions.
We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
INTERNATIONAL DATA TRANSFER
We are headquartered in the United States and may use service providers with operations in other countries, where privacy laws may be of a standard more or less protective as those in your state or the United States generally. Our service providers may have access to the personal information we collect about you during the course of our contractual relationship with them in order to provide their services or products. It is our practice, however, to enter into written agreements with our service providers that impose data protection obligations no less protective than our own.
The Service is not intended for use by children under 16 years of age. If we learn that we have collected personal information from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it.
HOW TO CONTACT US
You can reach us in the following ways:
- Mail: Investment Research Partners, LLC, P.O. Box 834, Lemont, PA 16851, Attention: Privacy
- Phone: (814) 996-7206