This Privacy Notice explains how Freestone Capital Management, LLC and its affiliates (collectively, “Freestone,” “we,” “us” or “our”) treat personal information of individuals resident in the state of California. The information in this Notice is provided pursuant to the California Consumer Privacy Act (“CCPA”). This Privacy Notice provides the details California residents (“you” or “your”) need to understand your rights under the CCPA, and to exercise those rights. It provides you with the contact information you need to take action regarding the privacy of your data.
This Privacy Notice only applies to residents of the state of California, and does not apply to any other person.
The CCPA and Your Personal Data Rights
The CCPA is a state law that grants you increased control over your personal information.
The CCPA allows you to find out what personal information of yours has been gathered, to request that businesses delete your data, to opt-out of having their information sold, and more. It requires affected companies to create processes to comply with and facilitate consumer data requests, to update their privacy policies, and take steps to assure that certain of their vendors comply as well.
Defining Personally Identifiable Information
Various laws and regulations (including the CCPA) use different terms and definitions for information about individuals that is personal and should be protected. Some laws and regulations consider only very limited types of information to be protected and private. Others include much broader categories.
In this notice, “Personally Identifiable Information” (PII) refers to data that could be used, alone or in combination with other data, to identify you as an individual. It can include name, physical address, email address, IP address, date of birth, social security number, passwords, credit card or other financial or payment information, and more.
Types of Collected PII
The types of PII we collect and share depend on the services we provide to you. This information can include:
- Social Security number
- Income
- Assets
- Risk tolerance
- Wire transfer instructions
- Transaction history
Purpose for Collecting Your PII
We collect your PII for various purposes including:
- Creating and managing your account with us
- Contacting you or your designated representative by phone, email, fax, or mail
- Sharing information about our services including investment research
- Providing you or your representative with marketing communications
- Facilitating financial transactions related to your account
- Fulfilling our legal and regulatory obligations
Our Website and Your PII
Visiting and navigating our website will likely involve using and access to your PII in one form or another. This section details the methods and permissions involved.
Consent to Use Your PII
By visiting our website or completing any of our online forms, you consent to us using your PII to reply to your request as well as to contact you in the future, whether or not at your request, to provide you with additional information, seek additional information from you or to market to you.
Note that we might also be required to comply with applicable privacy laws and regulations to record and maintain certain PII from you (e.g., monitoring email and other network traffic).
Without some of this information we cannot provide you with the services you may request. If you are currently receiving information or marketing communications from us, however, you may opt-out of receiving further communications at any time.
Use of Cookies
Some of the PII we collect is obtained through the use of third-party automated collection tools on our website, such as cookies that capture information sent from your web browser to our website. Information that is collected includes your IP address, the website address that you were at before landing at our website, and information such as the pages you clicked through while at our website. This information is collected to improve your experience.
When you first visit our website, you are asked if you agree to our use of cookies. You may agree and opt-in, or refuse and opt-out. If you opt-out, please note that your experience using our website may not be optimal.
Sharing your PII
Your PII may be combined with information we receive from other sources, or it may be provided to service providers that we work with.
Receiving PII from Third Parties
We may receive information about you from other sources and combine that information with the PII we collect directly from you. For example, we may receive your PII from accountant(s), lawyer(s), and other service providers that you are working with.
Sharing PII with Third Parties
We will not sell your PII. We may share your PII with our affiliates, business partners, and other third parties. We may do so for the purposes of operating our business, delivering and improving the financial services we provide to you, as well as for other legitimate purposes permitted by applicable law such as sending marketing and other communications related to our business.
We also share PII for a variety of additional purposes including, but not limited to:
- Within Freestone and our affiliates for data processing or storage purposes;
- For our affiliates’ everyday purposes in maintaining accounts; and
- In response to a request from law enforcement, judicial or government authorities, or other third parties as necessary to comply with legal process or to meet national security requirements.
Your PII Rights
The CCPA provides you with certain rights regarding what we do with your PII. This section details those rights, how to exercise them, and what we will do in response.
Please note that the rights under the CCPA do not apply to PII collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act (Public Law 106-102) or the Fair Credit Reporting Act (12 CFR 1022).
If you are an individual who resides in California and whose personal data is collected and processed by us, you may have the right to:
- Request that we disclose, free of charge, the categories and specifics of the PII we collect about you, the sources from which the PII was collected (and/or, if applicable, sell or otherwise disclose to a third party), and the business purpose for collecting PII.
- Choose to opt-out of the sale of your personal information. Currently, however, we do not sell personal information.
- Request that we delete the PII we have collected. Following our verification of the request, we will comply with the request and delete your PII from our records and direct any of our service providers to delete your PII from their records, in each case unless otherwise restricted by law or regulation.
Non-Discrimination for Exercising Your PII Rights
We follow the requirements of California Civil Code §1798.125 and will not discriminate against any consumer who exercises the rights set forth in this Privacy Notice.
Contacting Us to Exercise Your PII Rights
You may contact us in order to exercise any of your rights set forth in this Privacy Notice by calling this toll-free number (800) 990-3001, or emailing compliance@freestonecapital.comcompliance@freestonecapital.com or by submitting a data request form. Please include a description of what right you want to exercise and the information to which your request relates. Please note that you may only make a disclosure request twice within a 12-month period.
Verifying Your Identity
If you choose to contact us with a request, you will need to provide us with identifying information that matches the PII we currently have about you. For example, we may require identifying documents or information such as your name, address, social security number or date of birth, among other things.
Authorized Agent
You have the right to appoint an authorized agent to exercise your rights on your behalf. If you would like to do so, please send your request to compliance@freestonecapital.com m
Accessibility Information
For consumers with disabilities who need to access this policy in an alternative format, please contact compliance@freestonecapital.com
This Privacy Notice was last revised and posted June 3, 2020.