Last updated July 12, 2019
The Information We Collect and/or Receive
In the course of operating the Site, we will collect (and/or receive) the following types of information. You authorize us to collect and/or receive such information.
1. Contact Information: This may to used to contact you using the information you have entered provided that you have requested information about our firm and our services.
2. Other Information: In addition to the Contact Information, we may collect additional information (the “Other Information”). Such Other Information may include:
- From Your Activity - When visiting the Site, your browser makes an HTTP request to our web server. This HTTP request contains certain information logged by our web server including, without limitation, IP address, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Site visitors visit, and similar information concerning your use of the Site.
How We Use and Share the Information
You authorize us to use your Contact Information to provide information about our investment research and, subject to applicable law, potentially inform you about our company’s products and services.
You also authorize us to use and/or share your Contact Information and other Information (collectively, “Information”) with any of our affiliates, subsidiaries, or other companies under common control with us and as described below:
- Business Transfers - As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, your Information may be part of the transferred assets.
- Legal Requirements - To the extent permitted by law, we may also disclose your Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of PathWise or others.
Accessing and Modifying Information and Communication Preferences
If you have provided us any personal information, you may access, remove, review, and/or make changes to the same by contacting us at Ryan Wells ryan@pathwise or 925-939-5607. You may manage your receipt of marketing and non-transactional communications by clicking on the “Unsubscribe” link located on the bottom of any relevant marketing e-mail. We will use commercially reasonable efforts to process such requests promptly. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.
How We Protect the Information
We take commercially reasonable steps to protect your Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should, therefore, take special care in deciding what information you send to us via e-mail.
Important Notice to Non-U.S. Residents
The Site and its servers are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.
How to Contact Us
Legal Basis and Purpose: PathWise acts as “data controller” of the Contact Information and Other Information collected on the Site for the purposes and under the legal bases described below:
- Contact Information: We provide our investment research and investment management pursuant to client agreements and our legitimate interest in providing investment research and account information materials to interested EEA Individuals. Note that EEA Individuals must affirmatively sign up to receive such materials. Such information will be retained to provide the subscription or to effectuate any “opt-outs” unless deletion of such information is requested. In some cases, the information may not be able to be deleted.
- Other Information: We collect Other Information so that individuals can connect and use the Site, and to maintain security audit logs to remove or defend against malicious visitors or attackers (e.g., thwarting DDOS attacks). This information is logged internally within the web servers that host our Site and stored on an ongoing basis.
Your GDPR Rights: Natural persons have a right to (i) request access to, correction and/or erasure of their personal data; (ii) object to processing of their personal data; (iii) restrict processing of their personal data; and (iv) request a copy of their personal data, or have a copy thereof sent to another controller, in a structured, commonly used and machine-readable format under the right of data portability. These rights may be exercised by contacting: Ryan Wells, CCO, at email@example.com. Natural persons also have the right to lodge a complaint about the processing of their personal data with a data protection authority.
Objecting to Legitimate Interest/Direct Marketing: Natural persons may object to personal data processed pursuant to PathWise’s legitimate interest. In such case, PathWise will no longer process their personal data unless PathWise demonstrates appropriate overriding legitimate grounds for the processing or if needed for the establishment, exercise, or defense of legal claims. Natural persons also may object at any time to the processing of their personal data for direct marketing purposes (such as opting out of investment research emails, see Accessing and Modifying Information and Communication Preferences above). In such a case, their personal data shall no longer be used for that purpose.
EU Representative: The firm does not have a representative physically in the EU as the firm manages the US assets of EAA/EU clients. The person responsible for EU regulations and EU clients is Ryan Wells, CCO firstname.lastname@example.org located at 2255 Contra Costa Blvd., Suite 207, Pleasant Hill, CA ,94523 925-939-5607.