Last modified: June 2020
RiverFront Investment Group (“RFIG,” “we,” “our,” or “us”). RFIG is a registered investment advisor that provides investment and asset management services (the “Services”). We take the privacy of our clients, our partner financial advisors, and those visiting our website (“you” or “user”) very seriously. Please read this Privacy Statement carefully to learn how we collect, use, share, and otherwise process information.
This Privacy Statement applies to information that we collect:
- through websites operated by us from which you are accessing this Privacy Statement, www.riverfrontig.com (collectively, the “Website”);
- through our social media pages that we control from which you are accessing this Privacy Statement (collectively, our “Social Media Pages”);
- through HTML-formatted email messages that we send you that link to this Privacy Statement and through your communications with us;
- when we provide you with any investment advice or asset management services (“Management Services”). Note: if you have a financial product or service with us, we will use and share your personal information in accordance with our privacy notice which is available upon request.
Collectively, we refer to the Website, the Apps, our Social Media Pages, and our Management Services as the “Services.” By using the Services, you agree to the terms and conditions of this Privacy Statement.
1. ACCEPTANCE OF PRIVACY STATEMENT
Each time you access, use, submit information on, or browse the Website, you signify your acceptance of the then-current Privacy Statement. If you do not accept this Privacy Statement, you are not authorized to use the Website and must discontinue use of the Website immediately. If you provide personal information to RFIG offline, RFIG asks that you review this Privacy Statement which also governs information collected offline .
2. COLLECTION OF INFORMATION
2.1. PERSONAL INFORMATION
RFIG collects personal information from you at various places and through various mechanisms when you use our Services. This may include, for example, when your financial advisor provides your personal information to us, when you invest with RFIG, when you provide your information to us for any reason, when you request information or materials from us, or when you communicate with us about questions or other matters. We may collect personal information from you through our online services. For example, you may provide us with your name, mailing address, phone number, email address and other information when you fill out a form on our website to subscribe to RiverFront commentary and other publications.
Personal information is only collected if you voluntarily provide such information to RFIG. Such information may include, without limitation, your first, middle and last name, maiden name, marital status, date and place of birth, current and former home addresses, email addresses, telephone numbers, income and asset information, account transaction information, driver’s license information and state/governmental identification number (where permitted by law), tax and withholding information, Social Security number, and other information that is not otherwise publicly available.
RFIG also may acquire personal information about you from other sources, such as Service Providers (as defined below in Section 5.1), vendors and other third parties, that may share information as permitted in their privacy policies. This Privacy Statement does not apply to personal information about you that we receive from other sources. However, if we combine information that we collect through other sources with personal information covered under this Section 2.1 in a manner that associates it with your name and contact information, we will use such information in accordance with the stricter of applicable law or the terms of this Privacy Statement.
2.2. NON-PERSONAL INFORMATION
Non-personal information refers to data and information that does not personally identify you as the individual to whom the data or information relates, which may include data and information that (i) is aggregated (that is, relates to a group of individuals) by RFIG or a third party (“aggregated non-personal information”), or (ii) is not linked to personal information (“de-identified non-personal information”). In either case, non-personal information does not personally identify the individual to whom the information or data collected relates. Non-personal information may include, without limitation, your media access control (MAC) address, Collection Technology (as defined below) information, type of computer or device you use, the operating system you use (e.g., Microsoft Windows, Mac OS or Google Chrome), the type of browser you use (e.g., Firefox, Chrome, Internet Explorer or Safari), the domain name of the Internet service provider, your activities while visiting or using the Website and the content you access or view, the time of your visit to or use of the Website, the pages you visit and the time spent on the pages, your general geographic location such as the city from which your computer or device is connecting to the Internet, information regarding the Website you visit prior to and after visiting the Website, and information regarding your Internet location when you see RFIG’s ads and whether you click on such ads.
2.2.1. Cookies and other “Collection Technology”
Non-personal information may be collected in a variety of ways, but Collection Technology is often used. “Collection Technology” refers to cookies, web beacons, pixels, gifs, tags and other technologies that collect information in similar ways. Collection Technology such as a cookie may store a piece of data on your browser or device, while other forms of Collection Technology may identify your browser or device and/or collect information through other means. When you visit the Website, or visit another website or application, your browser or device may be exposed to Collection Technology and Collection Technology may be stored on your browser or device. RFIG may come to acquire non-personal information about you upon collection of the non-personal information or some time thereafter.
- Necessary Cookies: We use these cookies to run our site, and to identify and prevent security risks. For example, we may use these cookies to store your session information to prevent others from changing your password without your username and password.
- Preference Cookies: We use these cookies to remember your settings and preferences, and to improve your experience on our site. For example, we may use these cookies to remember your language preferences.
- Performance Cookies: We use these cookies to collect information about how you use our site, monitor site performance, and improve our site performance, our services, and your experience.
For example, we can use these cookies to learn more about which features are the most popular with our users and which ones might need some tweaks.
- Marketing Cookies: We use these cookies to deliver advertisements, to make them more relevant and meaningful to consumers, and to track the efficiency of our advertising campaigns, both on our services and on other sites or mobile apps.
If you do not want data collected with cookies, you can learn more about controlling cookies at: http://www.allaboutcookies.org/manage-cookies/index.html.
You may also delete and/or refuse the use of certain Collection Technologies by selecting the appropriate settings on your browser. You may use the public portion of the Website even if you choose to refuse or delete such Collection Technologies; however please note that this you will not be able to access the Adviser Only portion of the Website.
2.2.2. Analytics Services
The Website may use analytics services provided by third parties, such as Google Analytics and Moz, among others. These analytics services use Collection Technology to collect and store information about you and your use of the Website, which may include the personal and non-personal information described above.
You can read Googles’ Privacy Statement, which applies to Google Analytics, at http://www.google.com/intl/en/policies/privacy/. You also can opt-out from being tracked by Google Analytics in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current browser https://tools.google.com/dlpage/gaoptout. You can read Moz’s Privacy Statement, which applies to Moz analytics, at http://moz.com/privacy-policy.
3. LINKING TO OTHER SITES
Our Website may contain third-party links, include third-party integrations, or offer a co-branded or third-party-branded service (collectively, “Other Links and Sites”). Through these Other Links and Sites, you may be providing information (including personal information) directly to the third party (which may include certain Service Providers), us, or both. Because these Other Links and Sites may not be hosted or controlled by RFIG, however, we are not responsible for the privacy practices of those Other Links and Sites or the content provided thereon. Collection Technology also may be used by some of those Other Links and Sites. Therefore, the privacy policies with respect to these areas may differ from those applicable to the Website and we encourage you to review the privacy policies of each of those Other Links and Sites.
4. SOCIAL MEDIA
Generally, online social media resources are interactive tools that enable you to collaborate and share information with others. Social media resources include, but are not limited to, social networks, discussion boards, bulletin boards, blogs, wikis, and referral functions to share web site content and tools with a friend or colleague. RFIG may collect personal information to enable you to use our Social Media Pages or online social media resources offered either by a third party. We may also enable you to use our Social Media Pages or other social media resources to post or share personal information with others.
If you use online social media resource offered by a Third Party Social Media Resource (“Third Party SMR”) through the RFIG Site or interact with any RFIG social media account, you acknowledge that RFIG may be able to access any information you make public through such Third Party SMR (such as your username, comments, posts and contacts) and other information your privacy settings on such Third Party SMR permit RFIG to access. RFIG will comply with the terms of this Privacy Statement and the privacy policies applicable to the social media resources it uses.
5. USE, SHARING AND DISCLOSURE OF PERSONAL INFORMATION
RFIG may use your personal information to:
- provide you with Services;
- process transactions that you have requested;
- develop, operate, improve, deliver, maintain, and protect our Website and Services;
- send you communications, including by email;
- process any applications, forms, requests, inquiries, or other information you submit through the Website;
- administer and process investments or payments;
- attend to tasks relating to your transactions and account with RFIG;
- provide customer service;
- update account information;
- inform you of events, programs, products or services that may be of interest to you;
- customize the content or functionality of Website to your preferences;
- respond to your communications; and
- manage your investment account or portfolio.
By providing your personal information to us, you authorize RFIG to transmit email and direct mail to you, call you, including with an automated telephone dialing system, send push notifications to your device, send you text messages, and otherwise contact you concerning these matters.
Your personal information will be intentionally disclosed to third parties as follows:
5.1. Disclosures to Third-Party Service Providers
RFIG may provide your personal information to third parties who work on behalf of or with RFIG including, without limitation, persons or firms that perform support services for us, such as Sponsor Firms; broker dealers; attorneys; accountants; auditors; consultants or consulting firms who are evaluating our business or are assessing our compliance with industry standards; and record keeping companies (“Service Providers”). These Service Providers may use your personal information as provided in the first paragraph under Section 5 above to help RFIG administer the Services, including, but not limited to, providing brokerage services and asset and accounting reconciliations, administering the Website, managing the Social Media Pages, complying with governmental or quasi-governmental reporting; providing customer service; or communicating with you about offers, events, programs, or other information relevant to RFIG. We may also share your personal information with Service Providers to provide general functions on our behalf relating to the Website and Services. Prior to disclosing your personal information, we enter into contractual agreements with these Service Providers parties that prohibit them from disclosing or using your personal information other than to carry out the purposes for which we disclose the information.
5.2. Disclosures Under Special Circumstances
RFIG may provide information about you in response to or to cooperate with law enforcement, government, quasi-governmental and public agency requests or reporting requirements, subpoenas, court orders or legal process; to respond to your requests for customer service or other information; to establish or exercise our legal rights or defend against legal claims; or to protect the safety or property of RFIG or others. RFIG also may provide information about you if RFIG believes it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required or permitted by law.
5.3. Major Transactions
RFIG reserves the right to transfer any and all information, including, without limitation, personal information, to any RFIG affiliate or a third party or successor in the event of any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations (including, without limitation, in connection with bankruptcy or any similar proceedings).
5.4. Other Purposes
We may use your information for other purposes specifically disclosed to you at the time we request your information. By providing your information, you consent to all disclosed uses.
6. USE, SHARING AND DISCLOSURE OF NON-PERSONAL INFORMATION
RFIG and its Service Providers may use your non-personal information in a variety of ways, such as to administer the Website, improve the Website, improve navigation of the Website upon your return visit, in relation to or to improve the Services we offer, analyze and develop advertisements and fundraising campaigns, provide you with special offers and promotions and determine their effectiveness, customize the content or functionality of Website to your preferences, and analyze trends and site usage.
RFIG also may use non-personal information to present you with targeted content and advertisements based on your past visits to the Website and non-personal information collected over time by us, and to determine the effectiveness of and optimize the content and advertisements, analyze your interactions with the content and advertisements you are presented with, and how those interactions relate to your visits to the Website.
If you prefer not to receive targeted advertisements from us, as described above, please email firstname.lastname@example.org.
RFIG may share or disclose your non-personal information with or to employees and Service Providers to perform the tasks described in Sections 5 and 6. RFIG also may use, disclose or share your non-personal information for our business purposes and other purposes consistent with applicable laws. If any aggregated non-personal information or de-identified non-personal information becomes identifiable to a person, RFIG will treat such information as personal information.
7. PROTECTION OF PERSONAL INFORMATION
We have implemented reasonable and technically feasible physical, technical and administrative safeguards. to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure. We follow generally accepted industry standards to protect personal information submitted to us by users, both during transmission and once we receive it.
Please be aware, however, that the Website and data storage are run on software, hardware and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond RFIG’s control. No transmission of data over the internet or method of electronic storage is guaranteed to be 100% secure.
8. NOTICE OF PRIVACY RIGHTS OF CALIFORNIA RESIDENTS
8.1. California “Shine the Light” Disclosure and CCPA
California residents are protected as “consumers” by the California Consumer Protection Act ("CCPA") with respect to personal information, subject to certain statutory exceptions set forth in CCPA.
RFIG does not sell or share personal information with third-parties for their marketing purposes. Under California S.B. 27 (“Shine the Light” Law), California residents have the right under certain circumstances to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. Under the CCPA, California residents may request this information twice a year. To make such a request, please send an email to email@example.com and please include the phrase “California Privacy Request” in the subject line, along with your name, address and email address. We will disclose and deliver to you free of charge this information in response to a verifiable request within forty-five days of receiving such a request.
California residents are protected as “consumers” by the California Consumer Protection Act ("CCPA") with respect to personal information, subject to certain statutory exceptions set forth in CCPA. Under CCPA, California residents have:
- the right to request disclosure of collection and sales practices in connection with the consumer's personal information, including categories of personal information collected, source of the information, use of the information and, if the information was disclosed or sold to third parties, the categories of personal information disclosed or sold to third parties and the categories of third parties to whom such information was disclosed or sold;
- the right to request a copy of personal information collected during the 12 months before your information (subject to certain requirements such as verification of identity);
- the right to request such information deleted (subject to certain requirements and exceptions)
- You have the right to opt-out of the sale of your personal information by a business. We do not, and will not, sell your personal information.
- You may not be discriminated against because you exercise any of your rights under the CCPA in violation of Cal. Civ. Code §1798.125.
- You may designate an authorized agent to make requests under the CCPA on your behalf if you sign a written declaration declaring such and the authorized agent is a natural person or business entity registered with California's Secretary of State.
8.2. California “Do Not Track” Disclosure
At this time, RFIG does not alter the practices detailed herein based upon your selection of the “Do Not Track” setting or other “opt out” setting or feature that may be offered by your browser.
Our Services are not designed for individuals under the age of 16. We do not knowingly collect or store any personal information from children under the age of 16. If we become aware that we have collected personal information from a user under age 16, we will remove his or her personal information from our files. If you are a parent or guardian and believe RFIG may have inadvertently collected personal information from your child, please notify us immediately by sending an email to firstname.lastname@example.org.
We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); and
- Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations).
11. CHANGES TO THIS PRIVACY STATEMENT
The Privacy Statement may be revised from time to time. We display an effective date at the end of this Privacy Statement (“Last Revised Date”) for you to know when there has been a change. Accordingly, you should check the Privacy Statement on a regular basis for the most current privacy practices. Each time you access, use or browse the Website, you signify your acceptance of the then current changes to the Privacy Statement. Any changes in the Privacy Statement will take effect upon posting.
12. CONTACT US
Last Revised Date: June 2020
No Offer, Solicitation, Investment Advice or Recommendations
This website is for informational purposes only and does not constitute an offer to sell, a solicitation to buy, or a recommendation for any security, nor does it constitute an offer to provide investment advisory or other services by RiverFront Investment Group, LLC or any of its employees or affiliates. No reference to any specific security constitutes a recommendation to buy, sell or hold that security or any other security. Nothing on this website shall be considered a solicitation or offer to buy or sell any security, future, option or other financial instrument or to offer or provide any investment advice or service to any person in any jurisdiction. Nothing contained on the website constitutes investment advice or offers any opinion with respect to the suitability of any security, and the views expressed on this website should not be taken as advice to buy, sell or hold any security. In preparing the information contained in this website, we have not taken into account the investment needs, objectives and financial circumstances of any particular investor. This information has no regard to the specific investment objectives, financial situation and particular needs of any specific recipient of this information and investments discussed may not be suitable for all investors. Any views expressed on this website by us were prepared based upon the information available to us at the time such views were written. Changed or additional information could cause such views to change. All information is subject to possible correction. Information may quickly become unreliable for various reasons, including changes in market conditions or economic circumstances.
Restrictions on Use of Materials
By accessing this website, you agree that you may not (i) copy, reproduce, republish, upload, post, transmit, alter, or distribute in any way material from this website in any manner inconsistent with the purposes for which it is offered RIG, (ii) without the prior written consent of RIG, copy, modify, or display the logos of RIG, or any text, graphic images, or other content from this website, (iii) redeliver any of the pages, text, images, or other content of this website without the prior written consent of RIG, (iv) include "RiverFront Investment Group," "RiverShares," "RIG,” “RiverFront Advantage,” “RiverFront ETF Advantage” or the name of any of their respective personnel, or any variation of any of the foregoing, as a metatag, hidden textual element, or any other indicator that may create a false or misleading impression of affiliation, sponsorship, or endorsement between any user and/or website and RIG, (v) upload, e-mail, or otherwise transmit any material that contains viruses or any other computer code, files or programs that might interrupt, limit or interfere with the functionality of any computer software or hardware or file communications equipment that is owned, leased, or used by RIG, or (vi) create a link to this website unless and until the user or the operator of the other website has executed a standard agreement with RIG for the granting of permission to establish such a link.
Limitation of Liability
The materials on this website are provided "as is" and without warranties of any kind either expressed or implied. To the fullest extent permissible pursuant to applicable law, RIG disclaim all warranties, expressed or implied, including, but not limited to, implied warranties of merchantability and fitness for a particular purpose. RIG does not warrant that the functions contained in the materials will be uninterrupted or error-free, that defects will be corrected, or that this website or the server that makes it available are free of viruses or other harmful components. RIG does not warrant or make any representations regarding the use or the results of the use of the materials on this website in terms of their correctness, accuracy, reliability, or otherwise. In no event shall RIG be liable for any direct, incidental, consequential, or punitive damages or injury or loss, including, but not limited to, loss of anticipated profits, benefits, use or data that may result from any performance, failure of performance, error, omission, interruption, deletion, defect, delay in operation or transmission, computer virus or worm, communications line failure, theft or destruction or unauthorized access to, alteration of, or use of information, resulting from the use of or access to this website.