Folmar Advisory, LLC
Client Privacy Policy
Effective: December 20, 2021; Updated: May 22, 2023.
Our Commitment to You
Folmar Advisory, LLC (“Folmar”) is committed to safeguarding the use of your personal information that we have as your Investment Advisor. Folmar (referred to as "we", "our", and "us" throughout this notice) makes reasonable efforts to protect the security and confidentiality of the personal information we have and to ensure that such information is used for proper business purposes in connection with the management or servicing of your account. Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything we can to maintain that trust.
Details of our approach to privacy and how your personal nonpublic information is collected and used are set forth in this privacy policy.
This site privacy policy (“Privacy Policy”) explains how Folmar collects, uses, shares, and safeguards information about you when you engage with Folmar, or you use the Folmaradvisory.com website and any associated content and materials available in connection with the website (collectively, the “Site”).
We reserve the right to make changes to this Privacy Policy at any time and for any reason. Any changes will be reflected in a revised policy posted on the Site and we will alert you that there has been a change by updating the “Revised” date displayed on the Privacy Policy. If Folmar determines that such changes materially affect your privacy rights, we will provide additional notice to you. Additionally, we strive to send you notice of our privacy policy at least once every twelve months.
Collecting Your Information
We may collect information about you in a variety of ways but generally speaking it is done either through (1) you completing our web forms or (2) you visiting our websites. The types of information we may collect include, but are not limited to:
Information You Provide To Us
This is personal information you choose to provide in connection with completing an online form, providing content on the Site, or other activities in which you participate on the Site, such as your name, age, phone number, location, and financial information.
Information We Collect About You
Information our servers automatically collect when you visit, use, or browse the Site, such as your IP address, your operating system, browser version, the address of a referring website, the pages you visit on the Site, the dates and times you visit the Site, device and usage information, such as language preferences, referring URLs, country, location, information about how and when you use our services and other technical information. If you access the Site from a mobile device, information about the type of mobile device you use.
In order to collect this information, the Site may use cookies, web beacons, and other tracking technology, depending on the features offered. Tracking technology is useful for gathering information such as browser type and operating system, tracking the number of visitors to the Site, and understanding how visitors use the Site. Cookies can also help us customize the Site and improve your experience. If you previously provided personally identifiable information to us, a unique identifier in the cookie may tie the information collected via the cookie to such information. Aggregate cookie and tracking information that does not directly identify you may be shared with third parties. We do not control these third parties’ tracking technologies or how they may be used. Most web browsers are set to accept cookies by default. You can usually choose to set your browser to disable or reject cookies. Be aware that disabling or rejecting cookies could affect the availability and functionality of the Site or certain portions of the Site. Also, please note that we may still use information we’ve collected from cookies prior to your disabling them; however, we will not collect any further information from the disabled cookies.
Additional Information
Folmar does not collect any sensitive personal data on its users, nor does it collect any data from third parties. If a user completes a web form questionnaire, the user will have a lead identifier tagged to their account. The lead ID (“Lead ID”) is intended to be pseudonymized when used internally by Folmar and de-anonymized when provided externally by Online Partners.
Using Your Information
We may use the information that you provide to us to match you with a financial advisor or for our Online Partners to attribute revenue to Folmar appropriately. Any information collected about you via the Site may be used to: help increase the efficiency and operation of the Site; deliver and improve our products and services; manage our business; monitor and analyze usage and trends to improve the Site and the user experience; generate a personal profile of you to make future visits to the Site more personalized; perform the functions and services you request; send you confirmations, updates, alerts, administrative messages, and otherwise facilitate your use of the Site; request feedback and contact you about your use of the Site; respond to your emails; compile anonymous statistical information and analyses, which we may use internally and/or provide to third parties; to support our customers and their interactions with you through our Services; market our services (and those of third parties) to you that we believe may be of interest to you; and deliver information to you that you request or that we think may be of interest to you, such as articles, news, or information about various promotions.
Sharing Your Information
We may share your information with third parties that perform services for or on our behalf this includes:
- When you provide authorization for us to share it with a financial advisor
- To perform analytics on website and/or web form engagement
- When it is shared as part of a transfer of assets
- For security and fraud purposes
- When we are required by law to share it.
Match With a Financial Advisor
Folmar shall only provide web form submitted answers with a financial advisor if you provide your express consent. Otherwise, Folmar does not provide any personal information.
Analytics
We may allow selected service providers or processors, such as Hotjar, to use tracking technology on the Site, which will enable them to collect information about how you use the Site over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.
Transfer of Assets
If we reorganize or otherwise transfer some or all of the Site or our assets to another organization (such as in the course of a merger, dissolution, or liquidation), your information may be shared with the transferee; however, we will ask the transferee to honor commitments we made in this Privacy Policy.
Targeted Advertising
Folmar does not sell or share your data in exchange for monetary consideration or value.
Security and Fraud
We allow third parties such as Cloudflare to receive personal information from our users to provide both security and fraud protection to Folmar. We do not control these third parties or how it is used. For more information on how Cloudflare uses your personal information, please visit their privacy policy here: https://www.cloudflare.com/privacypolicy/
Required by Law
We may share your information as permitted or required by any applicable law in response to a subpoena or other legal process or as we deem necessary to investigate or remedy any actual or potential violation of our policies or to protect the rights, property, and safety of Folmaradvisory.com or others, as we deem appropriate.
Attribution
Folmar allows third parties to host our web form on their website domain (“Partner Websites”). For the purposes of attributing revenue and analysis, Partner Websites receive your LeadID along with certain attribution features. Folmar does not provide any identifiable personal information while doing this and the LeadID is not intended to be re-identified by third by our Partner Websites. If you have reason to believe a Partner Website has violated this section, please contact us using the information below.
Security of Your Information
While we take reasonable steps to protect any personally identifiable information you choose to provide via the Site from unauthorized access, please be aware that, despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online can potentially be intercepted and used by unauthorized parties, so please keep this in mind when disclosing any personal or personally identifiable information via the Site. To help ensure security via the Internet, we recommend you keep your browser up to date with automatic security updates enabled.
Policy for Children
We do not use the Site to solicit information from or market to children under the age of 18. By using the Site, you represent that you are at least 18 years of age. We encourage parents and legal guardians to monitor their children’s internet usage and to instruct their children never to provide personal information through the Site or any other website without parental consent. If you believe a child has provided personal information to us via the Site, please contact us and we will use reasonable efforts to locate and delete the information.
Links to Other Websites and Third Party Practices
The Site may contain links to third party websites. It is our intent to provide links only to other quality websites. However, we have no control over these linked websites or, for that matter, any third parties. Any information collected by websites, other than the Site, is not covered by this Privacy Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites that may be linked to or from the Site. We encourage you to read the provisions of privacy policies on other websites before providing them with your personal information.
Submitting Information From Outside The United States
We control and operate the online and mobile resources from within the United States of America (the “U.S.”). Information collected through the Website and Services may be stored and processed in the United States or any other country in which our vendors or we maintain facilities. Although we do not actively block or monitor visitors from other countries, the Website is directed only at visitors from the U.S. As such, this Privacy Policy is consistent with U.S. law and practice and is not adapted to other laws (including European data security and privacy laws). Folmar will apply the applicable laws of the U.S., including as embodied in this Privacy Policy in place of data protections under your home country's law. That is, you freely and unambiguously acknowledge that this Privacy Policy, not your home country's laws, controls how we will collect, store, process, and transfer your personal information. Similarly, the English language version of this Privacy Policy is the controlling version regardless of any translation you may attempt.
Excercise Your Privacy Rights
Folmar takes privacy seriously. Where applicable, data subjects have certain rights which they can request for Folmar to fulfill. These requests can be made by either the data subject or an authorized agent. These rights include:
- The Right to Know.
You have the right to request that Folmar disclose the personal data that Folmar has collected about you - The Right to Amend.
You have the right to correct any information that Folmar stores about you - The Right to Delete.
You have the right to request that Folmar delete information that it maintains about you, subject to certain exceptions - The Right to Opt Out Of Your Personal Information Being Sold or Shared.
You may opt-out of Folmar sharing or selling your information.
In order to exercise any of the rights detailed above, contact@folmaradvisory.com. We will use your email as proof of verification unless otherwise prohibited. Exercising your rights under this section will not result in any discrimination by Folmar. We will treat you the same as any other user. If you disagree or dispute a decision that has been made on the scope or application of the rights described in this clause, you may appeal this decision by contacting contact@folmaradvisory.com
Retention Period
Folmar shall only store personal information for as long as it is required. This is determined by considering the purposes for which it was obtained in accordance with applicable laws. Our retention period is based on (1) the nature of our relationship with the data subject and (2) any legal obligations we are bound to fulfill.
Contact Us
If you have questions or comments about this Privacy Policy, please send us an email at contact@folmaradvisory.com.
California Consumer Privacy Act Notice
The California Consumer Privacy Act (“CCPA”), which provides California Consumers certain rights regarding their Personal Information (“PI”) as those terms are defined in the CCPA, became effective on January 1, 2020. As of that date, the California Attorney General had not completed the rule making process to establish the regulations for businesses to implement the law.
In the meantime, we are providing you with notice of the personal information we collect and our purposes for that collection for data that may be subject to the CCPA (“CCPA Notice”). This CCPA Notice does not cover information that is outside of the scope of the CCPA. This notice also does not apply to data collected from employees, applicants or contractors or to data collected from individuals acting as representatives of another business in connection with business communications or transactions.
We may collect and share the following personal information that may be subject to the CCPA for the following purposes:
| Category of PI | Purposes for Collection | Categories of Third Parties with whom PI is shared |
|---|---|---|
| 1. Identifiers and Personal Records
(e.g., name, phone number, e-mail address, IP address) | Providing our services, improving our services, quality assurance, marketing, security, internal analytics and reporting | Vendors, data analytics partners, advertising partners, financial services providers |
| 2. Internet Usage Information (e.g. information regarding your interaction with our services) | Security, internal analytics and reporting | Vendors, data analytics partners, advertising partners |
| 3. Geolocation Data | Security, internal analytics and reporting | Vendors, data analytics partners, advertising partners |
| 4. Inferences from PI Collected (e.g. your preferences, your likelihood of interest in certain of our services) | Providing our services, improving our services, marketing | Vendors, data analytics partners, advertising partners |
In addition, we may collect, use, and disclose your PI as required or permitted by applicable law, or as directed by you, in accordance with this Privacy Policy.
We do not knowingly “sell” personal information that we collect from you, in accordance with the definition of “sell” in the CCPA, and will treat personal information we collect from you as subject to a do not sell request.
California Consumers have the right to exercise the privacy rights under the CCPA. California Consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA. Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI.
We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.
If you are a California Consumer and would like to register a request under your “right to know about personal information collected, disclosed or sold” (including right to obtain copies of specific pieces and/or information about categories of personal information practices), “right to request deletion of personal information,” or “right to opt-out of the sale of personal information,” or otherwise exercise any of your other privacy rights under the CCPA, you can contact us at contact@folmaradvisory.com and we will respond to your request as and when we have regulatory guidance on how to properly verify you and respond to your requests and are able to do so.
You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
- The categories of PI we have collected about you.
- The categories of sources from which we collected your PI.
- The business or commercial purposes for our collecting or selling your PI.
- The categories of third parties with whom we have shared your PI.
- The specific pieces of PI we have collected about you.
- A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
- A list of the categories of PI sold about you in the prior 12 months, or that no sale occurred. If we sold your PI, we will explain:
- The categories of your PI we have sold.
- The categories of third parties to which we sold PI, by categories of PI sold for each third party.
You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining.
Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.
Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Note also that we are not required to delete your PI that we did not collect directly from you.
You may alternatively exercise more limited control of your PI by instead exercising one of the more limited opt-outs, including unsubscribing from email newsletters.
We will revise this CCPA Privacy Notice from time to time as implementing regulations further develop and come into effect and we are able to provide you with better information on your CCPA rights and how to exercise them.
Nevada Residents
Nevada residents have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. This site does not engage in activity that triggers the opt-out requirements defined in Nevada Revised Statutes Chapter 603A, beyond the purpose of the services offered on this site. However, you can exercise this right by contacting us at contact@folmaradvisory.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. We will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change