We do not disclose client information to unaffiliated third parties unless one of the following limited exceptions applies:
We receive prior written consent;
- Through written consent we disclose client information to the client, and persons authorized by the client such as Issuers and Mutual Funds. We disclose client information to brokers, custodians and other service providers with whom we must share information in order to manage or service each client account;
- We may disclose client information in limited circumstances where we are permitted or required by law to release the information to the recipient.
We collect personal information from the following sources in the normal course of business to serve you better:
- User/Account information is included in a feed from the Broker/Dealer or the Back Office provider that provides services to the Broker/Dealer. This entails client name and address, account number, their positions in different shares and the number of shares.
- Voting patterns obtained by the virtue of collecting their votes from our portals, from the paper ballots and phone votes collected by our partner companies.
We protect the confidentiality and security of your personal information. We restrict access to client’s personal information as much as possible, to those employees who need to know in order to provide our services. All the data that is collected in our portals or via our feeds processes is by default classified to be confidential data. Out of the two categories of personal data mentioned above, we collect User/Account Information via data feeds via our Broker/Dealer clients and the Voting patterns via our portals.
At INVeSHARE, the privacy of client information is a primary concern. We have established various safeguards to ensure privacy and review our policy and safeguards on an ongoing basis and implement new procedures and amend our policies where and whenever necessary. Current measures to protect privacy extend to three different areas of service and some of our safeguards are as follows:
Our staff – All staff members must sign an agreement which incorporates a confidentiality clause. Personal information is provided to accredited professionals on a need-to-know basis;
Paper files – Client personal information is stored in a secure environment. Older information may be stored off-site and is also maintained in a secure environment provided by a third party specializing in secure storage;
Electronic files – As with many industries and businesses, technology has significantly impacted the way in which we conduct our business. INVeSHARE makes use of various safeguards such as secure firewalls for all internet connections, frequently changed passwords, encryption of back-up files that are stored offsite with a third party service provider. Any information stored offsite with third party providers is also covered by separate confidentiality agreements.
Information Shared with our Print Partners – In order to service our clients, we partner with Industry leading Print Providers to service the paper delivery and fulfillment side of the business. We have PII contracts (which are reviewed by INVeSHARE’s Legal counsel and signed off by the executives) with each of these partner companies and share the User Information (First Name, Last Name, Address) with them in order to complete the delivery of the paper materials. All this transaction is done in an encrypted and secure ftp process.
The Broker/Dealers are responsible for maintaining the confidentiality of their client’s User ID and Password, and are fully responsible for all activities that occur under those User ID and Password. INVeSHARE systems do not store the login IDs or the passwords associated with those logins as the authentication always happens at the Broker/Dealer’s systems. The Broker/Dealer agree to (a) immediately notify INVeSHARE LLC of any unauthorized use of User ID and Password or any other breach of security, and (b) ensure to train their clients to exit from their account at the end of each session. INVeSHARE cannot and will not be liable for any loss or damage arising from your failure to comply with this section. Also, the quality of the data provided by the Broker/Dealer is the sole responsibility of the Broker/Dealer. INVeSHARE does not tamper or modify the data provided by the Broker/Dealer and uses that information as is.
If there is ever a requirement to withdraw consent with respect to disclosure of PII data, then the Broker/Dealer needs to collect that information and present it to INVeSHARE in a written form of communication. Such notice should contain the name of the Shareholder, their account(s) and the kind of request that the Broker/Dealer has approved.
Links to other Sites
For the convenience of our members, our Web sites may contain links to other partner/vendor sites. While we generally try to link only to sites that share similar high standards and respect for privacy, we are not responsible for the content, products or services offered or the privacy and security practices employed by these other sites.
INVeSHARE’s Chief Compliance Officer (CCO) is charged with the responsibility for ensuring compliance with the policies and procedures that have been established for INVeSHARE, including those outlined in this document.
We welcome the opportunity to answer any questions you may have about this statement or the safeguarding and confidentiality of your information. If you have any questions or concerns regarding our policies and procedures, please contact our CCO at email@example.com.
Any exceptions not addressed within this policy will be addressed by the CCO who can be reached at firstname.lastname@example.org.