Privacy Policy

Introduction

Atria Wealth Solutions (“Atria,” “we,” “us” or “our”) understands that by using our website, you are entrusting us with your personal information. As a result, we have crafted this Privacy Policy (“Privacy Policy”) with you in mind, so that we can protect your personal information and inform you of your privacy rights. In this Privacy Policy, we explain our policies and procedures for data collection, use, maintenance, protection, and disclosure when you visit https://grovepointfinancial.com/ (the “Site”). This policy is effective as of December 30, 2019.

We will update this policy as we adjust our procedures to protect your information. Before these changes go into effect, we will post our updated Privacy Policy here, along with an effective date for the amended Privacy Policy. Once we alter the Policy, continued use of the Site on or after the effective date is considered consent to the amended Policy.

Automatically Collected Information

Automatic Information Collection

As is customary for websites, the Site will collect information, including technical and routing information about your computer or device, without you being prompted. We use this information to optimize our Site for our users’ use.

Cookies & Web Analytics

Some information, including but not limited to IP addresses, operating systems, browsers, and browsing patterns, is either tracked or collected using “cookies” (which are small data files that a website places on your hard drive for record-keeping purposes) or “web beacons” (which are transparent pixel images that are used in collecting information about website usage). We use these to ensure that our content improves and meets your, and other visitors’, needs. While most of the cookies we use will “disappear” when you finish browsing, we also use persistent cookies. Persistent cookies stay on your computer simply to ensure we recognize your device when you revisit our Site.

Please note that there are options on most browsers (including, but not limited to, Google Chrome, Mozilla Firefox, Safari, and Internet Explorer) to disable cookies. You can use such features to disable cookies, but it may impact your use of certain Site functions. To learn more about your ability to manage cookies and web beacons, please consult the privacy features in your browser.

Google Analytics

We may use Google Analytics to collect information about your use of the Site. Google Analytics collects certain information, such as how often you visit the Site, the pages you visit, and the other websites you use prior to visiting the Site. We may use the information received from Google Analytics to improve the Site. Google Analytics collects only the IP address assigned to you on the date you visit the website, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with any other information collected from you. Although Google Analytics stores a permanent cookie on your machine to identify you as a unique user the next time you visit the Site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is governed by the Google Analytics Terms of Use available at http://www.google.com/analytics/tos.html and the Google Privacy Policy available at https://policies.google.com/privacy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.

Other Information We Collect

When you use our website, we may request personal information, including your name, address, email, telephone number, or other identifiers. This information is only collected when you provide it to us, and we may use it for a variety of reasons, as explained in more detail below.

Use of Personal Information

We may use (and, where specified, share) your personal information for the following purposes:

Communication

When you contact us, we may use personal information to reply and provide you with the services or information you requested. We also may use your personal information to collect feedback on our Site and policies.

Site Improvement

We may use your personal information and browsing behavior to personalize our Site and improve the overall user experience. We also may use personal information to evaluate responsive rates or gauge the usability of the Site.

Protect Content

In order to stop malicious, deceptive, fraudulent or illegal activity from occurring on our website, we may use identifying information to monitor users’ behavior on the Site. Our attempts to prevent malicious, deceptive, fraudulent, or illegal internet activity may cause some users to be suspended from the Site and its features.

Data Processing

We process your information so that we can deliver information that you have either already requested or that we believe you would be interested in. Any information we transfer to a third-party processor that is not affiliated with Atria is done so as permitted by law. In some of these cases, we process this information automatically, but in others we will ask your permission in advance. Either way, your information helps us understand what our visitors are looking for, and helps us operate as a better, more responsive business. We always strive to respect your privacy.

Data Rights

Subject to applicable law, you may have the right to request and obtain information about, or copies of, the personal information we collect regarding you, where said information comes from, the business or commercial purpose for collecting this information, the third parties with whom this information is shared, and whether our source of information is publicly available.

All of our collection and processing is in furtherance of a legitimate business interest under applicable law. We recognize that when collection and processing of personal information is based on consent, a user may withdraw consent if the consumer wishes to do so, and that such consumer maintains a right to his or her own data.

For EU Data Subjects

The European Union’s General Data Protection Regulation (“GDPR”) and other countries’ privacy laws provide certain rights for data subjects. We are not established in the European Union, however, and we do not offer goods or services to data subjects in the European Union, nor do we monitor behavior of data subjects in the European Union for the purposes of profiling. For these reasons, your rights under GDPR may be limited in relation to your use of our website. To the extent GDPR grants you rights in relation to the use of our website, we will honor them.

Information Disclosure

We may need to disclose your personal information, as described herein. Most of our disclosures are necessary to either complete a transaction or provide the information you have requested. Nonetheless, we may disclose your information if needed to comply with a court order, law, legal proceeding, or request from the government. We also reserve the right to disclose your information if we have the reasonable belief that said disclosure is fundamental to the safety of individuals associated with Atria or others unaffiliated with the company.

We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to require that the transferee use personal information provided through this Web site in a manner that is consistent with this Privacy Policy.

Tracking Disclosure

We do not respond to web browser “do not track” signals or other similar mechanisms.

Children Under the Age of 13

This Site is not designed for children under the age of thirteen, and we do not collect information about children specifically. If you believe that we have inadvertently collected information from a child in that age demographic, please contact us. Our policy is to delete any information collected from a child under the age of 13 as quickly as possible.

External Links

The Site may contain links to third-party material, including other websites. This material is not affiliated with, or owned by, Atria, and all other websites have their own separate terms and conditions and privacy policies. After you choose to follow a link and leave our Site, we are not responsible for the content of those websites, or their privacy policies. We are not responsible for what information they collect, or how they choose to use that information, as their respective privacy policies control your use of these websites.

Our site also links to websites maintained by other entities that are affiliated with Atria, currently listed on our website as “Our firms.” Although these firms are affiliated with Atria, each of their websites, and your use of those websites, is governed by the website’s own privacy policy.

Security

We utilize standard and reasonable security methods, including administrative, technical and physical safeguards, to prevent theft, unauthorized access, alteration, destruction, or unauthorized disclosure in relation to your information. Our methods are frequently and repeatedly tested and improved. Nonetheless, no communication using the internet is perfectly secure. We will attempt to protect your information, but we cannot guarantee the safety of any information you send to us, and you do so at your own risk. In the unlikely case of a breach of your personal information, we will disclose the breach to you as required under relevant law.

California Consumer Privacy Act

The California Consumer Privacy Act of 2018 (“CCPA”) gives certain individuals (natural persons) who reside in the State of California certain rights to know what personal information we collect about them and how we collect, share, and protect their personal information. This information is set forth in “Information we Collect” and “Sharing Personal Information.” The CCPA also provides individual California residents with a right to opt-out of the sale of personal information, a right to request that a business disclose what personal information it holds about a consumer, and a right to request that a business delete their personal information. Certain individuals are and personal information is excluded from the coverage of the CCPA.

Consumers and Personal Information Excluded from the CCPA

Customer Personal Information. The CCPA does not apply to any personal information we collect or obtain from or about our current and former individual customers who obtain or have obtained a financial product or service from us that is used primarily for personal, family, or household purposes.

Employee Personal Information. The CCPA does not apply to personal information that: (a) we collect about a natural person in the course of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of our business to the extent that the natural person’s personal information is collected and used by us solely within the context of the natural person’s role or former role as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or a contractor of our business, (b) we collect that is emergency contact information of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of our business to the extent that the personal information is collected and used solely within the context of having an emergency contact on file, and (c) is necessary for us to retain to administer benefits for another natural person relating to the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of our business to the extent that the personal information is collected and used solely within the context of administering those benefits.

Consumers and Personal Information Excluded from the CCPA

Customer Personal Information. The CCPA does not apply to any personal information we collect or obtain from or about our current and former individual customers who obtain or have obtained a financial product or service from us that is used primarily for personal, family, or household purposes.

Employee Personal Information. The CCPA does not apply to personal information that: (a) we collect about a natural person in the course of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of our business to the extent that the natural person’s personal information is collected and used by us solely within the context of the natural person’s role or former role as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or a contractor of our business, (b) we collect that is emergency contact information of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of our business to the extent that the personal information is collected and used solely within the context of having an emergency contact on file, and (c) is necessary for us to retain to administer benefits for another natural person relating to the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of our business to the extent that the personal information is collected and used solely within the context of administering those benefits.

Right to Know About Personal Information Collected, Disclosed, or Sold

If you are a California resident and not an individual customer or employee of Atria, you have the right to request that we disclose certain information to you about our collection, use, and disclosure or sharing of your personal information. Once we receive and confirm your request, we will disclose to you:

We will not provide you with specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of the personal information, your account with us, or the security of our systems or networks.

Right to Know About Personal Information Collected, Disclosed, or Sold

Within the last twelve months we have collected the following types of personal information from consumers and shared certain types of personal information with third parties for a business purpose:

Category
Types of Personal Information Collected
Sources from which information is collected
Business or commercial purpose for which information is collected
Categories of third parties with whom we share information
A. Identifiers Your real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, and other similar identifiers. Employment application, employment interview, authorization for background check, and employment or independent contract agreement, consumer reporting agency For our everyday business purposes, including to determine your qualifications for employment or association and verify your identity. Our affiliated broker dealers and investment advisers, legal counsel, and regulatory agencies
B. Personal information described in Section 1798.80(e) of the California Civil Code Your signature, telephone number, passport number, state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, any other financial information, medical information, and certain health insurance information.
C. Protected classification characteristics under California or federal law Age (40 years or older), race, color, national origin, citizenship, marital status, medical condition, physical or mental disability, sex, pregnancy or childbirth, and related medical conditions), military or veteran status.
D. Commercial information Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information Fingerprints (applies to employees, associated persons, and registered representatives). Employment application Required for all employees and associated persons for security purposes Regulatory agencies
F. Internet or other electronic network activity Browsing history, search history, and information on a consumer’s interaction with a website, application, or advertisement. When you access our website or send us an email Supervisory control procedures, data security, and protection of data from unauthorized access Service providers
I. Professional or employment-related information Job application, resume, employment contract, performance review, photo for identification, information for payroll processing and benefits administration, and contact information Employment application, employment or independent contractor agreement, payroll and benefits records, interview To verify employee information and pay and provide benefits to our employees and independent contractors Professional employer organization, legal counsel, regulatory agencies

We generally do not sell personal information and did not sell any personal information in the previous twelve months. We do not sell the personal information of minors under 16 years of age without affirmative authorization.

Right to Request Deletion

If you are a resident of California and are not an individual customer of employee of Atria, you have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and verify a consumer request, we will delete your personal information from our records, unless an exception applies, or de-identify or aggregate the personal information. Your right to request that we delete your personal information is not absolute and is subject to a number of exceptions. There are instances where applicable law and regulatory requirements allow or require us to retain personal information.

We may deny a deletion request if it is necessary for us or our service providers to maintain your personal information for any of the reasons sets forth in Section 1798.105(d) of the CCPA.

Exercising Your Right to Know or Request Deletion of Your Personal Information

If you are a resident of California and are not an individual customer of employee of Atria, you may exercise your right to know or request deletion of your personal information by submitting a request to us by either:

Only an individual who is not a customer or employee of Atria (or a person registered with the California Secretary of State that an individual authorizes to act on his or her behalf), may make a request related to his or her personal information.

You may only make a request to know what personal information we collect, use, or disclose about you twice within a 12-month period.

How We Verify Requests

We are required to verify that an individual making a request to know or delete personal information is the person about whom we have collected information.

We may use a third-party verification service to verify the identity of a consumer making a request to know or delete personal information.

We will decline a request to know or delete personal information if we cannot reasonably verify that you are the person (or a person authorized to act for the person) whose personal information is the subject of a request.

Response Timing and Format

We will confirm receipt of a request a request to know or delete personal information within 10 days and provide information about how we will process the request, our verification process, and when you should expect a response.

If we cannot respond to a request within 45 days, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Our response will explain the reasons we cannot comply with a request, if applicable.

We will not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Authorized Agent

A California resident may authorize another person or a business entity registered with the California Secretary of State to act on their behalf to submit a request to know or delete personal information subject to the requirements set forth in Section 999.326 of the California Civil Code.

Accessibility

We are committed to making our Privacy Policy accessible to all our customers and employees. If you are not able to access any content in this Privacy Policy from our website due to a disability, please contact privacy@atriawealth.com to get the Privacy Policy in another format.

Contact Information

If you have any questions, concerns, or comments about this Privacy Policy and our privacy practices, please do not hesitate to contact us at:

833.995.1944
privacy@atriawealth.com or
cgmarketing@cadaretgrant.com