Privacy Policy

Smartcomm, L.L.C.'s  Privacy Policy - A Commitment to Your Privacy
(Effective January 2, 2008)

At Smartcomm, L.L.C ("Smartcomm") our most important asset is our relationship with you. We are honored that you have entrusted us with your financial affairs and we are committed to safeguarding the privacy of information we maintain about you. Establishing and adhering to an effective privacy policy is an important part of that dedication.

Below, you will find details about Smartcomm's commitment to protecting your privacy, including the types of information we collect about you, how we use and share that information, and how you can instruct us to limit certain types of information sharing.

Our privacy policy applies to all clients with whom we have a relationship and is also extended to each of our former clients.

Your Privacy Is Not for Sale
Simply put, we do not and will not sell your personal information to anyone, for any reason, at any time.

How We Collect Information About You

We collect personal information about you in a number of ways.

  • Application and registration information.
    We collect information from you when you subscribe to an investment offering or enroll in one of our services. You will also be asked for information when you choose to participate in a Smartcomm promotion. We may also collect information from consumer reporting agencies to verify your identity in the application process. The information we collect may include your name, address, phone number, email address, Social Security number and date of birth, as well as details about your interests, investments and investment experience.

  • Transaction and experience information.
    Once you have initiated an application or request with us, we collect and maintain personal information about your account activity, including your transactions, balances, positions and history. This information allows us to administer your account and provide the services you have requested.

  • Third-party information providers.
    We may collect information about you from information services and consumer reporting agencies to verify your identity, employment or creditworthiness, or to better understand your financial needs.

  • Website usage.
    When you visit our website, our computer may use devices known as "cookies," graphic interchange format files (GIFs), or other similar Web tools to enhance your Web experience. These tools enable us to recognize you when you return to our site, maintain your Web session while you browse, as well as help us provide you with a better, more personalized experience at Smartcomm.

How We Share Information About You With Our Clients
Many clients of Smartcomm may do business with more than one affiliate, creating an efficient, comprehensive financial relationship to meet individual needs. When appropriate, Smartcomm may share information we collect about you with our affiliates:

  • help provide you with better service or perform services on our behalf;
  • respond to communications from you or as you authorize or request;
  • make it more convenient for you to open a new account;
  • allow an affiliate to provide you with information about its products and services that we believe may benefit or interest you.

You may instruct us not to share information about you with our affiliates for certain purposes, as explained under "How to Limit the Sharing of Information About You."

How We Share Information About You Outside of the Smartcomm Company
We provide access to information about you to outside companies and other third parties in certain limited circumstances, including:

  • to help us process transactions for your account;
  • when we use another company to provide services for us, such as printing and mailing your account statements;
  • when we believe that disclosure is required or permitted under law. For example, we may be required to disclose personal information to cooperate with regulatory or law enforcement authorities, to resolve consumer disputes, to perform credit/authentication checks, or for risk control;
  • when we enter into a joint marketing agreement with another financial institution in order to provide you with a Smartcomm-branded (or other Smartcomm affiliate-branded) financial product or service. We only make such agreements with companies that we believe can help us provide a financial product or service that will benefit you.

You may instruct us not to share information about you with outside companies for joint marketing purposes, as explained under "How to Limit the Sharing of Information About You."

How to Limit the Sharing of Information About You
If you prefer, you may choose to limit the information we share about you with our affiliates and outside companies. Specifically, you may instruct us:

  • not to share with our affiliates consumer reports and other personal information about you that may be used to determine your eligibility for credit (for example, information about your income, profession or employment status);
  • not to allow our affiliates to market their financial products or services to you based on information they receive from us about your eligibility for credit or your transactions and experiences with us;
  • not to share personal information about you with an outside company for joint marketing purposes.
  • You may exercise this choice by writing to Smartcomm, LLC, Attn: Investor Relations Dept., 3131 E. Camelback Rd., Suite 450, Phoenix, AZ 85016.  Your choice will be applied to you as an individual and will automatically be extended to all of your accounts with us, as well as to any accounts you may have with any of our affiliates.
  • Joint account holders may instruct us on behalf of another account holder.
  • You may make your privacy choice at any time, and it will remain in effect until you change it.

If you choose to limit these types of information sharing, we may continue to share information with our affiliates that identifies you (such as your name and Social Security number), as well as information about your transactions and experiences with us. In addition, our affiliates may continue to use information they receive from us to perform services on our behalf, to respond to communications from you, as you authorize or request, or, if you are their customer, to offer you products or services. We may also continue to share information about you with outside companies as permitted or required by law.

State Laws
We will comply with state laws that apply to the disclosure or use of information about you. For example, if your address is in Vermont, we will automatically limit information sharing as described in "How to Limit the Sharing of Information About You" without your having to advise us of this privacy choice.

The following notice is required to be made under Arizona law to all customers with an Arizona mailing address. At any time, you may request to be placed on our internal "do not call" list. You may do so by calling Smartcomm at 602.224.1080. Customers from any state may request to be placed on Smartcomm's internal "do not call" list by calling 602.224.1080. If you would like further information about this notice, you may contact us at Smartcomm, LLC3131 E. Camelback Rd., Suite 450, Phoenix, AZ 85016; or call 602.224.1080 or  Email us at contact@smartcommllc.com.

Safeguarding Your Information, Maintaining Your Trust
We take precautions to ensure the information we collect about you is protected and is accessed only by authorized individuals or organizations.

Companies we use to provide support services are not allowed to use information about our clients for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of information to the performance of the specific services we have requested.

We restrict access to personal information by our employees and agents. Our employees are trained about privacy and are required to safeguard personal information.

We maintain physical, electronic and procedural safeguards to protect personal information.

Teaming Up Against Identity Theft
Identity theft is a serious concern to all of us. Safeguarding information to help protect you from identity theft is our priority. Smartcomm takes steps to protect you from identity theft by:

  • utilizing client identification and authentication procedures before initiating transactions;
  • creating a secure transmission connection to our Smartcomm website. You will never be asked to enter your Social Security Number or Federal ID number on a website location.
  • ensuring our employees are trained to safeguard personal information about you.

You can also help protect your identity and accounts. Here are a few steps to remember:

  • Smartcomm will never request your account number, login password, or Social Security number in either a non-secure or unsolicited email communication;
  • shred documents that contain personal information;
  • check your credit report regularly for unauthorized activity and protect your personal identification numbers (PINs) or personal data.

Greater Accuracy Means Better Protection
We are committed to keeping accurate, up-to-date records to help ensure the integrity of the information we maintain about you. If you identify an inaccuracy in this information, or if you need to make a change to it, please contact us promptly by calling 602.224.1080.

A Commitment to Keeping You Informed
We will provide you with advance notice of important changes to our information-sharing practices.

Contact Us with Questions
If you have any questions or concerns, please contact us by email at contact@smartcommllc.com or call us at 602-224-1080.

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