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
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
relationship and is also extended to each of our former
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
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
- 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
- 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
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
- respond to communications from you or as you authorize or
- 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 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
We provide access to information about you to outside companies
and other third parties in certain limited circumstances,
- 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
How to Limit the Sharing of Information About
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
- 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.
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
Safeguarding Your Information, Maintaining Your
We take precautions to ensure the information we collect about you
is protected and is accessed only by authorized individuals or
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
- 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
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
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
firstname.lastname@example.org or call us at
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