SyFi, LLC (“SyFi”) is committed to the protection of your privacy. We understand keeping your information secure and confidential is critical to earning and keeping your trust.
We never rent, sell or trade your Personal Information (as defined below).
“Personal Information” is your personally identifiable information such as your name, email or mailing address, phone number, account information, account numbers and any other identifier that we gather from our web sites, mobile applications, or through communications with representatives of SyFi that can be used to identify you personally.
The types of information we collect depend on which of our services you choose to use. The following are the types of Personal Information we collect at various stages of our relationship with you.
This section of the Privacy & Security Statement is relevant to you if and when you are a Visitor.
When you visit our Site, we may place a cookie on your computer so that our system can recognize you when you make a return visit. That cookie tells us your IP address and the type of browser you are using. For information about how we use this information, please refer to the section about cookies.
For eSyFi℠ Members:
For SyFi Customers:
For All SyFi Website Users:
We may share your Personal Information to conduct everyday business or to comply with the laws, regulations and rules by which we are governed. We may share your Personal Information, and the Personal Information of those you refer to us, with the service partners we retain as our third-party service program providers. Our agreements with those third-party service providers prohibit them from using your Personal Information for any other purpose or from sharing that information with other third-parties. We may use the email address and other Personal Information that you provide to us to send you surveys as part of our marketing activities. Responding to those survey solicitations is completely voluntary. We may share the email address and other Personal Information that you provide to us with third parties with whom we contract to conduct the surveys just mentioned above on our behalf. Our agreements with those third-party contractors prohibit them from using your email address or other Personal Information for any other purpose or from sharing that information with other third-parties. We collect and utilize the kinds of non-Personal Information mentioned above to optimize, secure and simplify your experience with us. Besides in connection with the third-party service providers who help us collect, interpret and manage this non-Personal Information, this non-Personal Information is not disclosed or shared outside of SyFi.
Browser or Device:
Certain information is collected by most browsers or applications, such as your “user agent string”, to help us determine your computing device type, operating system version and Internet browser type and version. We use this information to ensure that our web sites function properly and for security purposes.
SyFi deploys Pixel Tags used to track your access to web site pages email messages. We use pixel tags to measure the effectiveness of our communications, the success of our marketing campaigns, compile statistics about usage and response rates, and to assist us in resolving User questions about the use of our services.
Your IP Address is a number assigned to the device that you are using by your Internet Service Provider. An IP Address is identified and logged whenever you visit our web sites or applications, along with the page(s) that were visited. We use IP Addresses, individually and collectively, for purposes such as identifying potential visitors, calculating usage levels, helping diagnose technical problems and supporting our web sites and applications. Additionally, we use your IP Address to assist in fraud detection and authentication to better protect your security.
Email Marketing Opt-out:
When we communicate our own marketing offers to you, these communications are CAN-SPAM compliant, including the ability for you to opt-out of marketing communications.
Deletion/Retention of Personal Information:
Unless you request otherwise, we will retain the Personal Information we collect from you indefinitely.
SyFi, as a registered investment advisor, must comply with certain legal and regulatory requirements pertaining to record retention. We will respond to any requests we receive asking that we delete Personal Information that we possess from those who use our services. However, we will not delete information that we are required to retain in order to comply with applicable laws and regulations.
How to Request Deletion of the Personal Information We Collect:
SyFi’s Statement Regarding “Do Not Track” Signals:
Most browsers can be set to send signals to third-party websites requesting them not to track the User’s activities. At this time, SyFi does not respond to “do not track” signals. Consequently, SyFi, its third-party service providers such as Google Analytics, and other third-party websites and online services may indeed track and collect Personal Information about your online activities over time while navigating to, from and on our Site and our mobile app and across those third-party websites and online services, notwithstanding any “do not track” signals we may receive.
Contacting us by Telephone or online-conference technology:
If you communicate with us by telephone or online-conference technology, we may monitor or record the call or online-conference. This is done for reasons such as maintaining the integrity of our services, providing effective and timely service, and the improvement of SyFi’s operations.
Personal Information may be disclosed or transferred as part of, or during negotiations of, a merger, consolidation, sale of our assets, as well as equity financing, acquisition, strategic alliance or in any other situation where Personal Information may be transferred as one of the business assets of SyFi.
eSyFi℠ is powered using technologies and practices that many banks and other financial institutions use to protect customer information, such as SSL encryption for data in transit and AES encryption for sensitive data at rest. We do not store your financial institution credentials in our systems or in our applications. eSyFi℠ account aggregation is provided by an industry-leading third-party account aggregation service that employs comprehensive financial data security standards and is subject to ongoing regulatory examinations.
No Money Movement. While using eSyFi℠, you can only view financial account balances and transactions. You cannot transfer money between accounts, authorize spending or move money, safeguarding you from unauthorized money transfers from your financial accounts.
eSyFi℠ allows you to monitor all your transactions for accounts linked to your Account, providing you with a comprehensive view of all account activities.
Protecting your personal information:
SyFi takes the privacy and security of your personal information seriously. We maintain administrative, technical and physical safeguards designed to protect your information’s security, confidentiality and integrity.
SyFi does not maintain or have access to your eSyFi℠ login password. If you believe your password has been compromised, please either please notify us immediately to have your password reset.
Remember – all information you submit to us by email is not secure, so please do not send sensitive information in any email to SyFi. We never request that you submit sensitive or personal information over email, so please report any such requests to us by sending an email to email@example.com.
There are many steps you can take to help us keep your information safe. First and foremost, choose complex, independent passwords for each service you maintain an account with. This helps keep any breach of any of your accounts isolated to one service. Also, don’t use a password that is easily guessable.
SyFi urges your caution when using a public computers or networks, like at a coffee shop or library. To best protect your personal information and login information, don’t use such computers to access your sensitive accounts, and if you must do, ensure that you logout of your account entirely.
In recent years, individuals, businesses and even governments have seen a rise in “phishing” attacks. Phishing occurs when someone attempts to obtain your password or other sensitive information. Scammers often do this by impersonating a trusted service provider, or offering a compelling reason to open a malicious email attachment, click on a link or give over information. We never ask for your sensitive personal information, such as password, over email or other unsecure methods. Please notify us at firstname.lastname@example.org if you ever receive suspicious correspondence.
Requirement of Visitors, Members, Customers and Users to be United States of America Residents:
The Site provided by SyFi is not directed to individuals residing outside of the United States of America. Nothing in this Site should be interpreted as a solicitation for investment advice, insurance, other financial services, or any other service in which SyFi is registered to offer, in any state or jurisdiction other than states and jurisdictions SyFi is lawfully registered to offer such services.
Protecting Children’s Privacy Online:
The Site provided by SyFi is not directed to individuals under the age of thirteen (13), and those children should not provide Personal Information through our web sites or applications. We do not knowingly collect information from children under 13 without parental consent. For more information about the Children’s Online Privacy Protection Act (COPPA), visit the Federal Trade Commission website.
Please contact us as set forth below.
11145 SW Novare Pl.
Portland, OR 97223
By E-Mail: email@example.com using the subject line “Feedback”
Last Updated: July 1, 2018
1. Our Commitment to Privacy
- The security precautions we have implemented to protect information we collect;
- The types of personal information we collect and how we use it;
- How we disclose the information we collect;
- How to correct and/or change the information we collect;
- Use of de-identified and aggregated data;
- Use of “cookies”;
- Links to third party web sites; and
2. Security Precautions
3. Personal Information Collected
We collect personally identifiable information about you via your use of eSyFi. We may collect extensive information from you concerning you, your family and your finances. The data collected includes, but is not limited to, name, address, phone number and information required to calculate a net worth statement. This data may be entered by you and/or SyFi and stored in eSyFi and used by you and/or SyFi to generate financial, retirement and estate plans.
4. Use and Disclosure of Your Personal Information
We use collected information for many purposes, including, but not limited to, providing you eSyFi, offering products and/or services available for sale to you, administering and improving eSyFi, verification processing, diagnosing problems and finding opportunities with our systems, developing new ideas and services, and communicating with you. We do not disclose or share the information that we collect from you or that is otherwise entered into eSyFi concerning you except: (1) all information stored in eSyFi concerning you is accessible to SyFi, and if applicable, your Alliance Partners (as more particularly described in the eSyFi Terms of Service); (2) to vendors (such as hosting providers and the vendor of the account aggregation service) as necessary to provide services; and (3) as necessary to comply with legally required disclosures such as disclosures made in response to a subpoena. When your data is disclosed to vendors, it is done under an obligation of confidentiality if disclosure is necessary to provide services to you. You should refer to the privacy policies of SyFi and affiliated institutions concerning their use and disclosure of your information.
5. Changing Your Information
With respect to account aggregation information, just log into eSyFi and make whatever changes and deletions you desire to the accounts you have established. All other information may only be changeable or removed through SyFi. Please contact SyFi if you want to change or remove information concerning you that is stored in eSyFi.
6. Aggregated Data
We may, from time to time, collect data from Members to prepare analyses, reports and other materials regarding (i) how Members use eSyFi, (ii) the types and volume of assets managed within the Applications, and (iii) other matters which may be useful to SyFi, including for marketing purposes. This data may be aggregated with other Member’s data for such purposes.
A cookie is a piece of data stored on a Member’s hard drive containing information about the Member. eSyFi uses session cookies containing encrypted or encoded information. Session cookies allow eSyFi to process your online requests. Session cookies also help eSyFi to validate who you are after you have logged into the Applications. Session cookies exist during an online session. Session cookies become invalid when you completely close your browser software for the session in which they were created if the browser is configured to do so.
8. Do Not Track
Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (DNT) mechanisms, we do not respond to any browser-based DNT signals.
9. Other Web Sites
eSyFi may contain links to third party web sites and include embedded videos that are hosted by such third parties. We are not responsible for the privacy practices or the content of these other web sites. These third parties may use web measurement and customization technologies (such as cookies) in conjunction with the provision of this content or functionality. If you use a link to another web site or view an embedded video, you should consult the privacy notice for the site you visit. We have no control over the information that is submitted to, or collected by, other web sites and we are not responsible for the content of any linked site or any link contained in a linked site, or any changes or updates to such sites, or any embedded video. This privacy statement applies solely to information collected by us or otherwise stored in eSyFi.
We process and store information on behalf of our Members. If you would like to opt out of getting communications from SyFi please contact us at firstname.lastname@example.org or follow the unsubscribe instructions included in each marketing email. Requests to opt-out of transfers to our third-party vendors will also be considered, but limitations on data sharing may make it difficult or impossible to provide eSyFi in this manner.
Under California Civil Code sections 1798.83 and 1798.84, California residents are entitled to ask us for a notice describing what categories of personally identifiable information we share with third parties or affiliates for their own direct marketing purposes during the previous calendar year. eSyFi does not share personally identifiable information with unrelated third parties for their own direct marketing purposes. If you would like a copy of this notice, please refer to the “Contact Us” section at the end of this Policy for appropriate contact information. In your request, please specify that you want a “California Privacy Rights Notice”.
12. Business Transactions
13. Contact Us
Notice of Privacy Practices
SYFI, LLC (“SYFI”, “we”, “us”), a registered investment advisory firm, is committed to safeguarding the confidential information of its customers. We collect nonpublic personal information in order to open and administer your accounts with us and to provide you with prudent advice. In compliance with Securities and Exchange Commission Privacy Regulations for Investment Advisors, we are required to provide customers with this privacy notice. In accordance with that regulation, the material below describes how we collect, use, and safeguard the information that is provided to us.
SYFI may collect nonpublic personal information about you (including, but not limited to, your name, date of birth, contact information, social security number, financial details) from the following sources:
Agreements, Applications, Contracts, and other Forms
Information about your transactions with others or us
Questionnaires, Discussions, Conversations etc.
Email correspondence and communications
Tax Returns & Estate Planning Documents
Information collected may vary depending on the services provided.
SYFI may disclose personal information about our customers as necessary to conduct business where disclosure is permitted or required by law, and uses your personal information in the following manner:
We do not sell your personal information to anyone.
We limit employee access to information only to those employees who have a business reason for such access, and only to information necessary to conduct their professional duties.
We limit non-affiliated third-party access to information only to information that may be required to perform services on our behalf as permitted by law, including but not limited to financial service companies, consultants, auditors, custodians, brokerage firms, insurance firms, or so that our firm may discuss your financial situation with your accountant or attorney. We also require strict confidentiality in our agreements with them and expect them to keep this information private. Federal and state regulators also may review firm records as permitted under law.
SYFI maintains information policies in accordance with applicable rules and regulations:
We will provide notice of changes in our information sharing practices. If it is necessary to disclose your personal information in a way that is inconsistent with this policy, we will give you advanced notice of the proposed change so you will have the opportunity to opt out of such disclosure.
We maintain physical, electronic, and procedural safeguards to guard your information and not placed it unreasonable risk.
Personally identifiable information about you will be maintained during the time you are a customer, and for the required time thereafter that such records are required to be maintained by federal and state securities laws. After this required period of record retention, all such information will be destroyed.