AgentRisk Overlay Privacy Policy

Policy Effective Date: January 15th, 2020

Introduction

Jon V, Inc. d/b/a AgentRisk (“we”, “us” and/or “our”) is a SEC regulated investment advisor that operates an automated investment service ​managed by Artificial Intelligence (A.I) (the “Service”). Our Service is made available through a website and via application(s) that reside on mobile devices. This Privacy Policy describes how AgentRisk treats your information when you use or evaluate our service.

For the purpose of this agreement a User is an individual who uses our website to evaluate our service, or for educational purposes and a Client is an individual who signs our Client Agreement that entitles the Client to have her or his investment portfolio managed by AgentRisk. Our Privacy Policy, Terms of Use and where applicable Client Agreement collectively govern your use or evaluation of our service.

Information Collection

In General

We collect information from you when you voluntarily provide information to us, or, in case of Usage Data (which we explain about below), we collect data automatically when you use AgentRisk.

Examples of instances when we collect information include when you contact our client service organization with questions or when you become a Client. Wherever AgentRisk collects information, we make an effort to link to this Privacy Policy and other relevant terms, such as our Terms of Use.

Information collection from clients and users

We collect personal information such as name and email address. ​We may collect your telephone number should you opt to engage via our website with our client service team.

We may also collect personal information from you offline, such as when you attend one of our events, or when you contact customer support. We may use this information in combination with other information we collect about you as set forth in this Policy.

Usage data

AgentRisk’s servers automatically record certain information (“Non-Identifiable” or “Aggregated Data”) about your use or evaluation of our Service. We call this “Usage Data”. Similar to other technology platforms and services, AgentRisk records information such as browsing activity, data displayed or clicked on (such as UI elements, ads, and links), and other information (such as browser type, date and time of access, cookie ID, and referrer URL). Along with cookies, AgentRisk may also use third-party tracking technology, such as Google Analytics, to record similar information regarding you and your activity on the Site.

Use of Information

AgentRisk’s number one priority is your trust. Protecting your privacy is essential to earning and keeping that trust. This tenet drives all of the decisions we make, as well as how we gather, use and store any information we acquire from you.

In general, we use personal information to create and improve our Services, our content, to provide client support and for loss prevention and anti-fraud purposes. We may use this information for the purposes below (which also form our legal bases) as described:

To provide customer service - We process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems.

To provide Service communications - We send administrative or account-related information to you to keep you updated, inform you of relevant tax issues, security issues or updates, or provide other transaction-related information.

To enhance your website experience - We process your personal information to provide you with a personalized experience.

To engage in marketing activities - Based on your communication preferences, we may use your information to send you targeted marketing communications regarding our Service or to tell you about blog posts or services that we believe will be of interest to you. If you decide at any time that you no longer wish to receive marketing communications from us, please follow the “unsubscribe” instructions provided in the communications. Please note that you cannot opt out of administrative communications such as regulatory, billing or service notifications.

To maintain legal and regulatory compliance - Our Services are subject to laws and regulations requiring us to collect and use your personal identification information, formal identification information, financial information, employment information, online identifiers, and/or usage data. For example, we must identify and verify customers using our Services in order to comply with anti-money laundering and terrorist financing laws across jurisdictions. In addition, we may use third parties to verify your identity by comparing the personal information you provided against third-party databases and public records.

You may choose not to provide such information to us, but if you choose not to provide such information, you will not be able to become a Client.

Information Sharing and Onward Transfer

We will never sell, rent, or trade your information with any third parties.

We may share your information if we are required by law, such as when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, front running or scalping, situations involving potential threats to the physical safety of any person, or violations of our Terms of Use.

There are certain circumstances, outlined below, in which we may share your information without further disclosure to you. You may request a detailed analysis of which data we may share with third parties by sending us an email at ​support@agentrisk.com.

We may share the information required to become a Client with Interactive Brokers, our brokerage partner solely for the purpose of allowing our brokerage partner to provide services to you. You can review their Privacy Policy h​ere​.

We may share your information with service providers under contract who help with parts of our business operations such as marketing, and technology services. In the case we hire another company to perform a function of this kind, we only provide them with the minimum information they need to perform their specific function.

Except as required by law or requested by regulatory authorities, AgentRisk agrees to maintain your non public information in strict confidence.

Your rights

You can object to our use of your personal information for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your personal information (and require them to be deleted).

If you close your Account, we will mark your account in our database as "Closed," but will keep your account information in our database for a period of 5 years. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personal information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.

Other Important Information

Security

AgentRisk takes reasonable steps to protect your information from loss, misuse, and unauthorized access, alteration, disclosure, or destruction. No Internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error free so, please take special care in deciding what information you send to us in this manner. You play a vital role in protecting your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.

Data Storage

AgentRisk will try to limit the storage of your personal information to the extent that storage is necessary to serve the purpose(s) for which the personal information was processed, to resolve disputes, enforce our agreements, and as required or permitted by law. Once the retention period expires, information shall be deleted.

We may store and process all or part of your personal and transactional information in the United States and elsewhere in the world where our facilities or our service providers are located.

This Privacy Policy and these terms apply only to AgentRisk Overlay operated services and applications. The policies described herein do not apply to Third Party websites or applications.

Minors

AgentRisk Overlay is not to be used by anyone under the age of 18 and as such does not knowingly collect information from anyone under the age of 18. If you are under the age of 18, please do not submit any information to AgentRisk. If a parent or guardian becomes aware that his or her child under the age of 18 has provided us with personally identifiable information without his or her consent, he or she should contact us at ​support@agentrisk.com.

Changes

We reserve the right to modify this Privacy Policy at any time, and when required by law, we will notify you of changes to this Privacy Policy. Each version of this Privacy Policy will be identified at the top of the page by its effective date.

This document constitutes the complete Privacy Policy for AgentRisk Overlay.

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