AgentRisk Privacy Policy

Introduction

Jon V, Inc. d/b/a AgentRisk (“we”, “us” and/or “our”) is a SEC registered investment advisor. AgentRisk operates an automated investment service (“Service”). Our Service is made available through our website and via application(s) that reside on mobile devices. This Privacy Policy describes how AgentRisk treats your Personal Data 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

AgentRisk’s servers automatically record certain information (“Non-Identifiable” or “Aggregated Data”) about your use or evaluation of our Service. 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.

Types of Data collected

The types of information we collect depend on whether you are a User or Client. We collect Personal Data from you when you voluntarily provide information to us, or, in case of Usage Data, we collect data automatically when you use AgentRisk. Additionally, we may collect data from you when you use our broker/custodian Interactive Brokers.

Examples of instances when we collect Personal Data include when you answer questions on our website to determine what kind of portfolio we might recommend if you were to become a Client, when you register to open an account, when you contact our client service organization with questions or when you become a Client. Wherever AgentRisk collects Personal Data, we make an effort to link to this Privacy Policy and other relevant terms, such as our Terms of Use.

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies, Usage Data, various types of Data, email address, first name, last name, middle name, gender, date of birth, username, password, company name, profession, country, state, province, ZIP/Postal code, Social Security number (SSN), city, workplace, field of activity, id or passport picture. Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy.

Information Collection from Users

We collect personal information such as name, address, telephone number and other optional information you may provide, such as your age, investable assets, and risk tolerance, which may include your financial goals and objectives, income information and other financial planning information about your household.

We may collect your email address and/or telephone number should you opt to engage via our website, email or dedicated telephone number with our client service team.

We also collect account numbers and login credentials for the accounts (bank or brokerage) you choose to link to our Service, any challenge and/or security questions associated with those accounts and any information contained in those accounts.

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.

Information Collection from Clients

If you choose to become a Client, in addition to the information we collect from you as a User, as described above, we will ask you for certain information, including, but not limited to, your full legal name, contact information, birth date, ID, citizenship, investment objectives, approximate net worth, and other regulatory disclosures that may be necessary and required under European law (see our Client Agreement).

In the event you already have an account with Interactive Brokers , which you want us to manage, we will receive the above information from Interactive Brokers.

Personal Data collected for the following purposes and using the following services:

Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.

Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)
Hotjar is an analytics service provided by Hotjar Ltd.
Hotjar honors generic Do Not Track headers. This means your browser can tell its script not to collect any of your data. This is a setting that is available in all major browsers.
Personal Data collected: Cookies and Usage Data.
Place of processing: Malta – Privacy Policy – Opt Out.

Hosting and backend infrastructure

This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Google Cloud services (Google, Inc.)
Google cloud is a hosting and backend service provided by Google Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Klaviyo (Klaviyo Inc.)
Klaviyo is an email address management and message sending service provided by Klaviyo Inc.
Personal Data collected: email address, email address, first name, last name, middle name
Place of processing: United States – Privacy Policy.

HubSpot (HubSpot Inc.)
HubSpot is a CRM and email service.
Personal Data collected: email address, first name, last name, middle name, customers’ personal and financial info that have been collected at the onboarding process.
Place of processing: United States – Privacy Policy.

Olark (Habla, Inc)
Olark is a customer communication and support tool
Personal Data collected: email address, first name, last name, middle name.
Place of processing: United States – Privacy Policy.

Registration and authentication

By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.

Direct registration (AgentRisk)
The User registers by filling out the registration form and providing the Personal Data directly to AgentRisk.
Personal Data collected: city, company name, country, date of birth, email address, field of activity, first name, last name, middle name, gender, password, profession, province, Social Security number (SSN), state, username, workplace and ZIP/Postal code, marital status, financial status.
Place of processing: United States.

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 personalised experience

To engage in marketing activities - Based on your communication preferences, we may use your Personal Data 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 Personal Data with any third parties except as 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 Personal Data 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 here.

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.

We may your information with third party identity verification services in order to prevent fraud. This allows us to confirm your identity by comparing the information you provide us to public records and other third party databases. These service providers may create derivative data based on your personal information that can be used solely in connection with provision of identity verification and fraud prevention services.

Except as required by law or requested by regulatory authorities, AgentRisk agrees to maintain your non public Personal Data 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 Personal Data 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. 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.

Data Processing

We process data using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to us, in some cases it might be necessary that, the Data is accessible to certain types of persons in charge, involved with the operation AgentRisk (administration, legal, system administration). You may request the updated list of these parties at any time.

Retention time

Personal Data shall be processed and stored for a period of 5 years retention due to legal purposes. Once the retention period expires, Personal Data shall be deleted.

Place

The Data is processed at our cloud services and in any other places where the parties involved in the processing are located.

Advertising

We do not allow third party advertising on our Website or Mobile applications.

Social Media and Links to Other Web Sites and Apps: “Third Parties”

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

Minors

AgentRisk is not to be used by anyone under the age of 18 and as such does not knowingly collect Personal Data from anyone under the age of 18. If you are under the age of 18, please do not submit any Personal Data 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 and the Services.