Policy Effective Date: January 25th, 2019
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
describes how AgentRisk treats your Personal Data when you use or evaluate our service.
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.
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
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.
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.
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.
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
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.
Olark (Habla, Inc)
Olark is a customer communication and support tool
Personal Data collected: email address, first name, last name, middle name.
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
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 email@example.com.
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.
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).
Other Important Information
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.
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.
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.
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.
The Data is processed at our cloud services and in any other places where the parties involved in the processing are located.
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”
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 firstname.lastname@example.org.
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