This Privacy Policy explains how RIA Central LLC (“RIA Central”) collects Personal Information (as defined below) on the RIA Central Platform, and how RIA Central uses and discloses that Personal Information. “Personal Information” means information that allows a person to directly identify an individual, such as name, address, phone number and email address. This Privacy Policy is incorporated into and is subject to the RIA Central Terms of Service. Any capitalized terms not defined herein have the meaning set forth in the RIA Central Terms of Service. By using the RIA Central Platform, you expressly consent to the information handling practices described in this Privacy Policy.
1. The RIA Central Platform
RIA Central provides a software platform found at www.riacentral.com (the “RIA Central Platform”) that enables registered users who hold securities licenses or professional financial designations (“Members”) to join and participate in the social networks built on the RIA Central Platform. In its operation of the RIA Central Platform, RIA Central collects and uses all information, including Personal Information, that you disclose in your use of the RIA Central Platform. When you sign up to become a Member, you are providing Personal Information to RIA Central.
As part of the resources on the RIA Central Platform, Members may also attend webcasts provided by, or submit requests to receive information directly from, third party providers (“Content Providers”). Such Content Providers may also collect additional types of Personal Information, or they may receive such Personal Information from RIA Central, and they may use and disclose Personal Information in accordance with their respective privacy policies.
2. Collection of Personal Information
You must register for a RIA Central ID to become a Member. When you register for a RIA Central ID, you are required to provide certain Personal Information, including your name, email address, date of birth, and a password that you select. You must also create a RIA Central Profile and provide other Personal Information within your RIA Central Profile, such as your gender, city, state, and country, a photo, and additional information interests and any organizations you belong to. You can change the privacy level of your RIA Central Profile to modify your default disclosure settings, including the option to not display your RIA Central Profile to anyone. Please note, however, that even if you choose not to display your RIA Central Profile, that information, including Personal Information, will be accessible by RIA Central.
In order to become a Member, you must respond to additional questionnaires that are required to better ensure that only appropriate investment advisors are permitted to join RIA Central. Your responses may also constitute additional Personal Information.
You will have other opportunities to voluntarily provide Personal Information to RIA Central and/or Content Providers. For example, if you contact RIA Central or a Content Provider to provide feedback, participate in webcasts or other events, participate in marketing initiatives, submit a request for product information or request support we and/or our Content Providers collect your email address and other Personal Information that you provide.
3. Passive Data Collection
Like most web-based services, RIA Central automatically receives and records information on our server logs from your browser when you use the RIA Central Platform. RIA Central may use a variety of methods, including clear GIFs (also known as “web beacons”), and “cookies,” to collect this information. The information that RIA Central collects with these automated methods may include, for example, your IP address, RIA Central cookie information, a unique device or user ID, browser type, system type, the content and pages that you access on the RIA Central Platform, and the “referring URL” (i.e., the page from which you navigated to the RIA Central Platform).
We also use cookies on the RIA Central Platform to recognize your RIA Central ID, and to store references to your RIA Central ID and session validators on your hard drive. We also include clear GIFs in some of our email messages in order to learn whether the messages are delivered and opened.
Websites visited before visiting RIA Central may place Personal Information within the URL of your browser during a visit to that previous website. RIA Central may collect that information as part of referring URL information that it collects.
Also, please be aware that third parties, including Content Providers, advertisers, and the hosting/software service provider for the RIA Central Platform may set cookies or use other means of passively collecting information about your use of their services. We do not always have access to, or control over, these cookies or other means of passive data collection. You should consult the respective privacy policies of these third parties and Content Providers. This Privacy Policy does not apply to, and we cannot control the activities of, such other third parties and Content Providers.
4. Content and Use of RIA Central
When you send messages, make postings, or otherwise post or transmit anything on the RIA Central Platform (“Submissions”), others who visit or use the RIA Central Platform may access any Personal Information within such Submissions. Within your Member settings, accessible at the “Settings” link, you may be able to modify your privacy settings for certain types of Submissions that you make available on RIA Central. For example, you may be able to specify that your photos, videos, and blog posts will be viewable by anyone, by your “friends” only, or only by you. Please note, however, that while the general public or other Members can not view Content that you specify as viewable only by you, RIA Central can view this information. We may collect and maintain posts, messages, and other Submissions that you have posted or transmitted to RIA Central, as well as information about those Submissions and your interaction with it.
Some of this information, such as your latest activity on the RIA Central Platform, and the most active members of RIA Central may be made available to other Members and visitors to the RIA Central Platform as well as to Content Providers. Because you may voluntarily disclose Personal Information when you post or otherwise transmit Submissions, please be careful with the information that you choose to disclose.
5. Third Party Advertisers
RIA Central may allow other companies to advertise on the RIA Central Platform and/or to solicit you directly. These third party advertisers may use technology to send, directly to your browser, the advertisements that appear within the RIA Central Platform and they automatically receive your IP Address and other log file information when this happens. Such third party advertisers may also use other technologies (such as cookies, javascript, or web beacons) to measure the effectiveness of their advertisements and to personalize their advertising content. Certain third party advertisers may also use these cookies to serve ads to you based on your visit to specific locations on the RIA Central Platform and other sites on the Internet.
RIA Central may provide your Personal Information to these third party advertisers, and by using the RIA Central Platform you are providing your consent to do so. You should consult the respective privacy policies of these third party advertisers. This Privacy Policy does not apply to, and we cannot control the activities of, such other advertisers or web sites. RIA Central reserves the right to add or remove third party advertisers in its discretion.
6. Information Received From Third Party Sources
We may also obtain information, including Personal Information, from third party sources. This includes certain Personal Information that may be provided to us by Content Providers or other third party advertisers. If we directly combine information from other third parties with Personal Information that we collect on the RIA Central Platform, we will treat the combined information as “Personal Information” and handle it in accordance with this Privacy Policy.
7. How RIA Central Uses Personal Information
We may use Personal Information to operate, provide, improve, and maintain the RIA Central Platform and our other services and systems, and to develop new products and services; to provide you with offers from third parties; to prevent abusive and fraudulent use of the RIA Central Platform and our other services and systems; to personalize and display advertisements and other content on the RIA Central Platform; to send you administrative messages, and information about the RIA Central Platform, content, and services in which we believe you may be interested; and for other administrative and internal business purposes.
We use passively-collected information to administer, operate, and improve the RIA Central Platform and our other services and systems, and to provide services and content that are tailored to you, including providing customized information, advertisements and monitoring and reporting of the effectiveness of marketing campaigns. If we directly combine any information gathered through passive means with Personal Information, we treat the combined information as Personal Information under this Privacy Policy. Otherwise, we use information collected by passive means in aggregated or other non-personally identifiable forms.
8. When RIA Central Discloses Personal Information
RIA Central does not share Personal Information with third parties except in the limited circumstances described in this Privacy Policy. Please be aware, however, that any information that you voluntarily choose to display on any publicly available portion of the RIA Central Platform becomes publicly available to other Members and may be collected and used by RIA Central or others without restriction. In addition to the circumstances described elsewhere in this Privacy Policy, RIA Central may share your Personal Information in the following circumstances:
- RIA Central Service and Content Providers. RIA Central uses third parties to perform some services necessary to operate the RIA Central Platform, such as payment processing, maintenance, security, data analysis, data hosting and operating the software that runs the RIA Central Platform. RIA Central may provide Personal Information to third parties for their use in performing such functions, or such third parties may have access to your Personal Information in the course of performing services for RIA Central.
- RIA Central Affiliates. RIA central is under common control with Fugent, Inc. Although RIA Central currently does not have any subsidiaries, joint venture partners, or other companies that it controls or is under common control with (collectively, “affiliates”), it may in the future. RIA Central may share some or all of your Personal Information with its affiliates, in which case we will require those affiliates to abide by the terms and conditions of this Privacy Policy.
- Legal Requirements. RIA Central may disclose Personal Information if we have a good-faith belief that doing so is required by a subpoena or other judicial or administrative order or otherwise required by law. Additionally, RIA Central may disclose Personal Information where we, in good faith, deem it appropriate or necessary to prevent violation of the RIA Central Terms of Service, or our other agreements; take precautions against liability; protect the rights, property, or safety of RIA Central, any Member or other individual, or the general public; maintain and protect the security and integrity of our services or infrastructure; protect ourselves and our services from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third party claims or allegations; assist in enforcement of payment obligations; or assist government enforcement agencies.
9. Change of Ownership
In the event of a change in ownership of RIA Central, or a merger with, acquisition by, or sale of assets to, another entity, we reserve the right to transfer all of your Personal Information to that entity or new owner. RIA Central will use reasonable efforts to notify Members of such a transfer (by a posting on the RIA Central Platform and/or by email to a Member’s email address that was provided to us, as chosen by us in our discretion).
10. Security
We endeavor to use industry standard security measures to protect against the loss, misuse, and alteration of Personal Information under our control. Although we make good faith efforts to maintain the security of such Personal Information, we cannot guarantee that it will remain free from unauthorized access, use, disclosure, or alteration. Further, while we work to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent “hackers” or other unauthorized persons from illegally accessing or obtaining this information. We do not assume any liability to third parties whose information you post or transmit in any Submissions. To help maintain the security of your RIA Central ID, please keep your password secure.
If we learn of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the RIA Central Platform or providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the RIA Central Platform. If a security systems breach occurs, RIA Central may post a notice on the RIA Central Platform and/or may send an email to you at the email address you have provided to us.
11. Your Choices
You may, at any time, update, correct, or delete certain categories of Personal Information that you have provided to RIA Central by logging in to the RIA Central Platform and updating your Personal Information. You may also, at any time, elect to deactivate your membership with RIA Central by clicking “leave RIA Central” on your Settings page. Additionally, you may terminate your Member account and end your use of the RIA Central Platform at any time and for no reason by contacting us at info@RIACentral.com or at the address set forth below in the “Contacting RIA Central” Section.
Additionally, even if you update or remove Personal Information that you have provided to RIA Central, your Personal Information may be retained in our backup files and archives for a reasonable period of time for legal purposes. Also, deleting your Personal Information or deactivating your membership with RIA Central will have no effect on any third parties who have already been provided with your Personal Information. Please contact such third parties directly regarding their handling of your Personal Information.
12. Third Party Services or Sites
The RIA Central Platform may contain links to websites and services provided by third parties. Any Personal Information you provide on third party sites or services is provided directly to that third party and is subject to that third party’s policies governing privacy and security. We are not responsible for the content or privacy and security practices and policies of third party sites or services to which links are displayed on the RIA Central Platform . We encourage you to learn about the applicable third parties’ privacy and security policies before providing them with Personal Information.
13. International Users
The RIA Central Platform is hosted in the United States. If you use or access the RIA Central Platform from another country, or any other region with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal data to the United States. The United States does not have the same data protection laws as the European Union and other countries. By providing Personal Information under this Privacy Policy, you consent to the use of Personal Information in accordance with this Privacy Policy and the transfer of your Personal Information to and within the United States.
14. Changes and Updates to This Privacy Policy
We may occasionally update and change this Privacy Policy. If we do, we will notify you about material changes by providing a notice on the RIA Central Platform and/or sending a notice to your email address. We encourage you to periodically review this Privacy Policy to stay informed about our collection, use, and disclosure of Personal Information on the RIA Central Platform. Your continued membership in or other use of the RIA Central Platform constitutes your agreement to this Privacy Policy and any changes.
15. Contacting RIA Central
If you have questions about this Privacy Policy, you may contact us at info@riacentral.com .
You may also write to us at:
RIA Central LLC
5131 Post Road, Suite 310
Dublin, Ohio 43017
Attn: Privacy Matters