Privacy Policy

Privacy

The privacy of individuals who visit the Four Points Advisors website is important to us. Personal information submitted electronically to Four Points Advisors is treated in the same manner as information submitted via a mail service or during an office visit. We do not compile personal information or other information for sale to third parties.

Four Points Advisors does collect and retain statistical and technical data about visits to our site, such as the date and time of the visit, the length of the visit, and the pages visited. We use this information to improve the content of our web services and to help us understand how visitors use our services. This information may be shared with an outside consultant to improve the quality of our site and prevent pay-per-click fraud.

Four Points Advisors retains the right to monitor network traffic to identify any unauthorized attempts to cause damage to or manipulate current information on our web site.

Our web site is hosted on the Wix.com  Cookies are simple text files stored by your web browser and are used to enhance our functionality and your browsing experience. None of the information collected identifies you personally, but instead stores a randomly generated identifying tag on your computer. Cookies are commonly used to increase an application’s functionality and stores information such as: a list of forms you wish to download, search strings, your browsing preferences, etc. Many cookies are only stored temporarily. You have the ability to refuse a cookie or delete the cookie file from your computer using many widely available methods. Please see www.aboutcookies.org for more information. If you refuse or delete a cookie, you may experience some inconvenience in your use of our website. 

Security

There are security issues raised when submitting personal or confidential information over an Internet connection. The decision to do so is at your discretion.

We attempt to provide our users with a safe Internet browsing experience. However, there may be times when such security measures are beyond our control. You are directly responsible for correct use, maintenance and security of your computer, network system, software applications and/or electronic files. Four Points Advisors is not liable for any damages to or loss of your computer, network system, software applications or electronic files due to inadequate security features, user error and/or failure to comply with recommended operating procedures and maintenance; nor is Four Points Advisors liable for any damages or loss due to Internet connection and/or service failures, problems, or damages caused by applications owned and maintained by a separate corporation or entity.

Outside Links

Four Points Advisors may use links to other web sites in an effort to assist users in locating information on topics that might be of interest to them. We cannot attest to the continued accuracy of information provided by linked sites. Linking to a web site does not constitute an endorsement by Four Points Advisors of any of its employees of the sponsors of the site or the products presented on the site. Technical problems with outside links, other than a link that has been moved or changed, should be reported to the entity that maintains the site.

Consent

Use of our website is denoted as your implicit consent of all provisions of this policy. For questions regarding this policy, please contact Four Points Advisors.

 

 

Our Commitment to Privacy

 

The relationship between Four Points Advisors and our clients is our most important asset. We strive to maintain your trust and confidence in our firm, an essential aspect of which is our commitment to protect the confidentiality, integrity and security of your non-public personal information. As we believe that all of our clients value their privacy, we do not disclose your non-public personal information to anyone unless it is required by law, at your direction, or is necessary to provide you with our services. We do not sell your non-public personal information to anyone.

Personal Information That We Collect, Maintain, and Communicate

 

We collect and maintain your non-public personal information, so we can provide investment management and/or tax preparation services to you. The types and categories of information we collect and maintain about you include:

·      Information we receive from you to open an account or provide investment or tax services to you (such as your date of birth, social security number, address, telephone number, and financial information);

·     Information about your transactions with us, our affiliates, or others to service your account (such as trade tickets and account statements);

·     Information that we receive from third parties with respect to your account (such as trade confirmations from brokerage firms).

·     Information provided to us by authorized parties acting on behalf of our clients such as accountants, attorneys, and investment consultants.

 

In order for us to provide investment management and tax services to you, we may disclose the non-public personal information that we collect and maintain in very limited instances, which includes:

·      Disclosures that are authorized or requested by you;

·      Disclosures that are required by law (for example, to cooperate with regulators or law enforcement authorities);

·      Disclosures to companies that perform services on our behalf (such as data processors that provide investment accounting and reporting services, or otherwise assist us in delivering services to our clients) subject to agreements that prohibit such companies from disclosing or using the information other than for the services required or as permitted by law;

·      Disclosures to companies as otherwise permitted by law, including those necessary to service your account (such as providing account information to brokers or custodians).

 

How We Protect Your Personal Information 

 

To fulfill our privacy commitment, we have instituted firm-wide practices to safeguard the information that we maintain about you. These include:

·      Maintaining physical, electronic and procedural safeguards that comply with federal regulations to guard your non-public personal information;

·     Limiting access to non-public personal information to employees and third parties that are necessary or appropriate to provide services to you;

·     Requiring third parties that perform services to us to agree by contract to keep your information strictly confidential;

·     Protecting information of our former clients to the same extent as our current clients.

Four Points Capital Partners may transfer your personal information abroad if required for the permitted purposes as described above. We will ensure that any such international transfers out of the European Economic Are (EEA) are made subject to appropriate or suitable safeguards as required by the General Data Protection Regulation (EU) 2016/679 (“GDPR”) or other relevant laws.

 

Updating your Personal information


If any of the personal information that you have provided to us changes, for example if you change your email address or if you wish to cancel any request you have made of us, please let us know by contacting us.

 

How long do we retain your Personal information for?


We retain your personal information in an identifiable form in accordance with our internal policies which establish general standards and procedures regarding the retention, handling and disposition of your personal information. Your personal information is retained for as long as necessary to meet legal, regulatory and business requirements. Retention periods may be extended if we are required to preserve your personal information in connection with litigation, investigations and proceedings.

 

Your Rights and Choices


If you are an EEA Individual you have a number of legal rights under GDPR in relation to the personal information that we hold about you. These rights include:

 

·      Obtaining information regarding the processing of your personal information and access to the personal information that we hold about you. Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information. In particular, information that is subject to legal professional privilege;

·     Requesting that we correct your personal information if it is inaccurate or incomplete;

·     Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it;

·     Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request;

·     Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.

Contact

We have designated a Data Protection Officer (“DPO”) to enhance and promote compliance with and understanding of privacy and data protection principles. If you wish to do any of the above please send an email to privacyoptout@4pointsadvisors.com 

 

We may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorized disclosure 

Last Updated: July 2018