COMMITMENT TO PRIVACY
Ignite considers client privacy to be fundamental to our relationship with our clients. Since Ignite was founded, we have been committed to maintaining the confidentiality, integrity, and security of clients’ non-public personal information entrusted to us. Internal guidelines have been developed to protect this confidentiality, while allowing client needs to be served. The guidelines address how Ignite handles non-public personal information within Ignite’s administrative, technical, and physical systems. Ignite employees are required to follow procedures with respect to maintaining the confidentiality of our clients’ non-public personal information. To guard clients’ non-public personal information, Ignite has imposed physical, electronic, and procedural safeguards that we believe are reasonably designed to comply with federal standards to guard clients’ non-public personal information. A client’s right to privacy extends to all forms of contact with Ignite, including telephone, written correspondence, and electronic media, such as the internet.
THE INFORMATION WE COLLECT
While providing products and services, Ignite may collect non-public personal information about clients. Ignite may collect this information from sources such as tax information, personal financial statement and brokerage accounts, or other forms or communications with us. In addition to non-public personal information that you provide directly to Ignite, we may receive such non-public personal information from third parties (such as financial advisors, accountants, or attorneys). The non-public personal information Ignite receives may include:
Ignite may obtain non-public personal information from third parties to verify your identity, to prevent fraud, or to help Ignite identify products and services that may benefit you.
The information Ignite collects and stores during normal Site usage includes your internet address, the name and version of your internet browser, the website that referred you to Ignite, the pages you request, and the date and time of those requests. Ignite may collect non-public personal information on this Site (including any information captured using “cookies” or other technologies). Ignite may also collect data from third-party analytic tools. Ignite uses this information to generate statistics and measure Site activity to improve the usefulness of customer visits.
There are instances where Ignite may require personally identifying information such as name and address to provide the Site visitor a service (registration to our password-protected website). The information you provide is used by Ignite and our affiliates to understand who our service users are, and to contact you regarding our and our affiliates’ services, subject to applicable law. Ignite generally does not, except for information with respect to employees, obtain information from a consumer reporting agency or information that is derived from a consumer report that identifies an individual. If Ignite obtains a consumer report on an individual client or potential client, Ignite will take reasonable steps to erase and/or destroy such information that identifies an individual, subject to applicable recordkeeping or other legal or regulatory requirements.
SHARING OF INFORMATION
Ignite does not sell client information – whether it is your non-public personal information or the fact that you are an Ignite client – to anyone.
Sharing Information with Affiliates. Ignite shares non-public personal information with our affiliates with the goal of better serving client accounts and may share such information with affiliates to make clients aware of other investments Ignite offers, to the extent permitted by law.
Sharing Information with Third Parties. Client non-public personal information is disclosed to third parties only in the limited circumstances permitted by law. For example, Ignite may share your non-public personal information to complete transactions that you request or authorize. In the normal course of serving clients, non-public personal information Ignite collects may be shared with companies that perform various services for Ignite, such as a broker-dealer that would conduct securities transactions. The organizations that receive client information receive information that Ignite believes is necessary or advisable to carry out the organizations’ assigned responsibilities, and they are authorized to use that information for the services required. In addition, such organizations are not permitted to share or use this information for their marketing and sales purposes.
In addition, Ignite may disclose or report non-public personal information in limited circumstances where we believe in good faith that disclosure is required or permitted by law (for example, to cooperate with regulators or law enforcement authorities, such as responding to a subpoena, regulatory information request, or other legal process, or to protect accounts from fraud), or to resolve client disputes. Ignite may also share your non-public personal information with third parties pursuant to your request, authorization, or consent.
THE INTERNET AND THIRD-PARTY SITES
As this Site is linked to the internet, and the internet is inherently insecure, Ignite cannot provide any assurance regarding the security of transmission of information you communicate to Ignite online. Ignite also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to Ignite online is transmitted at your own risk.
NOTICES AND FUTURE CHANGES
Ignite may revise our policy or this summary in the future and will promptly post the new policy on this Site.
If you believe that your privacy has been compromised or your non-public personal information that Ignite stores is in error, please contact us using the contact information below and provide details of the incident so that we can investigate it.
Ignite requests that complaints about potential breaches of privacy be made in writing, so we can be sure about the details of the complaint. After Ignite has completed our enquiries, we will contact you, usually in writing, to advise the outcome, unless prohibited by law or a law enforcement agency request otherwise. If we receive a response from you, we will assess it and advise if we have changed our view.