PRIVACY POLICY

Stapleton Advisors, Inc. (hereinafter “Stapleton Advisors”) cares about your privacy. For this reason, we collect and use personal information only as needed to deliver our products, services, websites and mobile applications, and to communicate with you about the same, or as you have requested (collectively, our “Services”).

For all non-securities-based products and services on this website only, your personal information includes data such as:

— Name

— Address

— Telephone number

— Date of birth

— Email address

— Billing and payment information

— Candidate information (for job applicants)

— Other data collected that could directly or indirectly identify you.

Our Privacy Policy not only explains how and why we use your personal information that we collect, but also how you can access, update or otherwise take control of your personal information. We’ve also created a Privacy Center that offers answers to your most common questions, quick links to access your Account Settings, instructions on how to exercise certain rights that might be available to you, and definitions to key terms and concepts noted in this Privacy Policy. If at any time you have questions about our practices or any of your rights described below, you may reach our Data Protection Officer (“DPO”) and our dedicated team that supports this office by contacting us at support @ stapletonadvisors.com.

This inbox is actively monitored and managed so that we can deliver an experience that you can confidently trust. What information we collect, how we collect it, and why Much of what you likely consider personal information is collected directly from you when you:

1. create an account or purchase any of our products or services (ex: billing information, including name, address, credit card number, government identification);

2. request assistance from our customer support team (ex: phone number);

3. complete contact forms or request newsletters or other information from us (ex: email); or

4. participate in contests and surveys, apply for a job, or otherwise participate in activities we promote that might require information about you.

However, we also collect additional information when delivering our products and/or services to you to ensure necessary performance. These methods of collection may not be as obvious to you, so we thought we’d highlight and explain a bit more about what these might be (as they vary from time to time):

Cookies and similar technologies on our websites and our mobile applications (if any) allow us to track your browsing behavior, links clicked, items purchased, your device type, and to collect various data, including analytics, about how you use and interact with our services. These technologies automatically collect data when you use and interact with our services, including metadata, log files, cookie/device IDs, page load time, server response time, and approximate location information to measure website performance and improve our systems, including optimizing DNS resolution, network routing and server configurations.

Specifically, interactions with the features, content and links (including those of third-parties, such as social media plugins) contained within the services, Internet Protocol (IP) address, browser type and settings, the date and time the services were used, information about browser configuration and plugins, language preferences and cookie data, information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and error data is collected. All this allows us to provide you with more relevant product offerings, a better experience on our sites and mobile applications, and to collect, analyze and improve the performance of our Services. We may also collect your location (IP address) so that we can personalize our services.

For additional information, and to learn how to manage the technologies we utilize, please visit our Cookie Policy. If you wish to opt out, contact us. 

Supplemented Data may be received about you from other sources, including publicly available databases or third parties from whom we have purchased data, in which case we may combine this data with information we already have about you so that we can update, expand and analyze the accuracy of our records, assess the qualifications of a candidate for employment, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

HIPAA Waiver

If you post any personal health information on our website you are waiving your privacy rights normally covered under HIPAA laws. If you post your personal information that information may be distributed throughout our website, and to third parties, such as Google, Bing and others. All posts on our website are considered covered under the Communications Decency Act (CDA).

How We Utilize Information

We strongly believe in both minimizing the data we collect and limiting its use and purpose to only that (1) for which we have been given permission, (2) as necessary to deliver the services you purchase or interact with, or (3) as we might be required or permitted for legal compliance or other lawful purposes:

Delivering, improving, updating and enhancing our products and services.

We collect various information relating to your purchase, use and/or interactions with our services. We utilize this information to:

— Improve and optimize the operation and performance of our Services (again, including our websites and mobile applications)

— Diagnose problems with and identify any security and compliance risks, errors, or needed enhancements to the services

— Detect and prevent fraud and abuse of our services and systems

— Collecting aggregate statistics about use of the services

— Understand and analyze how you use our services and what products and services are most relevant to you.

— Much of the data collected is aggregated or statistical data about how individuals use our services and is not linked to any personal information.

Sharing With Trusted Third Parties

We do not share personal information with third parties.

Communicating With You

We may contact you directly or through a third-party service provider regarding products or services you have signed up or purchased from us, such as necessary to deliver transactional or service-related communications. We may also contact you with offers for additional services we think you’ll find valuable if you give us consent or were allowed based upon legitimate interests. You don’t need to provide consent as a condition to purchase our goods or services. These contacts may include:

— Email

— Text (SMS) messages

— Telephone calls

— Messenger applications 

— Automated phone calls or text messages.

You may also update your subscription preferences with respect to receiving communications from us and/or our partners by signing into your account and visiting “Account Settings” page. If we collect information from you in connection with a co-branded offer, it will be clear at the point of collection who is collecting the information and whose privacy policy applies. In addition, it will describe any choice options you have in regards to the use and/or sharing of your personal information with a co-branded partner, as well as how to exercise those options.

We are not responsible for the privacy practices or the content of third-party sites. Please read the privacy policy of any website you visit. If you believe that anyone has provided us with your personal information, without your approval, and you would like to request that it be removed from our database, please contact us at support @ stapletonadvisors.com.

Transfer Of Personal Information Abroad

If you utilize our Services from a country other than the country where our servers are located, your personal information may be transferred across international borders, which will only be done when necessary for the performance of our services, when we have your consent to do so, or when the appropriate standard contractual clauses are in place. Also, when you call us, we may provide you with support from one of our global locations outside your country of origin.

Compliance With Legal, Regulatory and Law Enforcement Requests

We cooperate with government and law enforcement officials to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (such as subpoena requests), to protect our property and rights or the property and rights of a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be illegal or unethical. 

To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process. 

How You Can Access, Update Or Delete Your Data

To easily access, view, update, delete or port your personal information, or to update your subscription preferences, please sign into your Account and visit “Account Settings.” Please visit our Privacy Center for additional information and guidance for accessing, updating or deleting data. If you make a request to delete your personal information and that data is necessary for the products or services you have purchased, the request will be honored only to the extent it is no longer necessary for any Services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements. If you are unable for any reason to access your Account Settings or our Privacy Center, you may also contact us by one of the methods described in the “Contact Us” section below.

‘Do Not Track’ Notifications

Some browsers allow you to automatically notify websites you visit not to track you using a “Do Not Track” signal. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com.

Age Restrictions

Our Services are available for purchase only for those over the age of 18. Our Services are not targeted to, intended to be consumed by or designed to entice individuals under the age of 18. If you know of or have reason to believe anyone under the age of 18 has provided us with any personal information, please contact us.

Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. 

Changes To This Policy

We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy and any other places we deem appropriate, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make material changes to this Privacy Policy, we will notify you here, by email, or by means of a notice on our home page, at least thirty (30) days prior to the implementation of the changes.

Data Protection Authority

Although we have blocked traffic to our servers from the European Economic Area (EEA), if you somehow have been able to access our website, and believe we maintain your personal information subject to the General Data Protection Regulation (GDPR), you may send direct questions or complaints to our Office of the Data Protection Officer at the address listed below.

Contact Us

If you have any privacy-related questions, concerns or complaints about our Privacy Policy, our practices or our Services, you may contact our Office of the DPO by email at support @ stapletonadvisors.com. In the alternative, you may contact us by writing us at:

— Stapleton Advisors, Inc., 401 E. Jackson St., Ste 2340, Tampa, FL 33602.

We will respond to all requests, inquiries or concerns within thirty (30) days.