Your privacy is important to us. It is Wright Associates’ policy to respect your privacy and comply with any applicable law and regulations regarding any personal information we may collect about you, including across our website, https://kswrightassociates.com, and other sites we own and operate.
Pursuant to applicable federal and/or state privacy regulations, Wright Associates is a financial institution that has determined to keep confidential nonpublic personal information about each client.
Nonpublic personal information is defined to mean personally identifiable financial information that is provided by a consumer to a financial institution, results from any transaction with the consumer or any service performed for the consumer, or is otherwise obtained by the financial institution.
Personally identifiable financial information means any information: (1) a consumer provides to a financial institution to obtain a financial product or service; (2) about a consumer resulting from any transaction involving a financial product or service between a financial institution and a consumer; or (3) a financial institution otherwise obtains about a consumer in connection with providing a financial product or service to that consumer.
Wright Associates Privacy Notice
Wright Associates maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ Nonpublic Personal Information (“NPI”). Through this policy and its underlying procedures, Wright Associates attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.
It is the policy of Wright Associates to restrict access to and/or the sharing of all current and former clients’ information (i.e., information and records pertaining to personal background [including social security number and address], investment objectives, financial situation, financial planning issues, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in furtherance of the client’s engagement of Wright Associates.
Wright Associates shall disclose, as necessary, the client’s information: (1) to unaffiliated service providers and vendors in furtherance of establishing, maintaining, and reporting on the client’s Wright Associates relationship (i.e., broker-dealer, account custodian, record keeper, technology, performance reporting, customer relationship management software [CRM], proxy voting, insurance, independent managers, sub-advisers, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with applicable federal and/or state privacy regulations.
However, Wright Associates does not, and shall not, disclose or share information with any affiliated or nonaffiliated persons, entities or service providers for marketing or any other purposes or reasons not referenced above.
Should you have any questions regarding the above, please contact our Chief Compliance Officer.
Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use a website or online service.
This policy is effective as of 24 March 2022.
Last updated: 20 April 2022
Information We Collect
Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information.
“Voluntarily provided” information refers to any information you knowingly and actively provide us when using or participating in any of our services and promotions.
“Automatically collected” information refers to any information automatically sent by your devices in the course of accessing our products and services.
When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.
Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.
Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.
We may ask for personal information — when you contact us — which may include one or more of the following:
Legitimate Reasons for Processing Your Personal Information
We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our services to you.
Collection and Use of Information
We may collect personal information from you when you do any of the following on our website:
• Use a mobile device or web browser to access our content;
• Contact us via email, social media, or on any similar technologies;
• When you mention us on social media.
We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, our marketing and market research activities may uncover data and insights, which we may combine with information about how visitors use our site to improve our site and your experience on it.
Security of Your Personal Information
When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.
We follow all applicable laws and regulations related to data privacy and security to protect the personal information you provide to us. However, no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.
You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services, for example, ensuring you do not make your personal information publicly available via our platform.
How Long We Keep Your Personal Information
Kathleen S. Wright Associates, Inc.’s policy is to maintain required firm and client records and files in an appropriate office of Kathleen S. Wright Associates, Inc. for the first two years and in a readily accessible facility and location for an additional three years for a total of not less than five years from the end of the applicable fiscal year. Certain records for the firm’s performance, advertising and corporate existence are kept for longer periods.
However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.
We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13.
Your Rights and Controlling Your Personal Information
Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.
Access: You may request details of the personal information that we hold about you.
Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example providing user support), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.
Notification of data breaches: We will comply with applicable laws and regulations in respect to disclosure of any data breach.
Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified.
In the event of Wright Associates’ acquisition or dissolution, we would include data, including your personal information, among the assets transferred to any parties who acquire us, in accordance with the terms of your Investment Advisory Agreement. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.
Limits of Our Policy
Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites and cannot accept responsibility or liability for their respective privacy practices.
Changes to This Policy
If required by law, we will obtain your consent or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.
For any questions or concerns regarding your privacy, you may contact us using the following details: