Portfolio Pathway, LLC ("Portfolio Pathway", "we" or "us") is committed
to protecting your privacy. We understand your concerns with regard to how
information about you is used and disclosed, and we appreciate your trust
describes what information we collect about you, how we collect it, how we
use it, with whom we may share it, and what choices you have regarding it.
of our Web site (http://www.portfoliopathway.com, or any replacement site,
the "Site"). We encourage you to become familiar with the terms and conditions
and you accept and consent to the privacy practices (and any uses and disclosures
Changes to this Policy
From time to time, we may change our privacy
or services, in relevant and applicable legal or regulatory requirements,
or in our attempts to better serve the needs of our customers. In the event
of any changes to our privacy practices, notice will be given in the
posted on the Site.
What Information Do We Collect?
Certain aspects of the Site may allow you to voluntarily submit information
to us (for example, in opening, setting up, or maintaining an account on
the Site) or to request information from us. The information that you submit
or provide in such a case may include personal or individually identifiable
information, such as, for example, names, addresses, telephone numbers, and
other contact information, as well as, if you are a subscriber or registered
user of the Site, the account numbers and passwords with financial institutions
from which you want us to collect information. You should be mindful of the
information that you choose to provide to us, and you should make sure that
any information that you do provide is complete, truthful, and accurate.
We may also collect certain identifying information from or about you in
connection with your use of the Site. For example, we may retain the content
of, and metadata regarding, any correspondence you may have with us or our
representatives, regardless of the subject matter or the mode of communication
by which such correspondence is made. This information helps us to improve
our capabilities and services, as well as the Site and the content, materials,
and opportunities that we feature or describe on the Site, and to more effectively
and efficiently respond to both current and future inquiries.
As with many other Web sites, the Web servers used to operate the Site
may automatically collect certain data pertaining to you and the equipment
and communications method that you use to access the Internet and the Site.
Without combining these data with other sources of information, they do not
readily or personally identify you. They may reveal such things as the Internet
protocol ("IP") address assigned to your computer, specific pages that you
accessed on the Site or immediately prior to visiting the Site, and the length
of time spent in a visit to the Site. The purposes for which this information
is collected and used include facilitating Site operation and system administration,
generating aggregated statistical information that is not personally identifiable,
monitoring and analyzing Site traffic and usage patterns, and improving content
and content delivery with regard to the Site and the materials, opportunities,
and services that we describe or make available on the Site.
We may also use "cookies" (small text files stored on your computer) to
help track and customize your access to and use of the Site. Cookies store
and retain information that helps us recognize you when you return to the
Site following a previous visit. Most popular Internet browser packages allow
you to configure the browser so as not to accept cookies. However, setting
your browser to reject cookies may, in certain instances, prevent you from
taking full advantage of the Site and the materials, products, and services
that we make available on the Site.
How Do We Use The Information That We Collect?
We may use, disclose, and keep on file any information that you submit
or provide to us (or that you cause to be submitted or provided to us) through
or in connection with the Site, as necessary and appropriate for the purposes
for which it was submitted. For example, if you request information or materials
from us about our services, we may use the information that you provide to
contact you and to deliver the requested materials to you. If you provide
us with account numbers and passwords for accounts with financial institutions,
we will store and use that information for the purpose of providing our services
to you. However, we will not use, disclose, sell, lease, or license personally
or individually identifiable information about any individual for other purposes,
With regard to other information collected by or on the Site, in addition
to the uses mentioned or described above or otherwise described in our Terms
of Use, we may use the information that we collect to analyze and improve
the content, features, materials, and opportunities that we make available
on the Site, to notify you of changes made to the Site or of new opportunities
made available on or through the Site, to evaluate your needs and customize
the Site content delivered to you according to those needs, to send you promotional
materials that you request from us, and for other legitimate and lawful business
purposes. If you contact us for support or assistance in connection with
using the Site, we may use information about you or your system for purposes
such as verifying whether your system meets the minimum requirements needed
to use the Site and any capabilities or functionality that we make available
on the Site. In addition, we may use information that we collect or obtain
about you to, from time to time, send you announcements, newsletters, and
notices about our services.
With Whom Do We Share Information That We Collect?
We may, in the
course of conducting our business, and in addition to any other uses
share certain personal or individually-identifiable information that we collect
or that you submit to us, whether solicited or unsolicited, to the trusted
business partners and service providers that we utilize in operating, maintaining,
and further developing the Site and in delivering the content, materials,
opportunities, and services that we make available on or through the
Site or otherwise as part of our business. We share such information only
to the extent necessary and appropriate for the purposes for which the information
was collected or submitted (such as, for example, as necessary for purposes
of communicating with you or fulfilling your requests for services, materials,
or information), and we require our business partners and service providers
to be subject to legally binding obligations of confidentiality.
We may also produce reports on Site traffic or usage patterns and share
these reports with our business partners and others, but the information
contained in these reports is anonymous and does not allow identification
of any specific individual or entity. Similarly, we may from time to time
share with third parties other aggregated information and data that do not
identify any particular individual or entity. Please be assured, however,
information that we obtain through the Site will not be shared with third
parties in a manner that identifies or is attributable to any particular
We may disclose information (including personal and individually identifiable
information) about you or your use of the Site if we become subject to a
subpoena or court order or if we are otherwise legally required to disclose
such information. We may also use and disclose information about you or your
use of the Site to establish, exercise, or protect our legal rights, to enforce
such disclosure is necessary to investigate, prevent, or take other action
regarding actual or suspected illegal or fraudulent activities or potential
threats to the physical safety or well-being of any person.
As Portfolio Pathway continues to grow and develop its business, it is
possible that our organizational structure might change or that we might
merge or otherwise combine with, or that Portfolio Pathway or portions of
its business might be acquired by, another company. In any such transactions,
customer information generally is, will most probably be, and should be expected
to be one of the transferred business assets.
What Choices Do You Have?
When corresponding with Portfolio Pathway
or our representatives, using the Site as a subscriber or registered
user, making a request for information, or otherwise interacting with Portfolio
Pathway through the Site, you choose what information to supply, what
questions to pose and comments to make, whether you wish to receive further
information, and by what method of communication that information should
be delivered to you. Please take care to share only such information as is
needed or that you believe is appropriate, and please make sure that any
information you submit or provide to us is complete, truthful, and accurate.
Subscribers and registered users of the Site may also use the functionality
of the Site to update, maintain, and remove personal or individually identifiable
information regarding themselves or their respective accounts. If you wish
to become a subscriber or registered user of the Site and our services, please
contact us about entering into a subscriber agreement with us.
You must be at least 18 years old to use our services and the Site. If
you are not 18, please do not continue to use the Site and please do
not contact us about a subscriber agreement, except through your parent or
How Do We Protect Information Collected About You?
Portfolio Pathway uses
commercially reasonable measures to secure and protect information transmitted
through, or stored on, the Site. However, we cannot and do not guarantee
that any such transmissions or information will be totally secure. Unencrypted
Internet communications are not secure, and no security measures are
impenetrable. You agree to immediately notify us of any breach of Site
If you are a subscriber or registered user of the Site,
or if you are accessing the Site on behalf of a subscriber or registered
user, your access to and use of the Site for the purposes of accessing
or using our services are subject to and governed solely by the terms
of the separate agreement that you have (or that your organization has) entered
into with Portfolio Pathway, the terms of which prevail over this Privacy
Policy for such purposes.
For your convenience, some hyperlinks may be posted on the
Site that link to other Web sites not under our control. We are not responsible
of those sites or of any companies that we do not own or control. We
you visit. In addition, if you submit information to or through, or otherwise
initiate a transaction on, a Web site that our Site links to, even if
you reached that site through our Site, the information that you submit becomes
subject to the privacy practices of the operator of that linked site.
You should read that site’s privacy policies to understand how personal information
that is collected on that site is used and protected.
Who Can You Contact
For More Information?
If you have any questions or suggestions about Portfolio
Pathway, the Site, or our products, services, or privacy practices, please
contact us at the numbers or addresses given below.
Portfolio Pathway, LLC
Attn: Dave Miller
200 E 5th Avenue
Naperville, IL 60563
BY ACCESSING OR USING THE SITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND,
AND CONSENT TO THE PRIVACY PRACTICES, AND TO THE USES AND DISCLOSURES OF