All of us at Arlington Capital Management share your concerns about privacy. The confidentiality of your personal financial information is of paramount importance to us, and we will continue to remain vigilant in protecting your privacy. We are sending you this privacy notice to help you understand how we use your private financial information, and to let you know what we do to help protect your privacy.
What Information Do We Collect From You and About You?
To serve our client needs, Arlington Capital Management collects information from you and about you. Some of this information is collected to satisfy certain legal and regulatory requirements. However, the majority of information that we collect from you is gathered so that we can service your account(s) effectively. Examples of the information that we collect includes:
• Information from your account application and other forms, such as name, address, Social Security number, telephone number, employment information, income, net worth, investment experience, and other information to service your account effectively. We may also collect information from consumer reporting agencies.
• Information provided by you when you visit us in person, over the telephone, through the mail or via e-mail.
• Information about your financial transactions, including securities purchased and sold, fund transfers, account balances, and other account activities.
To Whom Do We Disclose Your Information?
Arlington Capital Management does not sell your personal financial information to anyone.
However, we do disclose your personal information to third parties or outside companies that help us process your transactions or service your account. One such company is the broker/dealer which processes your transactions and acts as the account custodian. Other companies to whom we may disclose your personal information include outside investment advisors or asset managers, variable annuity or insurance companies, mutual fund companies, account custodians, or the like. We may also provide information to outside service providers that print and mail your account statements. Any outside company or third party provider must limit their use of your information to the purpose for which it was provided.
Arlington Capital Management may also provide your personal information when permitted or required by law or regulation. Examples include providing information in response to a subpoena or court order, to cooperate with regulators, governmental authorities or law enforcement authorities, or in response to a request from a consumer reporting agency.
Outside of these circumstances, we will not provide your personal information to third parties unless you have specifically requested that we do so.
What Do We Do To Protect Your Personal Information?
If you would like to receive a copy of our ADV form please contact Arlington Capital Management, Inc. 847-670-4030
Arlington Capital Management is committed to protecting your privacy and developing technology
that gives you the most powerful and safe online experience. This Statement of Privacy
applies to the Arlington Capital Management Web site and governs data collection and usage.
By using the Arlington Capital Management website, you consent to the data practices described
in this statement.
Collection of your Personal Information
Arlington Capital Management collects personally identifiable information, such as your e-mail
address, name, home or work address or telephone number. Arlington Capital Management also
collects anonymous demographic information, which is not unique to you, such as
your ZIP code, age, gender, preferences, interests and favorites.
There is also information about your computer hardware and software that is automatically
collected by Arlington Capital Management. This information can include: your IP address,
browser type, domain names, access times and referring Web site addresses. This
information is used by Arlington Capital Management for the operation of the service, to
maintain quality of the service, and to provide general statistics regarding use
of the Arlington Capital Management Web site.
Please keep in mind that if you directly disclose personally identifiable information
or personally sensitive data through Arlington Capital Management public message boards,
this information may be collected and used by others. Note: Arlington Capital Management
does not read any of your private online communications.
Arlington Capital Management encourages you to review the privacy statements of Web sites
you choose to link to from Arlington Capital Management so that you can understand how those
Web sites collect, use and share your information. Arlington Capital Management is not responsible
for the privacy statements or other content on Web sites outside of the Arlington Capital Management
and Arlington Capital Management family of Web sites.
Use of your Personal Information
Arlington Capital Management collects and uses your personal information to operate the Arlington Capital Management
Web site and deliver the services you have requested. Arlington Capital Management also uses
your personally identifiable information to inform you of other products or services
available from Arlington Capital Management and its affiliates. Arlington Capital Management may also
contact you via surveys to conduct research about your opinion of current services
or of potential new services that may be offered.
Arlington Capital Management does not sell, rent or lease its customer lists to third parties.
Arlington Capital Management may, from time to time, contact you on behalf of external business
partners about a particular offering that may be of interest to you. In those cases,
your unique personally identifiable information (e-mail, name, address, telephone
number) is not transferred to the third party. In addition, Arlington Capital Management
may share data with trusted partners to help us perform statistical analysis, send
you email or postal mail, provide customer support, or arrange for deliveries. All
such third parties are prohibited from using your personal information except to
provide these services to Arlington Capital Management, and they are required to maintain
the confidentiality of your information.
Arlington Capital Management does not use or disclose sensitive personal information, such
as race, religion, or political affiliations, without your explicit consent.
Arlington Capital Management keeps track of the Web sites and pages our customers visit within
Arlington Capital Management, in order to determine what Arlington Capital Management services are
the most popular. This data is used to deliver customized content and advertising
within Arlington Capital Management to customers whose behavior indicates that they are interested
in a particular subject area.
Arlington Capital Management Web sites will disclose your personal information, without notice,
only if required to do so by law or in the good faith belief that such action is
necessary to: (a) conform to the edicts of the law or comply with legal process
served on Arlington Capital Management or the site; (b) protect and defend the rights or
property of Arlington Capital Management; and, (c) act under exigent circumstances to protect
the personal safety of users of Arlington Capital Management, or the public.
The Arlington Capital Management Web site use "cookies" to help you personalize your online
experience. A cookie is a text file that is placed on your hard disk by a Web page
server. Cookies cannot be used to run programs or deliver viruses to your computer.
Cookies are uniquely assigned to you, and can only be read by a web server in the
domain that issued the cookie to you.
One of the primary purposes of cookies is to provide a convenience feature to save
you time. The purpose of a cookie is to tell the Web server that you have returned
to a specific page. For example, if you personalize Arlington Capital Management pages, or
register with Arlington Capital Management site or services, a cookie helps Arlington Capital Management
to recall your specific information on subsequent visits. This simplifies the process
of recording your personal information, such as billing addresses, shipping addresses,
and so on. When you return to the same Arlington Capital Management Web site, the information
you previously provided can be retrieved, so you can easily use the Arlington Capital Management
features that you customized.
You have the ability to accept or decline cookies. Most Web browsers automatically
accept cookies, but you can usually modify your browser setting to decline cookies
if you prefer. If you choose to decline cookies, you may not be able to fully experience
the interactive features of the Arlington Capital Management services or Web sites you visit.
Security of your Personal Information
Arlington Capital Management secures your personal information from unauthorized access,
use or disclosure. Arlington Capital Management secures the personally identifiable information
you provide on computer servers in a controlled, secure environment, protected from
unauthorized access, use or disclosure. When personal information (such as a credit
card number) is transmitted to other Web sites, it is protected through the use
of encryption, such as the Secure Socket Layer (SSL) protocol.
Changes to this Statement
Arlington Capital Management will occasionally update this Statement of Privacy to reflect
company and customer feedback. Arlington Capital Management encourages you to periodically
review this Statement to be informed of how Arlington Capital Management is protecting your
Arlington Capital Management welcomes your comments regarding this Statement of Privacy.
If you believe that Arlington Capital Management has not adhered to this Statement, please
contact Arlington Capital Management at firstname.lastname@example.org.
We will use commercially reasonable efforts to promptly determine and remedy the