Real Advisers LLC RIA Series (the “Firm”) is required by Texas and United States federal regulations to adopt certain procedures designed to maintain and secure the nonpublic personal information of its clients from inappropriate disclosure to third parties. The following policy (this “Privacy Policy”) is designed to meet the standards set forth in the regulations.
The Firm is committed to keeping personal information collected from potential, current and former clients confidential and secure. The proper handling of personal information is one of our highest priorities. The Firm never sells information relating to its clients to any outside third parties.
Client Information
The Firm collects and keeps only information that is necessary for it to provide the services requested by its clients and to administer clients’ business with the Firm.
The Firm may collect nonpublic personal information from clients or potential clients:
- From clients when they complete an application or other form. This includes information such as name, address, social security number, assets, income, net worth, copies of financial documents and other information deemed necessary to evaluate the client’s financial needs.
- As a result of transactions with the Firm, its affiliates if any, or others. This could include transactions completed with the Firm or information received from outside vendors to complete transactions or to effect financial goals.
Sharing Information
The Firm only shares the nonpublic personal information of its clients with non-affiliated companies or individuals (i) as permitted by law and as required to provide services to our clients, such as with representatives within our firm, securities clearing firms, mutual fund companies, insurance companies and other financial services providers, or (ii) to comply with legal or regulatory requirements. The Firm may also disclose nonpublic personal information to another financial services provider in connection with the transfer of an account to such financial services provider. Further, in the normal course of our business, the Firm may disclose information it collects about clients to companies or individuals that contract with the Firm to perform servicing functions such as:
- Recordkeeping;
- Computer-related services; and
- Good faith disclosure to regulators who have regulatory authority over the firm.
Companies hired to provide support services are not allowed to use personal information for their own purposes and are contractually obligated to maintain strict confidentiality. The Firm limits use of personal information to the performance of the specific service requested.
The Firm does not provide personally identifiable information to mailing list vendors or solicitors for any purpose.
When the Firm provides personal information to service providers, it requires these providers to agree to safeguard such information, to use the information only for the intended purpose and to abide by applicable law.
Employee Access to Information
Only employees with a valid business reason have access to clients’ personal information. These employees are educated on the importance of maintaining the confidentiality and security of this information. They are required to abide by our information handling practices.
Protection of Information
The Firm maintains security standards to protect clients’ information, whether written, spoken, or electronic. The Firm updates and checks its systems to ensure the protection and integrity of information.
Maintaining Accurate Information
The Firm’s goal is to maintain accurate, up to date client records in accordance with industry standards. The Firm has procedures in place to keep information current and complete, including timely correction of inaccurate information.
Should clients send the Firm questions and comments via e-mail, the Firm will share the client’s correspondence only with those employees or agents most capable of addressing the client’s questions and concerns.
The Firm will retain all written communication until it has done its very best to provide the client with a complete and satisfactory response. Ultimately, the Firm will either discard the communication or archive it according to the requirements under applicable securities laws.
Choices About How We Use and Disclose Your Information
The Firm strives to provide clients with choices regarding the personal information they provide to us. The Firm has created mechanisms to provide clients with the following control over their information:
- Tracking Technologies and Advertising. Clients may set their browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
- Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always opt-out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an e-mail stating your request to roland@realadviserscapital.com.
- Promotional Offers from the Company. If you do not wish to have your e-mail address or contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data, or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an e-mail stating your request to roland@realadviserscapital.com. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions.
- Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always adjust your user advertising preferences in your account profile by checking or unchecking the relevant boxes or by sending us an e-mail stating your request to roland@realadviserscapital.com.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website: http://www.networkadvertising.org/choices/.
Accessing and Correcting Your Information
You can review and change your personal information by logging into the Website and visiting your account profile page.
You may also send us an e-mail at roland@realadviserscapital.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use.
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to roland@realadviserscapital.com.
Disclosure of our Privacy Policy
The Firm recognizes and respects the privacy concerns of its potential, current and former clients. The Firm is committed to safeguarding this information. As a member of the financial services industry, the Firm is providing this Privacy Policy for informational purposes to clients and employees and will distribute and update it as required by law. It is also available upon request.