The California Consumer Privacy Act (“CCPA”) places certain obligations on companies doing business with California residents and requires that certain disclosures be made to You regarding the information collected about You and how that information may be used. The following discusses how Cambridge Investment Research, Inc. and its affiliates (“We”, “Us” and “Our”) collects, uses, retains, and distributes Your information. Your privacy is important to Us, and this Notice is intended to inform You of Your rights in compliance with the CCPA.
What is Personal Information?
Per the CCPA, “Personal Information” is the “information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device.” It includes, but is not limited to the following:
| Type of Information | Examples (not intended as an exhaustive list) | Purpose |
|---|---|---|
Identifiers |
Your name, social security number, address, email address, account number(s), etc. |
|
Financial Information |
Your financial and investor profile information such as Your risk tolerance, financial situation, investment timeframe, investment experience, tax situation, etc. |
|
Characteristics of Protected Classifications |
Your personal profile information such as date of birth, marital status, race, ethnicity, gender, disability, employment, education, etc. |
|
Commercial Information |
The products or services You have used, bank or credit card accounts, loan information, etc. |
|
Audio, electronic and/or visual |
Voice call recordings, video recordings and/or photographs at Cambridge events, etc. |
|
Professional/Employment Information |
Your current or former employers or place(s) of work. |
|
Information regarding minor children |
Any of the aforementioned information regarding minor children. |
|
Personal Information under the CCPA does not include any information that is publicly available, any de-identified or aggregated information, and any information which the CCPA excludes, for example health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA) and the Gramm-Leach-Bliley Act (GLBA).
These exclusions are important as they provide certain exceptions which may limit Your rights or may allow Us to continue to collect, use, retain, or distribute Your Personal Information. For instance, the CCPA does not apply to certain transaction or customer information collected by Us pursuant to the laws noted above.
This means that even if You submit to Us a verifiable request to delete or cease distributing any Personal Information, which may be required to be obtained or distributed in order to continue providing services to You, We may reject Your request to delete or cease distributing such information in order to either continue providing such services to You or to comply with the applicable laws, rules, or regulations.
We may obtain Your Personal Information from a number of sources, however, the main sources which provide Your Personal Information to us are You, Your financial professional, and the companies with whom You do business, along with any third parties who provide services or support to them. We collect Your information from You directly through Your account documents and updates, and from those third parties with whom We transmit information and data through the normal course of everyday business.
We use, retain, and share Your information to provide services to You and for various business reasons, including but not limited to the business purposes stated in Our Privacy Policy and to comply with Federal and State laws, rules, and regulations.
We provide Your Personal Information to Our affiliates and to Our various vendors, service providers, business partners, and other third parties with whom We have agreements in place, which contain provisions protecting Your Personal Information, to conduct transactions and other business dealings in order to provide services to You, for business purposes, and for regulatory purposes. Upon request or per regulation, We will provide Your Personal Information to government agencies as required by law, rule, or regulation.
The chart below shows the type of information We may collect and whether We disclose that information to a third party or sell the information. We do not collect all of the types of information listed on this chart, and the types of information collected may vary depending on the products and/or services utilized by You.
| Type of Information | Collected by Cambridge | Disclosed to a Third Party | Sold by Cambridge |
|---|---|---|---|
Identifiers |
Yes |
Yes |
No |
Financial Information |
Yes |
Yes |
No |
Characteristics of Protected Classifications |
Yes |
No |
No |
Commercial Information |
Yes |
Yes |
No |
Biometric Data |
No |
No |
No |
Internet Activity Information |
No |
No |
No |
Geolocation Data |
No |
No |
No |
Audio, electronic, visual, thermal, olfactory |
Yes* |
No |
No |
Psychometric information |
No |
No |
No |
Professional/Employment Information |
Yes |
Yes |
No |
Inferential Information |
No |
No |
No |
Information regarding minor children |
Yes |
No |
No |
*Cambridge does not collect all types of data in this category. Please refer to the examples above.
If You are a natural person residing in California, You have certain rights regarding Your Personal Information. The following describes those rights and how You may exercise them:
- You have the right to request that We disclose to You (1) the categories of Personal Information We have collected about You, (2) the sources from which Your Personal Information was or is collected, (3) the purpose for collecting Your Personal Information, (4) the categories of third parties with whom We share Your Personal Information, (5) the categories of Personal Information we either disclose to third parties or sell, and (6) the specific pieces of Personal Information We have collected, disclosed, or sold;
- You have the right to request that We delete certain Personal Information about You which we have collected (certain exceptions may apply);
- You have the right to request that We disclose to You (1) the categories of Your Personal Information that We have sold, and (2) the categories of third parties to whom Your Personal Information was sold, by category or categories of personal information for each category of third parties to whom the personal information was sold; and
- You have the right to direct Us to stop selling Your Personal Information. Neither Cambridge nor any of its affiliates sell Your data or Personal Information.
We will not discriminate against You because You exercise any of Your rights under the California Consumer Privacy Act.
To submit a request regarding Your Personal Information, please contact us at 888-245-0452 or email oad-processing@cir2.com.
Upon receipt of Your request, We will confirm receipt of Your request within ten (10) days. We have forty-five (45) days to respond to Your request and may extend that timeframe as reasonably necessary. We will notify You of any extension.
As the safety and security of Your Personal Information is important to use, We will not release any of Your Personal Information or data without verifying Your identity. We have implemented certain security protocols to protect Your Personal Information and to prevent fraud. In order to verify Your identity, We will ask certain questions regarding the Personal Information that We have received from You through Our ordinary course of doing business. In some instances, additional information may be required. If We are unable to verify Your identity, if You refuse to provide the information requested for verification purposes, or We are unable to contact You to complete any of the required verification steps, We will not provide Your Personal Information in response to the request.
In order to verify Your identity, You may be asked for some or all of the following information :
- First and Last Name
- Legal Address (street, city, state, zip code)
- Mailing Address (street, city, state, zip code) if different than Your legal address,
- Email Address
- Phone Number
- Account Number(s)
If submitting Your request via email, please include the specific data request You are making, such as, “I want to know the specific pieces of Personal Information You have collected about me.” Please do not provide any private or confidential Personal Information via email. We may provide You with additional instructions to complete Your request. We will reach out to You directly to verify Your identity.
If You are an authorized agent (such as a person or entity registered in California that has been authorized to act on behalf of Our client) making a data request under the CCPA regarding the information of a Cambridge client, We may require additional information from You. Further, if We do not already have documentation on file authorizing You to make such a request, We will require written authorization from Our client in order to provide You with the information. In some instances, We may also require that Our client directly verify their own identity according to Our information security protocols. If these steps are not met as required, requests for Personal Information will be rejected.
For any questions regarding this Notice, or any other questions regarding Your Personal Information, please call 888-245-0452 or visit JoinCambridge.com/privacy.
Please be advised, this Notice is subject to change. Please review it periodically as We may modify or update it as required by law, rule or regulation. Any changes to this Notice will become effective when posted to this site. Your continued use of Cambridge services will be construed as Your acceptance to any updates to this Notice or any other applicable Privacy Policy as revised.
The California Consumer Privacy Act (“CCPA”) places certain obligations on companies doing business with California residents and requires that certain disclosures be made to You regarding the information collected about You and how that information may be used. The following discusses how Cambridge Investment Research, Inc. and its affiliates (“We”, “Us” and “Our”) collects, uses, retains, and distributes Your information. Your privacy is important to Us, and this Notice is intended to inform You of Your rights in compliance with the CCPA.
What is Personal Information?
Per the CCPA, “Personal Information” is the “information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device.” It includes, but is not limited to the following:
| Type of Information | Examples (not intended as an exhaustive list) | Purpose |
|---|---|---|
Identifiers |
Your name, social security number, address, email address, account number(s), etc. |
|
Financial Information |
Your financial and investor profile information such as Your risk tolerance, financial situation, investment timeframe, investment experience, tax situation, etc. |
|
Characteristics of Protected Classifications |
Your personal profile information such as date of birth, marital status, race, ethnicity, gender, disability, employment, education, etc. |
|
Commercial Information |
The products or services You have used, bank or credit card accounts, loan information, etc. |
|
Audio, electronic and/or visual |
Voice call recordings, video recordings and/or photographs at Cambridge events, etc. |
|
Professional/Employment Information |
Your current or former employers or place(s) of work. |
|
Information regarding minor children |
Any of the aforementioned information regarding minor children. |
|
What is NOT included in Personal Information?
Personal Information under the CCPA does not include any information that is publicly available, any de-identified or aggregated information, and any information which the CCPA excludes, for example health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA) and the Gramm-Leach-Bliley Act (GLBA).
These exclusions are important as they provide certain exceptions which may limit Your rights or may allow Us to continue to collect, use, retain, or distribute Your Personal Information. For instance, the CCPA does not apply to certain transaction or customer information collected by Us pursuant to the laws noted above.
This means that even if You submit to Us a verifiable request to delete or cease distributing any Personal Information, which may be required to be obtained or distributed in order to continue providing services to You, We may reject Your request to delete or cease distributing such information in order to either continue providing such services to You or to comply with the applicable laws, rules, or regulations.
How does Cambridge obtain my Personal Information?
We may obtain Your Personal Information from a number of sources, however, the main sources which provide Your Personal Information to us are You, Your financial professional, and the companies with whom You do business, along with any third parties who provide services or support to them. We collect Your information from You directly through Your account documents and updates, and from those third parties with whom We transmit information and data through the normal course of everyday business.
How does Cambridge use my Personal Information?
We use, retain, and share Your information to provide services to You and for various business reasons, including but not limited to the business purposes stated in Our Privacy Policy and to comply with Federal and State laws, rules, and regulations.
To Whom does Cambridge provide my Personal Information?
We provide Your Personal Information to Our affiliates and to Our various vendors, service providers, business partners, and other third parties with whom We have agreements in place, which contain provisions protecting Your Personal Information, to conduct transactions and other business dealings in order to provide services to You, for business purposes, and for regulatory purposes. Upon request or per regulation, We will provide Your Personal Information to government agencies as required by law, rule, or regulation.
The chart below shows the type of information We may collect and whether We disclose that information to a third party or sell the information. We do not collect all of the types of information listed on this chart, and the types of information collected may vary depending on the products and/or services utilized by You.
| Type of Information | Collected by Cambridge | Disclosed to a Third Party | Sold by Cambridge |
|---|---|---|---|
Identifiers |
Yes |
Yes |
No |
Financial Information |
Yes |
Yes |
No |
Characteristics of Protected Classifications |
Yes |
No |
No |
Commercial Information |
Yes |
Yes |
No |
Biometric Data |
No |
No |
No |
Internet Activity Information |
No |
No |
No |
Geolocation Data |
No |
No |
No |
Audio, electronic, visual, thermal, olfactory |
Yes* |
No |
No |
Psychometric information |
No |
No |
No |
Professional/Employment Information |
Yes |
Yes |
No |
Inferential Information |
No |
No |
No |
Information regarding minor children |
Yes |
No |
No |
*Cambridge does not collect all types of data in this category. Please refer to the examples above.
What are my rights regarding my Personal Information?
If You are a natural person residing in California, You have certain rights regarding Your Personal Information. The following describes those rights and how You may exercise them:
- You have the right to request that We disclose to You (1) the categories of Personal Information We have collected about You, (2) the sources from which Your Personal Information was or is collected, (3) the purpose for collecting Your Personal Information, (4) the categories of third parties with whom We share Your Personal Information, (5) the categories of Personal Information we either disclose to third parties or sell, and (6) the specific pieces of Personal Information We have collected, disclosed, or sold;
- You have the right to request that We delete certain Personal Information about You which we have collected (certain exceptions may apply);
- You have the right to request that We disclose to You (1) the categories of Your Personal Information that We have sold, and (2) the categories of third parties to whom Your Personal Information was sold, by category or categories of personal information for each category of third parties to whom the personal information was sold; and
- You have the right to direct Us to stop selling Your Personal Information. Neither Cambridge nor any of its affiliates sell Your data or Personal Information.
We will not discriminate against You because You exercise any of Your rights under the California Consumer Privacy Act.
How do I submit a request regarding my Personal Information?
To submit a request regarding Your Personal Information, please contact us at 888-245-0452 or email oad-processing@cir2.com.
Upon receipt of Your request, We will confirm receipt of Your request within ten (10) days. We have forty-five (45) days to respond to Your request and may extend that timeframe as reasonably necessary. We will notify You of any extension.
As the safety and security of Your Personal Information is important to use, We will not release any of Your Personal Information or data without verifying Your identity. We have implemented certain security protocols to protect Your Personal Information and to prevent fraud. In order to verify Your identity, We will ask certain questions regarding the Personal Information that We have received from You through Our ordinary course of doing business. In some instances, additional information may be required. If We are unable to verify Your identity, if You refuse to provide the information requested for verification purposes, or We are unable to contact You to complete any of the required verification steps, We will not provide Your Personal Information in response to the request.
In order to verify Your identity, You may be asked for some or all of the following information :
- First and Last Name
- Legal Address (street, city, state, zip code)
- Mailing Address (street, city, state, zip code) if different than Your legal address,
- Email Address
- Phone Number
- Account Number(s)
If submitting Your request via email, please include the specific data request You are making, such as, “I want to know the specific pieces of Personal Information You have collected about me.” Please do not provide any private or confidential Personal Information via email. We may provide You with additional instructions to complete Your request. We will reach out to You directly to verify Your identity.
If You are an authorized agent (such as a person or entity registered in California that has been authorized to act on behalf of Our client) making a data request under the CCPA regarding the information of a Cambridge client, We may require additional information from You. Further, if We do not already have documentation on file authorizing You to make such a request, We will require written authorization from Our client in order to provide You with the information. In some instances, We may also require that Our client directly verify their own identity according to Our information security protocols. If these steps are not met as required, requests for Personal Information will be rejected.
Questions and Updates to this Notice
For any questions regarding this Notice, or any other questions regarding Your Personal Information, please call 888-245-0452 or visit JoinCambridge.com/privacy.
Please be advised, this Notice is subject to change. Please review it periodically as We may modify or update it as required by law, rule or regulation. Any changes to this Notice will become effective when posted to this site. Your continued use of Cambridge services will be construed as Your acceptance to any updates to this Notice or any other applicable Privacy Policy as revised.