WHO WE ARE
ETF
Model Solutions, LLC (“ETFMS”, “we”, “us” and/or “our”) offers financial
planning and investment advisory services (“Services”). ETFMS is a U.S.
Securities & Exchange Commission Registered Investment Adviser based in
Appleton, WI. We make information available about our services
through our website(s), including, but not limited to www.ETFModelSolutions.com, www.Embark-Invest.com,
mobile applications and corporate pages on social media sites, including, but
not limited to LinkedIn, Twitter, and Facebook (individually, the “Website”,
and collectively, the “Websites” and our related mobile app (“App”). Note:
Registration does not imply any particular skill or training.
OUR WEBSITE(S) USE
COOKIES
We
use cookies to analyze our website traffic (e.g. which pages you visit, what
type of device you use, which geographic location you’re located in, etc). We
also share information about your use of our site with our analytics partners
who may combine it with other information that you’ve provided to them or that
they’ve collected from your use of their services. To view our site, you need
to provide us with permission to do so by checking the “I accept to the use of
cookies” box. If you do not provide us with permission, you may be unable to
view certain content on our site.
Cookies
are small text files that can be used by websites to make a user’s experience
more efficient. We do not use cookies to collect personally identifiable
information (without your express permission).
The
Website(s) uses different types of cookies. Some cookies are placed by third
party services that appear on our pages. Once you’ve accepted cookies on this
website, you will no longer be presented with the settings popup again, unless:
TURNING COOKIES OFF
You
can usually switch cookies off by adjusting your browser settings to stop it
from accepting cookies. Doing so, however, will likely limit the functionality
of our and a large proportion of the world’s websites as cookies are a standard
part of most modern websites.
WHAT PERSONAL DATA WE
COLLECT AND WHY WE COLLECT IT
ETF
Model Solutions, LLC uses content forms on the Websites which it controls to
collect data from persons that voluntarily provide it when they sign up to
receive newsletters, white papers, research reports or other content, subscribe
to our blog, request a portfolio review, or risk profile analysis, or otherwise
indicate that they are interested in learning more about our services. Content
submitted via these forms is maintained indefinitely until individual opts out
of receipt of newsletters or other marketing collateral that may be sent from
time to time.
You
may decline to provide personal information to ETFMS. Declining to provide
personal information may disqualify you from receiving ETFMS services and
access to content and Site features that require certain personal information.
USE OF INFORMATION
The
personal information we collect will be used for the following purposes:
Information
voluntarily submitted through forms may be stored in multiple places,
including:
Information
about your website activity may be collected by 3rd-party services, including:
EMBEDDED CONTENT FROM
OTHER WEBSITES
Articles
on the Website(s) may include embedded content (e.g. videos, images, articles,
etc.). Embedded content from other websites behaves in the exact same way as if
the visitor has visited the other website.
These
websites may collect data about you, use cookies, embed additional third-party
tracking, and monitor your interaction with that embedded content, including
tracking your interaction with the embedded content if you have an account and
are logged in to that website.
This
Privacy Policy and these terms apply only to ETFMS operated services and
applications. ETFMS does not control linked Third-Party websites or their
privacy practices, which may differ from those set out in this Privacy Policy.
ETFMS does not endorse or make any representations about linked Third-Party
websites. Any Personal Information you choose to give to linked third parties
is not covered by this Digital Privacy Policy. We encourage you to review the
privacy policy of any company or website before submitting your Personal
Information. Some third parties may choose to share their users’ Personal
Information with us; that sharing is governed by that company’s privacy policy,
not this Privacy Policy.
WHO WE SHARE YOUR DATA
WITH
ETFMS
does not share personal data with any unaffiliated third party. If you become a
client of our ETFMS or one of our affiliates, we will share your data with
third-party service providers that provide us with necessary services to help
us serve your account.
HOW LONG WE RETAIN YOUR
DATA
We
will store your usage data until such time when you withdraw your consent for
us to do so. All other data as specified above will be retained for as long as
is necessary for the purpose(s) for which we originally collected it. We may
also retain information as required by law.
HOW WE PROTECT YOUR
DATA
ETFMS
takes reasonable steps and seeks to use appropriate technical or organizational
measures to protect your Personal Information from loss, misuse, and
unauthorized access, alteration, disclosure, or destruction. We proactively
monitor our stored data using intrusion detection and employ other industry
standard security practices. However, no Internet, email, or electronic
operating system that enables the transmission of data is ever fully secure or
error free therefore, we cannot ensure or warrant the security of any
information you transmit to us.
WHAT RIGHTS YOU HAVE
OVER YOUR DATA
If
you provide us with personal information, you can request to receive an
exported file of the personal data we hold about you, including any data you
have provided to us. You can also:
To
request any of the above, please send an email to [email protected] with
“Personal Information Request” form in the subject line and include your
requested action in the body of the message
This
does not include any data we are obliged to keep for administrative, legal, or
security purposes.
HOW DO I REQUEST A COPY
OF MY PERSONAL INFORMATION?
Under
the GDPR, EU residents have the right to place a SAR (Subject Access Request)
to see what personal data an organization holds about them. Please send an
email to [email protected] with
“Personal Information Request” form in the subject line and include your
request in the body of the message.
SPECIAL NOTE TO
INTERNATIONAL USERS.
The
Websites are hosted in the United States and is intended for and directed to
Users in the U.S. If you are a User accessing the Websites from the European
Union, Asia, or another jurisdiction with laws or regulations governing
personal data collection, use, and disclosure, that differ from United States,
please be advised that through your continued use of the Websites, which is
governed by U.S. law, this Privacy Policy, and our Terms of Service, you are
transferring your Personal Information to the United States and you consent to
that transfer.