Castle Hill Privacy & Security Statement
Last updated on October 22, 2018
Castle Hill is committed to the protection of your privacy. We understand keeping your information secure and confidential is critical to earning and keeping your trust.
We NEVER rent, sell or trade your Personal Information (as defined below) to anyone. Ever.
This Privacy & Security Statement describes the specific policies and procedures we use to collect, utilize, disclose, share and protect your Personal Information. We refer to Castle Hill Capital LLC as “Castle Hill”, “we”, “us” or “us”. We refer to those who establish an account with us using our financial planning tool (“Account”) or otherwise use our service offerings as “users”. We refer to those who visit our website without logging into an Account or using our service offerings as “Visitors”. We refer to those who enroll in our Advisory Service as “Clients”. Together with our Terms of Use Agreement, this Privacy & Security Statement governs your use of our services.
How to Use this Privacy & Security Statement
This Privacy & Security Statement explains, in plain English, how Castle Hill gathers and uses your Personal Information in the context of each of Castle Hill's service offerings, including use of our financial planning tool for aggregating your accounts (“Dashboard”), our delivery of personalized advisor financial consultations and personalized wealth management service (“Advisory Service”). In particular, we describe how your Personal Information is shared and/or disclosed, how we collect and use other non-Personal Information and how we address other privacy and security matters – such as our overall security practices, deletion of your Personal Information upon request and opting-out of marketing communications. Lastly, we describe methods for contacting Castle Hill if you have privacy or security questions, comments or feedback.
How We Collect & Use Your Personal Information
“Personal Information” is your personally identifiable information such as your name, email or mailing address, phone number, account credentials, account numbers and any other identifier that we gather from our web sites, mobile applications, or through communications with representatives of Castle Hill that can be used to identify you personally.
Except as set forth in this Privacy & Security Statement, we don’t share your Personal Information with anyone. We do not share your Personal Information for third party promotional use. And we will NEVER sell, rent or trade your Personal Information.
We may also collect and use non-Personal Information that we obtain from your website and mobile app activities. This includes information that you do not explicitly provide to us but which may be implicitly provided to us as part of such activities.
The types of information we collect depend on which of our services you choose to use. The following are the types of Personal Information we collect at various stages of our relationship with you:
For Castle Hill Dashboard Users
This section of the Privacy & Security Statement is relevant to you if you have registered to use the Dashboard.
Personal Information We Collect
When you register for our Dashboard, we collect:
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Your name;
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Your email address;
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Your phone number; and
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Other optional information you may provide, such as your age, investable assets and risk tolerance.
When you register, and at times thereafter, we may present questions that ask you to submit demographic and other information. Responding to these surveys is completely optional. If you do respond by sending us other information, we collect that information and will retain it indefinitely.
How We Use Your Personal Information
To allow you to register for an Account to use our dashboard.
To allow you to add accounts (aggregate third party data), including:
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Securely gathering account balances, statements, transactions and holdings from your financial institutions;
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Displaying personalized dashboards and financial visualizations for you; and
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Providing you with contextual and relevant observations and insights;
To provide you with customer support or service offerings:
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Responding to and resolving your inquiries and requests via email or by phone; and
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Offering you our other services such as our Advisory Service.
To provide comparisons:
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Providing you comparisons of your financial situation (e.g., investment risks & returns, financial ratios) to better understand your financial situation; and
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Personalizing your user experience with Castle Hill.
We may use certain third party service providers to help us provide you with some of the services mentioned in this Privacy & Security Statement. In doing so, we may provide your data (including your Personal Information) to those third party service providers, each of whom are required under contract with us to safeguard the Personal Information and to use it only to provide services to us.
For Castle Hill Advisory Service Users
This section of the Privacy & Security Statement is relevant to you only if you have elected to receive our Advisory Service from a registered financial advisor employed by Castle Hill Capital. Upon enrollment in our Advisory Service, you will be asked to review and agree to a number of written agreements and statements. Once you have completed the enrollment process we will collect:
Personal Information We Collect
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Your mailing address;
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Your tax data, such as tax bracket and security cost basis;
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Your financial goals;
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Your investment objectives;
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Employment and income information about your household;
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Retirement planning information about your household; and
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Other information you elect to share with us about your spouse/partner and/or beneficiaries.
How We Use Your Personal Information
To provide you with the Advisory Service, including:
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Establishing a discretionary investment management relationship with you;
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Informing you about existing risks and opportunities within your current investment portfolio;
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Providing you with account statements, trade confirmations, tax information and other notifications related to the Advisory Service;
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Providing Charles Schwab with ongoing information required to provide continuing services to you;
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Providing you with customized investment insights;
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Creating and continuously managing your investment portfolio strategy, aligned with your investment objectives, tax data and personal preferences; and
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Personalizing your user experience with Castle Hill.
Additional Privacy & Security Information
Reviewing and Updating your Personal Information
You can view and update the profile and information associated with your Account by going to your dashboard. The credibility and relevance of our services depend on your providing us with complete, accurate and up-to-date information about yourself and your accounts, both now and in the future.
Deletion/Retention of Personal Information
Unless you request otherwise, we will retain the Personal Information we collect from you indefinitely.
Castle Hill, as a registered investment advisor, must comply with certain legal and regulatory requirements pertaining to record retention. We will respond to any requests we receive asking that we delete Personal Information that we possess from those who use our services. However, we will not delete information that we are required to retain in order to comply with applicable laws and regulations.
How to Request Deletion of the Personal Information We Collect
You may request your Account be deleted by our support department by emailing info@castlehill.capital from the email address associated with your Account, indicating “CANCEL” in the subject line of the message. After confirming you are the Account owner we will remove Personal Information from our records and will only continue to retain such information as required by law.
Advertising
We do not allow third party advertising on our web site or applications.
Protecting Children’s Privacy Online
Castle Hill is not directed to individuals under the age of thirteen (13), and those children should not provide Personal Information through our web sites or applications. We do not knowingly collect information from children under 13 without parental consent.
Modifications to our Privacy & Security Statement
We change our privacy practices from time to time as the need arises. When we do, we will revise this Privacy & Security Statement and we will post the revised document on our website at https://www.castlehill.capital/privacy-policy.