Spearman Financial Services LLC Privacy Policy

Effective Date of this Policy: July 1, 2020

Introduction

Spearman Financial Services LLC; (“We” or “Us”) (“we,” “us,” or “our”) offer services and products (collectively, “Services”) to our customers, website visitors, and users (“you”). We also own this website, www.spearmanfinancialoh.com (the “Site”), to help us provide these Services to you. We sometimes collect Personal Information to provide information and Services that you request, and to better understand our customer’s wants and needs. Personal Information is information that specifically identifies an individual. Personal Information can include, but is not limited to, your name, address, e-mail address, phone number, and credit card information. Personal Information also includes the specific types of information defined under locally applicable law.

This Policy applies only to Personal Information collected through the Site and does not apply to any other data or information collected by us online or offline except to the extent this Policy is expressly referenced or incorporated into such other Services, such as by internet link on a website or presentation or display to Users.

We are committed to protecting the privacy of your information. Please take a moment to read this Privacy Policy (“Policy”) to understand how we collect, use, store, and delete Personal Information about you when you visit and/or use the Site; or use any of our Services.

Policy Integration

This Privacy Policy incorporates our Cookie Notice, which is accessible from a notice presented to users of the Site and/or Services and can be accessed here: Cookie Notice.

What Types of Information Do We Collect?

Information You Voluntarily Provide

We collect Personal Information you and others voluntarily provide when you use the Site and the Services. This could include information when you create an account, sign up for news alerts or newsletters, or contact us with questions. There may also be optional functions of the Site that you must provide Personal Information to use. The ways we will use such information will be provided on the page where you provide that information. Such optional services may include:

  • You opting in to location-based services;
  • Use of integrated services with third parties (e.g., logging using credentials from a different platform, linking accounts from different platforms);
  • Forum subscriptions after you create a forum registration;
  • Submitting general contact forms; and
  • Submitting inquiries in any form (e.g., e-mail, phone, mail, etc.).

Information Your Web Browser Provides

When you visit the Site, we automatically collect information provided by your web browser. This information includes, but is not limited to, your device’s unique identifiers and IP address, the pages within the Site that you visit, the number of visits you make to the Site and pages that you visit, any referring websites/URLs, the number of clicks you make while at the Site, the time that your device visited, the identity of your service provider, and the name and version of your operating system. This passively collected data is used to administer, operate, and improve the Site and Services, and to provide individualized advertising to you. We may use IP addresses and device data to identify a user who is noncompliant with our Terms of Use, or to protect the site or other users.

We may also use information in the aggregate that has no personal identifying characteristics to understand aggregate user and customer behavior. Non-personally identifiable information is not treated the same as Personal Information and we may use and disclose such information for various purposes.

How Do We Use and Share Personal Information?

Online Analytics

  • We use the following Google Analytics Advertising Features: The Site may employ Google® Analytics Display Advertising features.
  • The Site and other third-party vendors may use first-party cookies (such as the Google® Analytics cookie) or other first-party identifiers, and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together. Visitors to the Site can opt-out of the Google® Analytics Advertising Features used, including through Ads Settings, Ad Settings for mobile apps, or any other available means (for example, the NAI's consumer opt-out).
  • Our use of cookies is detailed in our Cookie Notice, which is available here: Cookie Notice You may revoke your consent to the use of web analysis at any time, either by downloading and installing the provided Google Browser Plugin or by following your internet browser’s instructions to enable, disable, or clear cookies.
  • Further information on Google Analytics is available in the Google Analytics Terms of Use, the Privacy and Data Protection Guidelines of Google Analytics and in the Google Privacy Policy.

Data Retention

Security of Information

Accuracy of Information

Questions About Your Data

Special Disclosures

Your California Privacy Rights

European Data Subjects

Changes and Updates to this Policy

Contact Information

Spearman Financial Services LLC Privacy Notice for California Consumers

Information We Collect

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA's scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
CategoryExamplesCollected
A. Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.YES
C. Protected classification characteristics under California or federal lAge (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).YES
D. Commercial InformationRecords of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.YES
E. Biometric Information Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.NO
F. Internet or other similar network activityBrowsing history, search history, information on a consumer's interaction with a website, application, or advertisement.YES
G. Geolocation dataPhysical location or movements.YES
H. Sensory data Audio, electronic, visual, thermal, olfactory, or similar information.YES
I. Professional or employment-related information.Current or past job history or performance evaluations.YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.NO
K. Inferences drawn from other personal information.Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.    YES

Use of Personal Information

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery.
  • To provide, support, personalize, and develop our Site, products, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site, third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our Site, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Site, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our [Website users/consumers] is among the assets transferred.

Sharing Personal Information

  • Category A: Identifiers.
  • Category B: California Customer Records personal information categories.
  • Category C: Protected classification characteristics under California or federal law.
  • Category D: Commercial information.
  • Category F: Internet or other similar network actiity.
  • Category G: Geolocation data.
  • Category H: Sensory data.
  • Category I: Professional or employment-related information.
  • Category K: Inferences drawn from other personal information.

Use of Personal Information

  • Our affiliates.
  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
    • We will use the data we have to match against data provided.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

Changes to Our Privacy Notice

Contact Information