VERMILLION & WHITE WEALTH MANAGEMENT GROUP, LLC., a Registered Investment Advisor, considers client privacy to be a fundamental aspect of our client relationships. We are committed to maintaining the confidentiality, integrity, and security of our current, prospective and former clients’ personal information.
In the course of providing clients with advisory services, we may collect, retain, and use client information for the purpose of administering our operations, providing client service, and complying with legal and regulatory requirements. This information may come from sources such as account applications, investment policy statements, from client transactions, and other forms from other written, electronic or verbal correspondence from client brokerage, attorney, accountant or other advisor the client may employ. We do not sell, exchange or disclose client information with outside organizations unless the third party is essential in administering our operations or except as required or permitted by law.
No confidential information, whatever the source, regarding any customer or client, may be disclosed except the following: We reserve the right to disclose or report personal information where we believe in good faith that disclosure is required under law, to cooperate with regulators or law enforcement authorities. Adviser reserves the right to disclose information with other Adviser employees in connection with the Adviser’s business and to non-affiliated third parties with whom the Adviser has a contractual agreement to jointly offer, endorse or sponsor a financial product or service; and to service and maintain customer accounts including effectuating a transaction. Adviser may disclose information about client or client’s account to a non-affiliated third party at client’s written or verbal request.
Finally, to further safeguard client information digitally, we maintain password protected systems, updated anti-virus and anti-spyware software, and encrypted hardware and software firewalls.
Your privacy is important to us. It is Vermillion & White Wealth Management LLC’s policy to respect your privacy regarding any information we may collect from you across our website, vwwgroup.com, and other sites we own and operate.
Information we collect
When you visit our website, our servers may automatically log the standard data provided by your web browser. This data is considered “non-identifying information”, as it does not personally identify you on its own. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details.
We may also collect data about the device you are using to access our website. This data may include the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.
We may ask for personal information, such as your:
- Social media profiles
- Date of birth
- Phone/mobile number
- Home/Mailing address
- Work address
- Payment information
- Driver’s license details
- Passport number
- Tax/SSN/Medicare/etc. number
This data is considered “identifying information”, as it can personally identify you. We only request personal information relevant to providing you with a service, and only use it to help provide or improve this service.
How we collect information
We collect information by fair and lawful means, with your knowledge and consent. We also let you know why we’re collecting it and how it will be used. You are free to refuse our request for this information, with the understanding that we may be unable to provide you with some of your desired services without it.
Use of information
We may use a combination of identifying and non-identifying information to understand who our visitors are, how they use our services, and how we may improve their experience of our website in future. We do not disclose the specifics of this information publicly, but may share aggregated and anonymised versions of this information, for example, in website and customer usage trend reports.
We may use your personal details to contact you with updates about our website and services, along with promotional content that we believe may be of interest to you. If you wish to opt out of receiving promotional content, you can follow the “unsubscribe” instructions provided alongside any promotional correspondence from us.
Data processing and storage
The personal information we collect is stored and processed where we or our partners, affiliates and third-party providers maintain facilities. We only transfer data within jurisdictions subject to data protection laws that reflect our commitment to protecting the privacy of our users.
We only retain personal information for as long as necessary to provide a service, or to improve our services in future. While we retain this data, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure, and cannot guarantee absolute data security.
If you request your personal information be deleted, or where your personal information becomes no longer relevant to our operations, we will erase it from our system within a reasonable timeframe.
The technology and security measures we employ and maintain are designed to protect your information. Sensitive information on our website is subject to a variety of protections. But, no data transmission over the Internet can be guaranteed as 100% secure. Despite our best efforts, we cannot ensure or warrant the security of any information you transmit to us or receive from us.
You may wish to participate in contests, sweepstakes and other promotions that we may offer from time to time. To do so, you may choose to share information found on our website with others and send e-mail invitations. We may ask you for information such as your name, e-mail address, date of birth and telephone number in exchange for participation in these promotions. We use the information you provide to administer the contests, sweepstakes and other promotions. Subject to applicable contractual or legal restrictions, we also may use the information to communicate with you, or the other people you select, about our products and services, or our partners or service providers may use such information to communicate with you about the contests, sweepstakes or other promotions or their products and services, and you consent to such use of any information you provide to us for this purpose.
Please be aware that any message boards, review capability, or any other interactive or social-type features or other features permitting content submission on a website administered directly by us, allow you to publicly post, and share with other users, certain messages, content, images or other information (e.g., stories, pictures, ingredients, tips, etc.). We may take certain precautions to protect those who use these areas of our website(s), but we encourage you to be wary of giving out any Personally Identifiable Information in such public forums. Any information you post or submit can be collected and used by people you do not know. We cannot guarantee the privacy and safety of these areas and are therefore not responsible for any information you choose to post. Your use of these features is fully at your own risk.
Special Statement for Job Applicants. Any Personally Identifiable Information you provide to us when applying for a career position with our company will be used solely to consider and act upon your application. We may retain your Personally Identifiable Information for a period of time, but only for as long as necessary for such purposes or as otherwise required by law. We may disclose your Personally Identifiable Information to our agents for the purpose of evaluating your qualifications for the particular position you applied for, for other available positions or as otherwise required by law or to perform background checks. We may also disclose your Personally Identifiable Information to third parties hired by us to collect, maintain, and analyze candidates for career positions or as otherwise required by law. By submitting this information to us, you agree to our use of this information.
Third-party access to information
We use third-party services for:
- Analytics tracking
- User authentication
- Advertising and promotion
- Content marketing
- Email marketing
- Payment processing
These services may access our data solely for the purpose of performing specific tasks on our behalf. We do not share any personally identifying information with them without your explicit consent. We do not give them permission to disclose or use any of our data for any other purpose.
We may, from time to time, allow limited access to our data by external consultants and agencies for the purpose of analysis and service improvement. This access is only permitted for as long as necessary to perform a specific function. We only work with external agencies whose privacy policies align with ours.
We will refuse government and law enforcement requests for data if we believe a request is too broad or unrelated to its stated purpose. However, we may cooperate if we believe the requested information is necessary and appropriate to comply with legal process, to protect our own rights and property, to protect the safety of the public and any person, to prevent a crime, or to prevent what we reasonably believe to be illegal, legally actionable, or unethical activity.
We do not otherwise share or supply personal information to third parties. We do not sell or rent your personal information to marketers or third parties.
Visiting our Websites from Outside of the United States.
Your California Privacy Rights.
Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personally Identifiable Information, such as name, e-mail and mailing address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the names and addresses of all such third parties. To make a request, please contact us at the e-mail address and/or telephone number provided on our website or write to us (with a reference to California Privacy Disclosure Information) at the address listed on our website. We will endeavor to respond to such requests for information access within 30 days following receipt at the e-mail or mailing address stated above. If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are only required to respond to each customer once per calendar year.
Limits of our policy
Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
Changes to this policy
Your rights and responsibilities
As our user, you have the right to be informed about how your data is collected and used. You are entitled to know what data we collect about you, and how it is processed. You are entitled to correct and update any personal information about you, and to request this information be deleted. You may amend or remove your account information at any time, using the tools provided in your account control panel.
You are entitled to restrict or object to our use of your data, while retaining the right to use your personal information for your own purposes. You have the right to opt out of data about you being used in decisions based solely on automated processing. You can view or request to anonymize your personal information at any time from this page: Request Personal Data. If you would like to request the deletion of personal data, please contact us.
Feel free to contact us if you have any concerns or questions about how we handle your data and personal information.
Vermillion & White Wealth Management LLC Data Controller
Contact Vermillion & White Wealth Management LLC
Vermillion & White Wealth Management LLC Data Protection Officer
Contact Vermillion & White Wealth Management LLC
This policy is effective as of 25 May 2018.
What is a cookie?
A cookie is a small piece of data that a website stores on your device when you visit, typically containing information about the website itself, a unique identifier that allows the site to recognize your web browser when you return, additional data that serves the purpose of the cookie, and the lifespan of the cookie itself.
Cookies are used to enable certain features (eg. logging in), to track site usage (eg. analytics), to store your user settings (eg. time zone, notification preferences), and to personalize your content (eg. advertising, language).
Cookies set by the website you are visiting are normally referred to as “first-party cookies”, and typically only track your activity on that particular site. Cookies set by other sites and companies (ie. third parties) are called “third-party cookies”, and can be used to track you on other websites that use the same third-party service.
Types of cookies and how we use them
Essential cookies are crucial to your experience of a website, enabling core features like user logins, account management, shopping carts and payment processing. We use essential cookies to enable certain functions on our website.
Performance cookies are used in the tracking of how you use a website during your visit, without collecting personal information about you. Typically, this information is anonymous and aggregated with information tracked across all site users, to help companies understand visitor usage patterns, identify and diagnose problems or errors their users may encounter, and make better strategic decisions in improving their audience’s overall website experience. These cookies may be set by the website you’re visiting (first-party) or by third-party services. We use performance cookies on our site.
Functionality cookies are used in collecting information about your device and any settings you may configure on the website you’re visiting (like language and time zone settings). With this information, websites can provide you with customized, enhanced or optimized content and services. These cookies may be set by the website you’re visiting (first-party) or by third-party service. We use functionality cookies for selected features on our site.
Targeting/advertising cookies are used in determining what promotional content is more relevant and appropriate to you and your interests. Websites may use them to deliver targeted advertising or to limit the number of times you see an advertisement. This helps companies improve the effectiveness of their campaigns and the quality of content presented to you. These cookies may be set by the website you’re visiting (first-party) or by third-party services. Targeting/advertising cookies set by third parties may be used to track you on other websites that use the same third-party service. We use targeting/advertising cookies on our site.
Third-party cookies on our site
Our third-party privacy promise
We review the privacy policies of all our third-party providers before enlisting their services to ensure their practices align with ours. We will never knowingly include third-party services that compromise or violate the privacy of our users.
How you can control or opt out of cookies
If you browse websites from multiple devices, you may need to update your settings on each individual device.
Although some cookies can be blocked with little impact on your experience of a website, blocking all cookies may mean you are unable to access certain features and content across the sites you visit.
We encourage parents to engage with us in protecting their children’s privacy, ensuring a safe and enjoyable online experience.
Collecting information from children
We do not knowingly collect Personally Identifiable Information from children under 13 on our website without first obtaining verifiable consent from a parent or guardian. When collecting non-personal information, we encourage children never to provide any details that may personally identify them or reveal their location. We do not require children to provide more information than is necessary to participate in an activity.
We do not use children’s contact details for marketing purposes, though we may use them for our internal marketing and research in order to improve the quality of products and services offered across our site.
In accordance with COPPA, if an activity does require any personal information (such as first name, last name, or email address), we will provide notice to and seek consent from a parent or guardian prior to collecting the information. We only retain collected information for as long as necessary to enable participation in the requested activity.
In the event we discover we have collected personal information in a manner non-compliant with COPPA, we will either delete the information or seek parental consent.
As a parent/guardian, if you believe your child is participating in an activity that collects personal information, and you have not received a notification or request for consent, please feel free to get in touch via our contact page vwwgroup.com. We do not use parent contact details for marketing purposes unless marketing materials are explicitly requested.
Safeguarding children’s privacy
We take security seriously, and do what we can within commercially acceptable means to protect your child’s personal information from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure, and cannot guarantee absolute data security.
Information abuse and community misconduct
We do not tolerate doxing (publishing of private or personal information about an individual without their consent), cyberbullying, or other forms of information abuse on vwwgroup.com.
If we discover that a child’s personal information has been disclosed on our site without the express consent of their parent/guardian, we will remove the content in question as quickly as possible and effect disciplinary measures (a warning, suspension or ban) on the offending account.
Third-party access to information
We do not knowingly disclose any personally identifying information or personal information provided by children to third parties. We may, however, disclose anonymised and aggregated versions of this information (analytics and statistics) for business, marketing or public relations purposes.
Parental controls and intervention
As a parent/guardian, you may at any time refuse to let us collect further information from your children for a particular activity or account. If you have given us consent previously, you may log in to your child’s account to review, edit or delete the information, or contact us via to request the removal of the information from our records.
Please be aware that the removal of certain information may result in the termination of the associated account, or withdrawal from the associated activity.