Updated: October 2018

Introduction

Counterpoint Capital Advisers, LLC (“Counterpoint,” “we,” “us,” and/or “our”) offers investment management services to various clients through our Equilibrium Portfolios (accredited and institutional investors only) and our Financial ANIE brand (individual investors). This Privacy Policy describes how we treat your Personal Information when you use or evaluate our Sites and Services. 

For this Privacy Policy, a User is an individual who uses our Sites to understand our Services, and a Client is an individual who signs a Client Agreement that entitles the Client to have her or his investment portfolio managed by us. 

Our Privacy Policy, Terms of Use, and, where applicable, Client Agreement collectively govern your use and/or evaluation of our Sites and Services.

Use of Information Collection

The types of information we collect depend on whether you are a User or a Client. Wherever we collect personal information, we try to link it to this privacy policy.

In General

The servers we use automatically record certain information (“Non-Identifiable” or “Aggregated Data”) about your use or evaluation of our Sites and Services. Similar to other technology platforms and services, we record information such as browsing activity, data displayed or clicked on (such as UI elements, ads, and links), and other information (such as browser type, IP address, date and time of access, cookie ID, and referrer URL). Along with cookies, we may also use third-party tracking technology, such as Google Analytics, to record similar information regarding you and your activity on our Sites.

Information Collected from Users

We do not collect Users’ Personal Information other than that described above under “In General.” 

Information Collected from Clients

In addition to the information we collect from you as a User as described above, we also collect Personal Information such as your and your beneficiaries’ full legal names, contact information, birth dates, Social Security Numbers, citizenship, investment objectives, investable assets, approximate net worth, income, and other regulatory disclosures that may be necessary and required by federal, state and certain statutory laws.

Use of Information

We and our authorized agents store, process, and maintain Personal Information related to you to provide client support, offer new products or services, and provide retirement planning and portfolio management services to Clients per the rules of regulatory bodies such as the Securities and Exchange Commission (the “SEC”) and the State of Oregon. If you choose not to provide such information, you cannot become a Client.

Additionally, we may share the information required to become a Client with our brokerage/custodian partner(s) solely to allow our brokerage/custodian partners(s) to provide services to you.

Information Sharing

We will not sell, rent, or trade your Personal Information with any third parties except as required by law, such as when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, front running or scalping, situations involving potential threats to the physical safety of any person, or violations of our Terms of Use.

Certain circumstances are outlined below, in which we may share your Personal Information without further disclosure. We occasionally hire other companies to perform certain business and technology-related functions (e.g., mailing information, database maintenance, and payment processing). If we employ another company to perform a function of this kind, we only provide them with the minimum information they need to perform their specific function. We maintain strict physical, electronic, and procedural safeguards that comply with federal standards to guard your Non-Public personal information.

Except as required by law or requested by regulatory authorities, we agree to maintain your non-public Personal Information in strict confidence.

Your Choices and Obligations

You may request deletion of your Personal Information by contacting us and giving us enough information to identify your account and prove that you own the specified account. We will try to make any deletion request effective as soon as possible. However, we may retain residual information related to your account per applicable laws. You may decline to provide your personal information to us; however, declining to provide your personal information may disqualify you from opening and/or maintaining an account with us.

Other Important Information

Security

We take reasonable steps to protect your Personal Information from loss, misuse, unauthorized access, alteration, disclosure, or destruction. No Internet, email, or electronic operating system that enables data transmission is ever fully secure or error-free, so please take special care in deciding what Personal Information you send us in this manner.

Advertising

We do not allow third-party advertising on our Sites.

Referral Program

We may offer a referral program that allows Clients to lower their annual advisory fee in exchange for referring other users who ultimately become Clients. Participation in our referral program is free and voluntary for Clients. By participating, you may provide us with certain information about the person to whom you refer to us, such as name and e-mail address. We treat this information like all our other Personal Information.

Social Media and Links to Other Websites and Apps: “Third-Parties”

This Privacy Policy and these terms apply only to our operated services and applications. Our Sites may contain links that access other websites and apps not operated or controlled by us. The policies described herein do not apply to Third-Party websites or applications.

Minors

Our Sites are not to be used by anyone under 18, so we do not knowingly collect Personal Information from anyone under 18. If you are under 18, please do not submit your personal information to us. If a parent or guardian becomes aware that their minor child has provided us with personally identifiable information without their consent, please contact us, and we will delete such information from our files.

Other

This Privacy Policy may change from time to time. We will post any Privacy Policy changes, and if the changes are substantial, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). Each version of this Privacy Policy will be identified at the top of the page by its updated date.