Capstone Partners, L.C. Privacy Policy
Effective January 1, 2008
Capstone Partners, L.C. (“Capstone”) understands the importance of protecting relationships and information, and therefore, privacy is taken seriously. Capstone is committed to protecting privacy and earning the trust of its clients, investors and peers, and respects the right to keep personal information confidential and to avoid unwanted solicitations.
Therefore, the Capstone believes it is important to understand how we use the information provided to us through the normal course of business. This privacy policy discloses the details of what information we collect as well as how we use that information. We may revise this privacy policy from time-to-time by updating the information posted on this web site. Amendments to the privacy policy will be effective when posted. You should therefore periodically visit this page to review the current privacy policy, so that you are aware of any such revisions.
Capstone collects and stores information about people and property to quote and service its’ financial transactions, advisory services, products and programs. This information allows us to better manage information and administer relationships. Some of the information is called “Nonpublic Personal Information,” which generally means information that is provided by an individual, corporation, fund, trust or agency, obtained by Capstone, or that results from transactions. It does not include information available to the general public. The type of information Capstone collects varies according to the transactions or services requested and may include:
General Information
Capstone may receive this type of information from applications or other forms, by phone and online. Initiating the any process constitutes consent for Capstone to use the information as described in this policy. This information includes, but is not limited to:
* Name, address, and telephone number, e-mail address, social security number, FEIN number, CRD number, date of birth, and gender.
* What transaction funding will be used for, and, when relevant, what securities will be pledged. This information, and related questions, helps Capstone to screen and evaluate interest, and provides you with a formal proposal or initiate advisory services
* Bank account information to allow for the electronic transfer funds.
Transaction Information
If you are a client, then Capstone may collect and store additional information about you and your company. Such information is generated through transactions with Capstone, its affiliates, insurance carriers, third party administrators, marketing organizations, lenders, or others.
This information includes, but is not limited to:
* Personal and investment assets, tax strategies, retirement plans, testamentary dispositions, and insurance policies.
* Information you provide to Capstone to establish one or more business relationships, such as company, contact, or billing information provided through online or paper forms.
* Information created and maintained by Capstone for its clients in order to maintain the business relationship and provide superior client service. Examples include account status, choice of services, and audit logs.
* Information related to a transaction that is saved within applications or forms maintained by Capstone. This information is stored within Capstone’s databases in order to provide the requested services.
Web Site Information
Whenever a party visits any web site on the Internet, including CapstonePartnerslc.com, certain information from the entities computer may be captured. The information Capstone may receive from a computer when Capstone website is contacted includes:
* Non-personally identifying statistical Information about a visit to
Capstone web site(s), including Capstonepartnerslc.com. This information is compiled to allow Capstone to improve its web site design and to determine the relative importance of its services. The information collected in this manner includes:
- Date and time content was accessed;
- The referring website visited before;
- The domain name and IP (Internet protocol) address from which Capstone site was accessed;
- The operating system and web browser used to access content;
- The specific pages viewed during a visit; and
- City, state, and country of the visitor's Internet Service Provider (ISP)
(if available) for demographic purposes.
* Use of Cookies - From time-to-time, Capstone may use "cookies" within its web site pages. Cookies are small pieces of information about a visit stored on a computer's hard disk. Cookies are commonly used to store information about a last visit, such as selections made while navigating the web site, non-personal technical information listed above, or browsing patterns. Most Internet browsers now support cookies. Many of them allow users to disable cookies. However, cookies are often required to provide features within many web sites. Examples of Capstone’s use of cookies includes saving information that will allow Capstone’s Contact Us form to pre-fill name, phone number, and e-mail address based on a previously submitted request.
* Information provided to Capstone through its web site via online forms and applications, such as services request forms, applications, or web site messages to Capstone. For instance, one web site message form collects: an interested parties first and last name, address, e-mail, and phone number. This information may be used to initiate advisory services or consultation.
Information Use within Capstone
Capstone uses the information collected for the following purposes:
* To improve services – Capstone analyzes some of the information collected in order to improve services. Studying how visitors use the web site and its services provides valuable insight into how Capstone can make them more useful and easier to use.
* Providing superior support, administration, reporting, client service and maintaining relationships - the information collected allows Capstone to respond to needs more quickly.
* To provide information about new or enhanced services - by understanding how our services are utilized, we can offer the opportunity to review other services that may be of value.
* To send marketing material related to updates to available Capstone services as they become available. Note that the ability to opt out of this is provided as outlined below.
Sharing Information with Others
First and foremost, Capstone NEVER sells lists or Nonpublic Personal Information to third parties; however, such information may be disclosed to others as permitted by law. Generally, this includes disclosures to third parties that are necessary to affect, administer or enforce a transaction with Capstone, or in connection with servicing a client. These parties may include, but are not limited to, lenders, counter parties, insurance support organizations, FINRA brokers, accountants, attorneys, financial planners, third party administrators, and courts and government agencies. In accordance with the Fair Credit Reporting Act, Capstone will not disclose information obtained from consumer reporting agencies without the client’s consent.
Capstone may also disclose information to people and companies that perform support services on behalf of Capstone to financial institutions with which Capstone may have joint agreements. The purpose of this is to inform the client of other financial products or services jointly offered, endorsed, or sponsored by Capstone, and that Capstone believes the client may find useful. Capstone is highly selective in choosing these companies, and restricts the information provided to only what they need to offer and administer these services. Capstone also requires them to comply with strict standards of security and confidentiality, and they are not permitted to release, use, or transfer any client information to any other party for their own purposes.
Notwithstanding the foregoing, Capstone may disclose and/or transfer client information (i) in connection with any merger, sale, or liquidation of all or part of Capstone; (ii) if disclosure is required pursuant to a request for specific client information to comply with a subpoena, court order, and/or other legal instrument, legal proceeding or relevant law, or (iii) if there is an immediate, imminent threat to the safety of any person, Capstone Fund, or our web site.
Information Confidentiality and Security
Capstone is committed to preventing others from unauthorized access to Nonpublic Personal Information, and we maintain procedures and technology designed for this purpose. We take several steps to protect Nonpublic Personal Information we
have about you, including the following:
* Capstone updates and tests its technology on a regular basis in order to improve the protection of client information.
* Capstone requires outside companies and independent contractors to whom we provide Nonpublic Personal Information for marketing, servicing, or processing purposes to enter into a confidentiality agreement that restricts the use of the information to those purposes and prohibits independent use of the information.
* Capstone has internal procedures that limit access to Nonpublic Personal Information, such as procedures that require an employee to have a business need to access such information. Capstone maintains policies and conducts employee training about the proper physical security of workplaces and records. Employees are required to comply with Client Information Privacy Principles policies and procedures, or be subject to disciplinary action, including termination.
* Capstone makes use of hardware and/or software firewalls to protect Nonpublic Personal Information from unauthorized access.
Information Integrity Measures
Capstone also strives to protect the integrity of it’s’ clients Nonpublic Personal Information, and other client-related information, through use of the following:
* maintaining regular backups of client data in case of data loss or corruption;
* The use of uninterruptible power supplies (UPS) to prevent data loss during power spikes and power outages; and
* The use of virus detection and elimination software to prevent corruption of client data by viruses.
Despite these measures, however, Capstone cannot guarantee that Nonpublic Personal Information will be completely free from unauthorized access.
Clients Opt Out, Update Personal Information, and Privacy Questions
Clients may opt out of receiving notices of new or upgraded services from Capstone and its partners by sending an opt out request to info@Capstonepartnerslc.com. In your request, please include your company name, transactions or services (if any) proved through Capstone, your contact information, and the nature of your opt out request.
Clients may not opt out, however, of receiving information from Capstone that is essential for maintaining or updating accounts or system information. In addition, opt out does not include updates that may be presented within other online services.
Clients may review their personal information on communication provided to them in regards to their relationship with Capstone. Presently, there is no online database that connects to our web site that allows for online review. To verify and/or change personal information please contact Capstone through any of the following:
Capstone Partners, L.C.
3475 Lenox Road, Suite 400
Atlanta, GA 30326
If you have additional questions related to the privacy of your information or Capstone's privacy practices, please contact us online or through the above contact information.
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