Personal Information refers to information that identifies (whether directly or indirectly) a particular individual or business entity. Examples may include your name, postal address, email address, telephone number, Social Security number, Federal Tax Identification number, birthdate, banking information or other information.
Anonymous Information means information that does not directly or indirectly identify, and cannot reasonably be used to identify, a particular individual or business. You could provide Anonymous Information or it could be collected automatically. Examples may include information about your internet browser, device information about your device you use to access the Site (this information may include geolocation information and unique device information), demographic data such as city and state, usage information about your use of the Site, additional traffic data such as time and date of access, software crash reports, session identification numbers and access time, and other information regarding your use of the Site.
We collect information from you or about you when you provide this information to us directly. For example, we may obtain information when you request products or services from us, register on the website or submit an application for services or products, respond to surveys, contact customer support or otherwise interact with us via a Site.
In addition, when you interact with our Sites, we collect information through technology, such as cookies, Flash cookies and Web beacons. See Online Tracking section below.
Information collected through this technology helps us serve you better each time you visit the Site. Cookies are pieces of information that are stored directly on the device you are using. They allow us to collect information such as the type of browser you are using, the amount of time you spend using the services, the Sites you visit and the preferences you have set up for your accounts.
We may also receive information about you from other online and offline sources, such as public databases, social media platforms and other third parties. We may also collect and store information about you that we receive from our offline interactions with you to, among other things, enable us to update and correct the information contained in our database and to better customize your experience on the Sites.
We and certain trusted service providers operating on our behalf collect information about your activity on the Sites using tracking technologies, including:
You can choose to have your device refuse to accept any cookies, and the majority of devices and browsers offer additional privacy settings for cookies. You do this through your browser settings. Each device and each browser is a little different, so look at your device Settings or your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you will not have access to many features that make your user experience more efficient and some of the Sites will not function properly. Please note that you will need to manage your cookie settings for each device and browser that you use.
We may use local shared objects, sometimes known as Flash cookies, to store your preferences and to assist with online authentication by allowing us to recognize you and your device when you return to the Website or an Application. This permits us to display content based upon what you view on our websites and applications to personalize your use of the Services. Our advertisers and third-party service providers also may use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount and type of data, as well as how data is stored.
Cookie management tools provided by your device or browser will not remove Flash cookies. If you disable Flash cookies, you will not have access to many features that make your user experience more efficient and some of the Sites are unlikely to function properly.
Information collected through this technology helps us serve you better each time you visit the Sites. Cookies are pieces of information that are stored directly on the device you are using. They allow us to collect information such as the type of browser you are using, the amount of time you spend using the Sites, the Sites you visit and the preferences you have set up for your accounts.
We use the information we collect to help us personalize and continually improve your experience on the Site. We may also use that information in the following ways:
SERVICE PROVIDERS. We may share personal and anonymous information with agents, subsidiaries, affiliates, partners and other third parties that perform functions on our behalf, such as hosting, content management tools, analytics, etc. These entities have access to the Personal Information needed to perform their functions and are obligated to maintain the confidentiality and security of that Personal Information. The Service Providers are restricted from using, selling, distributing or altering this data in any way other than to provide the requested services.
EMERGENCY SITUATIONS. We may also use or disclose Personal Information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the Site; (b) protect and defend our rights or property, the Site or our users, or (c) act under emergency circumstances to protect the personal safety of us, our affiliates, agents, or the users of the Site or the public.
SHARING ANONYMOUS INFORMATION. To the extent permitted under applicable local laws, we may disclose or share Anonymous Information (or other information, other than Personal Information) in any other manner that we deem appropriate or necessary. Among other things, we may disclose Anonymous Information to third parties to help us determine how people use parts of the Site and who our users are so we can improve the Site.
The security of your Personal Information is important to us. Personal Information collected by the Site is stored in operating environments that are not available to the public. Our security procedures mean that we may occasionally request proof of identity before we disclose your Personal Information to you. In certain telephone and in person transactions we may ask for your full Social Security number, account number or other information to verify your identity before conducting the transactions you have requested. Note that we will never initiate a request via email for your sensitive information (e.g., Social Security number, personal ID, password, PIN or account number). If you receive an email asking for your sensitive information, you should be suspicious of the request and promptly contact us to report the suspicious activity. Please understand, however, that while we try our best to safeguard your Personal Information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. We review our security procedures to consider appropriate technology and methods to secure information.
When using the Site, you promise to: (a) provide true, accurate, current and complete information about yourself and your business, and (b) maintain and promptly update the registration information to keep it true, accurate, current and complete. If you provide any information that is untrue, inaccurate, not current or incomplete, or we have reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, we have the right to suspend or terminate your account and refuse any and all current or future use of the Site (or any portion thereof). You are entirely responsible for the security and confidentiality of your password and account. Furthermore, you are entirely responsible for any and all activities that occur under your account.
If you have any questions or comments about this Policy or our privacy practices generally, we encourage you to contact us by regular mail or email:
Elan Advisory Services
200 South 6th Street
Minneapolis, MN 55402