By using our services and Site, you are consenting to our handling of your information as set forth in this Policy.
THE TYPES OF INFORMATION WE COLLECT:
Information you provide to us
We collect information that you provide directly to us. For example, we collect information when you engage for our services, you interact with us by sending us an email, or registering for a newsletter or an event through our Site. The types of information we may collect include your contact information, such as your first and last name, email address, phone number, and other information you may choose to provide to us and any information necessary for us to provide you services.
Information automatically collected from you
- Information about your use of our Site: FRCO and its third-party service providers may also use a variety of technologies that passively or automatically collect information about how the Site is accessed and used including but not limited to Internet Protocol (“IP”) addresses, Internet or other electronic network activity information, such as browsing history, search history, and other information regarding your interaction with an Internet website, application, or advertisement.
Cookies and other tracking technologies
Cookies are data files saved to your computer’s hard drive when you visit a website. A “session cookie” expires immediately when you end your session (i.e., close your browser). A “persistent cookie” stores information on the hard drive so when you end your session and return to the same website at a later date, the cookie information is still available.
Information we collect for events
For the purposes of this Policy, an “event” includes any conference, forum, seminar, webinar or workshop, whether it takes place in-person or virtually. If you register for an event, we may require that you provide us with your contact and other information. Such information could include your name, job title, company name, address, telephone number and/or e-mail address. In certain instances, you may also be required to provide your financial and billing information (e.g., billing name and address, credit card number, etc.). By registering for a specific event, you agree to our processing of the personal and/or other information you submit as part of the registration process. The use of such information is further described below.
Information we collect for services
We collect certain nonpublic information about you (“Customer Information”). The essential purpose for collecting Customer Information is to allow us to provide advisory services to you. Customer Information we collect may include:
- Information that you provide on applications or other forms. This Customer Information may include personal and household information such as income, spending habits, investment objectives, financial goals, statements of account, and other records concerning your financial condition and assets, together with information concerning employee benefits and retirement plan interests, wills, trusts, mortgages and tax returns.
- Identifying information such as your name, age, address, social security number, etc.
- Information about your transactions with us, or others (e.g., broker-dealers, clearing firms, or other chosen investment sponsors).
- Information we receive from consumer reporting agencies (e.g., credit bureaus), as well as other various materials we may use to provide an appropriate recommendation or to fill a service request.
Information we collect from third parties
We may receive information from third-party partners on our Site about your experiences or interactions with them. We may combine such third-party data with other information we receive from or about you.
HOW WE USE YOUR INFORMATION:
We use the information we collect from you for various purposes, including the following:
- To provide services to you.
- To update our mailing list information.
- To send you information regarding our news, upcoming events, products, and services.
- To use your personal information for the purpose for which it was collected.
- To communicate with you regarding specific events for which you have registered and/or attend and as reasonably necessary for the management of such events (including disclosure of your information to co-organizers, partners, sponsors, and third-party service providers).
- To communicate with you about your use of the Site and our services, to respond to your inquiries, to diagnose any technical problems, to understand how you and other users use our Site to improve our Site and services, and for other analytical and research purposes.
WHEN AND TO WHOM WE SHARE/DISCLOSE THIS INFORMATION:
- To Protect Ourselves or Others: We may access, preserve, and disclose your information, other account information, and content if we believe doing so is required or appropriate: (i) to comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) in response to your consent or at your direction to disclose the information; (iii) to protect the rights, property, and/or safety of you, us and others; or (iv) to enforce our policies, contracts or as otherwise permitted under applicable law.
- Merger, Sale, or Other Asset Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be shared as part of such a transaction as permitted by contract and/or applicable law.
Information We Disclose
As required or permitted by law, we disclose the nonpublic personal information we collect about our customers: (i) to persons necessary to effect the transactions and provide the services that our customers authorize, such as broker-dealers, custodians, independent managers etc.; (ii) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, etc.); (iii) our attorneys, accountants, auditors, and regulators; or (iv) as otherwise provided by law. We are permitted by law to disclose the nonpublic personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on our behalf or for joint marketing programs). These third parties are prohibited to use or share the information for any other purpose.
If you prefer that we not disclose Customer Information about you to third parties, you may opt out of those disclosures, that is, you may direct us not to make those disclosures (other than disclosures permitted by law). If you wish to opt out of disclosures to third parties, you may contact us via our portal https://www.lighthouse-services.com/frankrimerman/privacy, call our toll-free at 855-550-0007 or email us at [email protected].
- Information We Disclose to Affiliated Third Parties: We disclose Customer Information to third parties affiliated with FRCO. The affiliated third parties to whom we disclose Customer Information include: Frank, Rimerman Advisors, LLC, Frank, Rimerman Information Security, LLC, Frank, Rimerman + Co. CPA’s LLP, and FRC, LLC.
- Information We Disclose to Non-affiliated Third Parties: We disclose Customer Information to non-affiliated third parties. The non-affiliated third parties to whom we disclose this information include:
- Service Providers: We share your information with our cloud service providers who are providing services on our behalf and who need access to your information to carry out the services for us. These service providers do not retain, share, or use client data beyond the defined purpose of fulfilling the service. We also share your information with any third-party service providers with whom you instruct us to share, only with your prior consent.
Consumers residing in California
If you are a resident of California, you have the right to request a copy of the specific personal information collected about you during the 12 months before your request, and the right to have such information deleted. The term “personal information” has the same meaning given to it by the California Consumer Privacy Act (CCPA). Disclosure would include our business’ data collection and sales practices, including the categories and specific items of personal information we have collected, the source from which the personal information is collected, the business purpose of such collection, our use of the personal information and, if the information was disclosed or sold to third parties, the categories of personal information disclosed or sold to third parties and the categories of third parties to whom such information was disclosed or sold. You can make your request through the following channels:
- Privacy portal: https://www.lighthouse-services.com/frankrimerman/privacy
- Toll free telephone: 855-550-0007 Email: [email protected]
- Write to us at the following address:
Frank, Rimerman + Co., LLP
1 Embarcadero Center, Suite 2410
San Francisco, CA 94111
Your Choices and Rights
Where you have consented to our use of your information, you may withdraw that consent at any time and opt-out of further use.
If you would like to discontinue receiving promotional communications from us or to unsubscribe from mailing lists or any registrations, you can follow the instructions we have provided within the appropriate area of the Site or in our written communications to you.
- Request to Know: You have the right to request that we inform you of the personal information we have collected, used, and shared about you.
- Request to Delete: You have the right to request that we delete the personal information we have collected or retained about you.
- No Discrimination for Exercising Rights: You have the right not to be unlawfully discriminated against because you have exercised these rights.
To make a Request to Know or a Request to Delete, please contact us via our portal https://www.lighthouse-services.com/frankrimerman/privacy, call our toll-free at 855-550-0007 or email us at [email protected]. After you submit a request, we will require you to confirm your request and to also verify your identity by providing some information about yourself. If we are unable to verify your identity, we reserve the right to deny your requests.
You may also designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with your written and signed permission to act on your behalf and by directly confirming with us that you have provided the authorized agent permission to submit such a request. As permitted by law, we may require you to verify your identity in response to a request even if you choose to use an agent. The authorized agent will also need to verify their own identity directly with us.
If you are disabled, you may contact us to access this notice in an alternative format.
“Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Because there is not a commonly accepted standard for interpreting DNT requests, we do not recognize or respond to browser-initiated DNT signals. For more information about “do-not-track” requests please visit https://allaboutdnt.com/.
Your California Privacy Rights
California’s Shine the Light law gives customers who are California residents the right to ask us, once a year: (1) what personal Information we disclosed to third parties for those third parties’ direct marketing purposes in the prior calendar year; and (2) the identities of the companies with which we shared the information. The terms “customers” and “personal information” have the same meaning given by the Shine the Light law (see California Civil Code Sec 1798.83). To obtain such information, please contact us as indicated below in the “Contact us” section.
We do not intentionally collect or process, and we do not want you to provide (except as directly necessary for us to perform work for you), any sensitive personal data, including the following:
- Personal data that reveals your racial or ethnic origin, political opinions, philosophical or religious beliefs or union membership;
- Biometric or genetic data;
- Data concerning your health or medical condition; and/or
- Data concerning your sex life or sexual orientation.
Children’s Online Privacy Protection
Neither the Site nor our services are designed for or directed to children. Accordingly, we do not intentionally collect or maintain information about persons under the age of 16. If you believe that we have inadvertently collected personal information from a child under the age of 16, please contact us and we will make reasonable efforts to delete such information.
Security of your information
We maintain reasonable safeguards to protect your information against loss, unauthorized use, disclosure, or destruction and when transferring information for processing. We also require third parties providing services on our behalf to do the same. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information that you transmit to us.
Our employees and third parties are provided with client data on a need-to-know basis. All employees are subject to confidentiality agreements and undergo annual training on the proper handling of data.
Procedures have been developed and tested to handle a potential data breach. These procedures are designed to remediate any breach issues, to ensure that affected individuals are notified of the breach, and to minimize any potential damages or other harm.
Links to other websites and third-party contents
We will retain your information for as long as needed to provide our services or as otherwise required or permitted by law. We will retain and use this information as necessary to comply with our legal obligations, to resolve disputes, and to carry out and enforce our agreements.
Changes and policy updates
Frank, Rimerman + Co., LLP
1 Embarcadero Center, Suite 2410
San Francisco, CA 94111
Changes to this Privacy Notice
This privacy notice was last updated in April 2023.