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    Privacy Policy and Notices for California Residents


    Privacy Policy for Business Contacts, Prospective Business Contacts, and Website Visitors

    For AssetMark, Inc., AssetMark Trust Company, AssetMark Retirement Services, Inc., and AssetMark Brokerage, LLC

     

    California Residents

    California residents with whom we have business relationships or a prospective business relationship have certain additional rights over the personal information (“PI”) that we collect about you. AssetMark, Inc., AssetMark Trust Company, AssetMark Retirement Services, Inc., and AssetMark Brokerage, LLC (collectively, “AssetMark,” also referred to as “we” and “us”) collect California Personal Information for a variety of reasons. This California Privacy Policy for Business Contacts describes our information practices, the rights you may have with respect to the personal information we collect from and about you, and how you can exercise those rights.

    Personal Information We Collect

    The following table lists the categories of California Personal Information we may have collected about you in the last 12 months, the categories of sources from which we have collected it, and why we have collected it.

    CATEGORIES OF INFORMATION WE COLLECT CATEGORIES OF SOURCES PURPOSE FOR WHICH THE INFORMATION WILL BE USED

    Identifiers, such as your name, address, Internet Protocol (IP) address, device identifier, e-mail address, telephone number(s), signature.

    • You
    • Your business organization
    • To market, provide and/or receive products and services to or from your organization
    • To comply with legal requirements

    Commercial information, such as records of products or services purchased or considered.

    • You
    • Your business organization
    • To market, provide and/or receive products and services to or from your organization
    • To comply with legal requirements

     

    Audio information, such as telephone calls on recorded lines.

    • You
    • To service your accounts and provide financial products and services to you
    • To detect fraud and maintain security

    Visual information, such as images from security cameras in certain locations in our offices and surrounding areas.

    • You
    • To maintain security

     

    Professional or employment-related information, including financial advisory firm or broker/dealer affiliation, securities licenses and certifications.

    • You
    • Your business organization
    • Federal and state securities regulators and self-regulatory organizations
    • To market, provide and/or receive products and services to or from your organization
    • To comply with legal requirements

    Inferences drawn from any of the information that we collect about you and your business or organization.

    • You
    • Your business organization
    • To market, provide and/or receive products and services to or from your organization

     

    Sensitive personal information, including the log-in and agent code for your business or organizational accounts in combination with any security or access code or password allowing access to the account.

    • You
    • Your business organization
    • To market, provide and/or receive products and services to or from your organization
    • To comply with legal requirements
    • To maintain security and detect fraud

     

    Internet or other electronic network activity, such as your interaction with our websites.

    • You
    • To market, provide and/or receive products and services to or from your organization
    • To advertise and market our products and services to you
    • To monitor activities, to maintain the security of our systems, and to detect improper activity

    Commercial information regarding expenses that you submit for reimbursement, such as receipts.

    • You
    • Your business organization
    • To evaluate expenses and requests for reimbursement of authorized business expenses

    Information reported to us as a result of a consumer report or background check that you authorize.

    • You
    • Background check service providers that you authorize
    • To make product offering decisions

     

    Identifiers such as your name, along with commercial and professional information such as the broker-dealer with whom you are affiliated, and your use of particular model portfolios and discretionary managers.

    • You
    • Your business organization
    • To further our commercial purposes, and to enhance our business and the financial products and services we offer
    • To provide analytics to the portfolio strategists and discretionary managers

    Categories of Personal Information Sold or Shared With Third Parties in the Last 12 Months

    We have not sold or shared California PI with any third parties in the last 12 months.

    Consumers Under the Age of 16

    We do not have actual knowledge that we collect, sell or share California Personal Information of minors under 16 years of age.

    Sensitive Personal Information

    We use and disclose sensitive California Personal Information only as permitted by law.

    Your Privacy Rights

    The right to know. You have the right to know what California Personal Information we have collected about you, including the categories of California Personal Information, the categories of sources from which the California Personal Information was collected, the business or commercial purpose for collecting, selling or sharing California Personal Information, the categories of third parties to whom we disclose California Personal Information, and the specific pieces of California Personal Information we have collected about you.

    The right to delete. You have the right to delete certain California Personal Information that we have collected from you, subject to certain exceptions.

    The right to correct. You have the right to correct inaccurate California Personal Information that we maintain about you.

    The right to opt-out. If a business sells or shares your California Personal Information to third parties, you have the right to opt-out of the sale or sharing of your California Personal Information. If you have affirmatively opted in to accept our performance and marketing cookies upon visiting our public websites, we share your IP address, the URL you came from, and your interaction with our websites with our analytics providers, third-party advertising networks, and social media platforms for their use in cross-context behavioral advertising across multiple websites. You can withdraw your consent:

    • Specifically, for ewealthmanager.com, at any time via Manage Preferences, selecting “Cookies Settings” and toggling off performance cookies and marketing cookies;
    • Specifically, for assetmark.com, at any time via Manage Preferences and toggling off performance cookies and marketing cookies;
    • By sending us an opt-out preference signal through the privacy controls available on your web browser.
    Read our Notice of Your Right to Opt-Out of the Sale or Sharing of Data.
     
    The right to limit use of sensitive personal information. If a business uses or discloses sensitive California Personal Information for reasons other than those permitted by law, you have the right to limit the use and disclosure of that information. We use or disclose sensitive California Personal Information only as permitted by law.
     
    The right not to receive discriminatory treatment. You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights, including the right not to be retaliated against for the exercise of your privacy rights.

    How You Can Exercise Your Privacy Rights

    You may exercise your privacy rights by calling (833) 620-0416 (toll-free), sending an email to CPRACompliance@assetmark.com, or by completing the interactive request form.

    We will confirm receipt of your request. We will acknowledge receipt of your request within 10 business days.

    We will verify your identity. We will match pieces of personal information provided by you with personal information maintained by us that we have determined are reliable. We may also require that you submit a signed declaration under penalty of perjury stating that you are the individual whose personal information is the subject of the request. Our verification process will vary depending on the nature of your request and the sensitivity of the information. In some instances, there is no reasonable method by which we can verify your identity. This is the case, for example, when you visit our website. In that circumstance, we collect your Internet Protocol address and information about your activity on our website, but we do not associate the information with any identifiable person.

    We will respond. We will respond to your request no later than 45 calendar days after we receive the request. If we cannot respond to your request within that time, we may notify you that we may take up to an additional 45 calendar days to respond, and we will explain why we need additional time.

    You may designate an authorized agent to submit a request on your behalf. To have another person submit a request on your behalf, you or they may call us at (833) 620-0416 (toll-free), send an email to CPRACompliance@assetmark.com, or complete the interactive request form. You will need to provide us with written permission authorizing the other person to submit a request to know or delete on your behalf. We will give you instructions on how to send the written authorization to us. We will still verify your identity and will verify that you have given your authority to another person.

    How We Process Opt-Out Preference Signals

    An opt-out preference signal or global privacy control is a signal that is sent by a platform or browser that clearly communicates the consumer’s choice to opt-out of the sale and sharing of personal information. If we detect an opt-out preference signal on your device’s browser, we will treat it as a valid request to opt-out. Our websites process opt-out preference signals in a frictionless manner. You can implement an opt-out preference signal for us to process in a frictionless manner through the privacy controls available on your web browser, or by downloading a browser extension that can be enabled to support your single opt-out preference signal. To learn more about how to implement opt-out preference signals and global privacy controls, please consult your browser’s privacy settings or visit Global Privacy Control.

    We do not share your California Personal Information unless you have directed us to do so by your affirmative acceptance of our performance and marketing cookies. If you have affirmatively accepted our performance and marketing cookies, but we later detect that you have enabled an opt-out preference signal or global privacy control, we will treat that signal as a request to stop sharing of data that we gather through performance and marketing cookies. For more information about our use of cookies, please see our Online Privacy Policy. You can manage your individual cookie preferences at any time. If you “Accept All” or accept our performance and marketing cookies, you are consenting to our collection, use, and sharing of your data collected by the cookies used on our websites. If you choose:

    You will be automatically opted out of all cookies except strictly necessary cookies. You can then choose whether to affirmatively accept each individual category of cookie used by our websites. If you accept performance cookies, we will take your direction to share information (such as the URL of the page you are visiting, your IP address, and your engagement with our websites) with Google Analytics. To learn what information Google Analytics collects, please visit policies.google.com/technologies/partner-sites.

    Contact for More Information

    If you have questions or concerns about our privacy policies and practices, you may call us at (833) 620-0416 (toll-free) or email us at CPRACompliance@assetmark.com


    Effective Date: January 1, 2023