Introduction

This Privacy Policy describes the ways Centric Advisors, LLC. (“Centric”) and its affiliates (collectively, “we,” “us,” “our,” or “Centric”) collect, use, share, and protect information about you. By accessing or using any of our websites, mobile applications, other online or downloadable products and services, or offline services and tools, including call centers, offline enrollment tools, surveys, and other applications (each a “Service” collectively, the “Services”), you agree to the practices described in this Privacy Policy regarding our collection, use, sharing, and protection of information about you.

We also include specific disclosures for residents of California.

Personal Information We Collect

There are two primary ways we collect information about you: (1) when you voluntarily provide it to us while using the Services; and (2) with automatic technologies connected to the Services. We explain this in further detail below in the sections titled “Information You Provide to Us” and “Information We Automatically Collect.”

Information You Provide to Us

We collect information that you voluntarily provide when using the Services. For example, if you choose to open an account with us, we may also collect other personal information, such as your full legal name, contact information, date of birth, Social Security Number and other information that may be used to identify you.

Information We Automatically Collect

When you visit or use the Services, we may gather certain information about the device or browser you are using via automated means (e.g., cookies and web beacons) including, but not limited to, device identifiers, IP address, browser version and configuration, operating system details, language preferences, and length of visits. Cookies are elements of data that a website can send to your browser when you visit that website. Like most commercial website owners, we may use cookies to help you manage your use of the applicable Services. We may use cookies as follows:

To recognize you as a regular user;
To remind us of your identity;
To customize your website experience and target ads and offers to you;
To track your progress;
To measure and analyze website traffic patterns to understand how our users’ habits are similar or different from one another;
To compile statistics on usage patterns; and
To conduct other research.

In addition, we use cookies, web beacons, or similar technologies to collect information through data analytics tools like Google Analytics and other third-party tracking pixels to improve your site experience, to serve you better ads on other sites, and to track your activity over time and across websites, as well as across different devices you use to access the Internet. We may use information collected this way to target marketing we believe corresponds to your interests within and outside our Services, for example, by utilizing retargeting or other targeted marketing practices (collectively, “Online Behavioral Advertising”). When engaging in Online Behavioral Advertising, we follow the cross-industry Self-Regulatory Principles for Online Behavioral Advertising managed by the Digital Advertising Alliance. To learn more about Online Behavioral Advertising, your choices regarding the information collected for that purpose, or to opt out, you may visit HTTP://WWW.ABOUTADS.INFO/CHOICES or HTTP://WWW.NETWORKINGADVERTISING.ORG/CHOICES. If you choose to opt out of Online Behavioral Advertising, a cookie will be placed on your browser indicating your choice. Because cookies are stored by your browser, any opt out choice you make will be effective only for the computer/browser combination you used to opt out. Please note that even if you opt out of Online Behavioral Advertising, you may still receive advertisements from us, but they will not be customized based on your online browsing activities. Clearing your browser’s cookies will reset your opt out instruction because the instruction is stored in a browser cookie. If you were to clear your browser cookies, you would need to renew any opt out choice you previously made.

How We Share Information About You

We may share information we collect about you with business partners with whom we work, such as our affiliates and other companies that help us improve, market or provide our Services to you. In addition, we may permit our agents, vendors, consultants, and other service providers to access information we collect about you through the Services to carry out work on our behalf.

We may also disclose information about you to third parties: (1) if we are required to do so by law, regulation, or legal process (such as in response to a court order or subpoena); (2) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity; or (3) in the context of a business negotiation or transaction relating to Centric or any affiliated entity (e.g., further to a merger, reorganization, liquidation, or any other business transaction), including negotiations of such transactions.

Your Choices

Keeping information about you up-to-date is important. If you are a customer, you may update, correct or delete contact information by contacting your financial professional.

If you are a customer or a financial professional who has enrolled in online Services with Centric or one of its affiliates, you can access your profile, review contact information that is stored, and revise certain types of information by signing into your online account.

Additionally, if you are a customer, financial professional or just a visitor, you can unsubscribe from marketing emails sent by Centric by following the unsubscribe instructions included in our emails or by EMAILING US DIRECTLY. Please note that even if you opt out of receiving such communications from us, we may continue to send you non-promotional emails, such as communications regarding our ongoing relationship with you.

How We Respond to Do Not Track Signals

Your internet browser may offer what is referred to as a “do not track” configuration that allows your browser to automatically signal your privacy preferences to certain websites that you visit. Industry standards related to this technology continue to evolve, and we have not yet identified a consensus on how to respond to such signals. Therefore, our websites do not currently respond to the “do not track” signals issued by browsers. To learn more about “do not track” signals, you may wish  to visit HTTP://WWW.ALLABOUTDNT.COM/

Links to Affiliate and Non-Affiliate Websites

You should be aware that linked sites may have their own privacy policies or notices that differ from this Privacy Policy. Your use of linked sites is governed by the privacy policies and terms and conditions of those sites, which we strongly suggest you review.

Children’s Privacy

We do not knowingly collect personal information from children under the age of 13 through our Services, and we do not knowingly market to children under the age of 13. If we learn that we have received information directly from a child who is under the age of 13, we will delete the information in accordance with applicable law.

Security 

We employ administrative, technical, and physical safeguards to secure personal information. Centric’s Information Security Program is designed to allow our representatives to use the tools and software we provide with confidence. Although we use reasonable efforts to safeguard information, transmission via the Internet is not completely secure and we cannot guarantee the security of information collected through our Services.

Your California Privacy Rights

The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to know/access, delete, and limit sharing of Personal Information. The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” As a financial services organization, much of the information we collect is exempt from the CCPA because it is covered by a federal or state financial privacy laws, such as the Gramm–Leach–Bliley Act and the Fair Credit Reporting Act. In addition, some information we collect may be exempt because it is considered public information (i.e., it is made available by a government entity) or because it is subject to other federal privacy laws, such as the Health Insurance Portability and Accountability Act.

To the extent that we collect Personal Information that is subject to the CCPA, your rights as a California resident to request access and deletion of that information are described below.

We do not sell your Personal Information to third parties. However, as described in this policy, we do allow third parties and service providers to collect Personal Information through the Services and share information with third parties and service providers for business purposes.

Right to Know/Access Information

You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, the categories of third parties with whom we share it, and the specific pieces of Personal Information we have collected about you. To protect our customers’ Personal Information, we are required to verify your identity before we can act on your request to know/access information.

If you have authorized someone else to make requests on your behalf, we require that you provide additional documentation, as described below.

Right to Request Deletion of Information

You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. To protect our customers’ Personal Information, we are required to verify your identity before we can act on your request to delete information. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated.

How to Submit a Request 

You may submit a request to exercise your privacy rights through any one of these means:
(1) By filling out a Consumer Data Request Form.
(2) By calling us at (888) 215-5888.

Verification Procedures – In order to process your request to know about or delete personal information we collect, disclose, or sell, we must verify your request. We do this by requesting that you provide personal identifiers, such as your name, phone number, and e-mail, that we can match against information we may have collected from you previously. We may also request you to confirm your request using the email or telephone account stated in the request.

Requests by Authorized Agent – You may authorize another individual or a business registered with the Secretary of State, called an authorized agent, to make requests on your behalf. We require that you provide legal documentation confirming the identity and authority of an authorized agent to act on your behalf. Such documentation may include, but is not limited to, a power of attorney, conservatorship or guardianship documentation, letters testamentary, or notarized statements (as may be appropriate under the circumstances). Parents of minor children may be required to submit a birth of the child certificate, in order to make requests on the child’s behalf.

Changes to this Privacy Policy

If we make changes to this Privacy Policy, we will revise the “Last Modified” date at the top of this page. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the applicable Service. Your use of such Service following these changes means that you accept the revised Privacy Policy.

Contact Us

For any questions you may have regarding this Privacy Policy, you have several options for reaching us. You may email us at PRIVACY@CENTRICADVISOR.COM, phone us at 888.215.5888, or write to us at the following address:

Centric Advisors, LLC.
Attn: Legal Department
13231 Champion Forest Dr.
Suite 311
Houston, TX 77069

Last Modified: August 23, 2020