Last Updated: July 25, 2020

The Advisory Group of San Francisco, LLC (“The Advisory Group”, “ASGF”, “we,” “our” or “us”) respects your privacy and is committed to protecting it through our compliance with this privacy policy. This privacy policy explains our policies and procedures regarding the collection, use, disclosure, and security of certain information that we receive. As used in this privacy policy, “personal data” refers to information about an identified or identifiable individual, such as their name or email address.

Please note that by visiting or using https://advisorygroupsf.com/ (the “Site”) and the various other related services, features, functions, applications, websites and networks (together with the Site, collectively the “AGSF Services”), you are accepting the practices described in this privacy policy. This privacy policy is incorporated by reference into the Terms of Service that govern your use of the website (the “Terms”).

This policy describes the types of personal data and other information that we may collect from you or that you may provide when you access any AGSF Services or any of the other features, functions, services, and products, and our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy applies to personal data and information we collect or may collect:

• In accessing and using the Site.
• Through services provided to us or to you by third-party companies, financial advisors, agents or contractors.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by AGSF or any third party; or
• Any third party, including through any link that may be accessible from or on the AGSF Community, the Site or any of the other AGSF Services.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your only choice is not to access and AGSF Services. By accessing or using any of the AGSF Services, you agree to this privacy policy. This policy may change from time to time. Your continued access and use of AGSF Services, after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Minors under the Age of 18

None of the AGSF Services are intended for minors under 18 years of age. No one under age 13 may provide any information on or through the Site or any of the other AGSF Services. We do not knowingly collect personal data from children under 13. If you are under 13, do not use or provide any information on or through any of the AGSF Services or any of its features or register on the Site, use any of the interactive or public comment features of any of the AGSF Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name, username you may use or any pictures of you. If we learn we have collected or received personal data from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at info@advisorygroupsf.com.

Information We Collect About You and How We Collect It

We collect or may collect several types of information from users of the AGSF Site and the other AGSF Services, including:

• Information by which you may be personally identified, including personal data such as name, e-mail address, home address, phone number and birthday;
• Information that you provide when registering and creating an account;
• Information that is about you but individually does not identify you, such as IP address and date and time of visit;
• Billing information, including your credit card number, the address for billing and the billing contact information;
• Analytics or usage information and details such as when you use the AGSF Site or any of the other AGSF Services, information about your internet and mobile connections, and information collected through cookies.
• Usage details and information, such as the time, date, sender and your interactions with messages (such as when you open a message);
• Device, internet and mobile information such as the hardware model, operating system version, unique device identifiers, browser type, language, wireless network, and mobile network information (including the mobile phone number);
• Information that you provide by registering or creating accounts on or through the AGSF Site and the other AGSF Services, including information provided in connection with registering to access and use certain parts of the AGSF Site;
• Records and copies of your correspondence (including e-mail addresses), if you contact us; and/or
• Details of transactions you carry out through the AGSF Site and any of the other AGSF Services.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through or use the AGSF Site or any of the other AGSF Services.
• From third parties, such as our business partners and other third parties that provide us or you with certain services.

Certain transactions may also involve you calling us or our calling you. Please be aware that we may monitor, and in some cases, record such calls for staff training or quality assurance purposes.

Data Minimization

We take every reasonable step to limit the volume of your personal data that we process to what is reasonably necessary.

Use of Cookies and Other Tracking Technologies.

The technologies we use for automatic data collection may include:

• Cookies (or browser cookies).A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Site.

Do Not Track Policy

Your web browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. We do not honor any web browser “Do Not Track” signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third-party websites or online services. At present, no universally accepted standards exist on how companies should respond to do-not-track signals. In the event a final universally accepted standard is established, we will assess and provide an appropriate response to these signals.

Third-party Responsibilities and Services.

We may use or partner with other third-party companies, agents or contractors for various purposes in connection with our business and operations (“Service Providers”), including, web hosting, application and data base servers, payment processing, relationship building, the marketing and growth of our business and the performance of services on our behalf, such as gathering and analyzing information and the provision of services to you. In the course of performing these responsibilities and providing such services, these other companies may have access to your information. We may also share information, including your information, with these Services Providers in order to enable them to perform these responsibilities and to provide these services.  These Services Providers may have adopted their own privacy policies, which are not subject to control by AGSF. You should always review the policies of these Service Providers to make sure that you are comfortable with the ways in which they collect, use, maintain, protect and disclose your information. We do not list our current Service Providers because they change from time to time. If you would like the names of any of Service Providers, please email us at info@advisorygroupsf.com. The Service Providers may also transmit cookies to your computer or device when you click on ads that appear on or through the Service.

As a convenience to you, we may also provide links to other third-parties from within the AGSF Services. If you click on one of these links, you will be redirected to that third-party’s site (via affiliate cookies) and such third party may also transmit cookies to you. We do not have any control over that or how they collect, use, maintain, protect and disclose your information. Please be aware that cookies placed by third parties may continue to track your activities online even after you are no longer using any the AGSF Services, and those third parties may not honor “Do Not Track” requests you have set using your web browser.

WP Engine

The Site is hosted on WP Engine. WP Engine collects information about the website visitors to provide the service, analyze trends in the aggregate, and administer the site. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data.

As a visitor to the Site, you automatically transfer this information. Without this personal information it is impossible for AGSF to serve the Site in a reliable manner. For more information, please see WP Engine’s Privacy Policy.

Google Analytics

We use a tool called “Google Analytics” to collect information about use of the Site. Google Analytics collects information such as how often users visit the Site, what pages they visit when they do so, and what other sites they used prior to coming to the Site. We use the information we get from Google Analytics to improve the AGSF Services, the Site, and its related features, functionality and performance. Google Analytics collects only the IP address assigned to you on the date you visit this Site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit the Site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to the Site by disabling cookies on your browser.

You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to, you can opt out using the DoubleClick opt-out or permanently using a browser plugin.

DoubleClick: We may use Google Analytics and Google Ads remarketing codes to log when users view specific pages or take specific actions on a website. This allows us to provide targeted advertising in the future. If you do not wish to receive this type of advertising from us in the future you can opt out using the DoubleClick opt-out page or the Network Advertising Initiative opt-out page.

Google has additional information available about its Remarketing Privacy Guidelines, Policies, and Restrictions on its website.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal data:

• To provide the Site and the content that is on it to you.
• To provide technical and other support to you.
• To send you promotional communications, such as providing you with information about services, features, surveys, newsletters, offers, and events; and providing other news or information about us, AGSF Services, and our partners.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to the Site and the other AGSF Services.
• To enhance the safety and security of all of the AGSF Services.
• To verify your identity and prevent fraud or other unauthorized or illegal activity.
• To enable marketing, remarketing and targeted advertising and similar services from us or Service Providers, including direct and indirect marketing and on-line behavioral advertising regarding our own and third-party products and services that we believe may be of interest to you, including advertisement on third party websites.
• To perform targeted and other advertising on third party websites.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

Some of the information that we collect automatically is statistical data and does not include personal data, but we may maintain it or associate it with personal data we collect in other ways or receive from third parties or you provide to us. It helps us to improve the AGSF Services, and to deliver a better and more personalized service, including enabling us to:

• Estimate our audience size and better understand usage patterns.
• Store information about your preferences, enabling us to customize the Site according to your individual interests.
• Speed up your searches.
• Recognize you when you return to the Site and the other AGSF Services.

Storage and Transfer of Your Information

We may store any data or other information that we collect (personal or otherwise) ourselves or in databases and servers owned and maintained by us, our affiliates, agents or Service Providers. If you access or use the Site, the AGSF Services outside of the United States, information that we collect about you may be transferred to servers inside the United States and maintained indefinitely, which may involve the transfer of information out of countries located in the European Economic Area and other parts of the world unless otherwise prohibited by applicable law or agreed by AGSF and you. By allowing AGSF to collect information about you, you consent to such transfer and processing of such information without restriction. We may also store some information locally on your computer or other devices. For example, we may store information as local cache so that you can open the Site and view content faster.

Although users from all over the world may access the Site, keep in mind that no matter where you live or where you happen to use our services, you consent to us processing and transferring information in and to the United States and other countries whose data-protection and privacy laws may offer fewer protections than those in your home country.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal data that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To Service Providers, contractors and other third parties we use to support the AGSF Services and our business and operations.
• To a potential or actual buyer, assignee or other successor (including its related advisors and agents) in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of AGSF’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by AGSF about users of the Site is among the assets that may be or are actually transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your data information:

• To comply with any court order, law or legal process, including to respond to any government or regulatory request.
• To enforce or apply the Terms and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of AGSF.

We may share information that is anonymized (e.g., birthdates, etc.) or in an aggregated form that does not directly identify you and we may use and share any such information for any purpose without restriction so long as it does not violate the terms of this privacy policy or any applicable law. We may use, disclose or sell that anonymized or aggregated information without restriction so long as we do not disclose any of your personal data or violate the terms of this privacy policy or any applicable law.

Choices About How We Use and Disclose Your Personal Data

We strive to provide you with choices regarding the personal data you provide to us. We have created mechanisms to provide you with the following control over your personal data:

• Tracking Technologies and Advertising.You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website.
• Promotional Offers from AGSF.If you do not wish to have your e-mail address/contact information used by AGSF to market or otherwise promote our own or third parties’ products or services, you can opt-out through the unsubscribe mechanism at the bottom of the applicable email.

Accessing and Correcting Your Personal Data

You may change, correct or delete any personal data that you have provided to us by emailing us atinfo@advisorygroupsf.com.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of the Site that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please send an e-mail to info@advisorygroupsf.com or write to us at: 44 Montgomery Street, Suite 2410, San Francisco, CA 94104.

How Long We Store Your Personal Data

We will only retain your personal data, in a form which permits us to identify you, for as long as necessary to fulfil the purposes we collected it for. We will retain and use your personal data as necessary to satisfy any legal, accounting or reporting requirements, to resolve disputes or to enforce our agreements and rights. To dispose of personal data, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

Data Security

We understand that the security of your personal data is important. We provide reasonable administrative, technical, and physical security controls to protect your personal data.  However, despite our efforts, no security controls are 100% effective. AGSF cannot ensure or warrant the security of your personal data. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the home pages of the Site for at least 30 days. If we make material changes to how we treat our users’ personal data that are materially less protective than provided in this policy, we will use reasonable efforts to notify you by e-mail to the e-mail address specified in your account and/or through a notice on the home pages of the Site and to attempt to get your consent to the changes. The date the privacy policy was last updated is identified above. You are responsible for ensuring that we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting the Site and this privacy policy to check for any changes.  Like our Terms, of which this privacy policy is a part, your use, and/or continued use after our efforts to contact you, of the Site, or any of the other AGSF Services, means that you agree to be bound by such changes.

Survival

The policies indicated in this privacy policy will remain effective, even if the Terms and the other agreements between us are terminated and you are no longer using the Site or any of the other AGSF Services.

 Contact Information

To ask questions or comment about this privacy policy and our privacy practices or need to reach us for any other reason, you may contact us by e-mail at info@advisorygroupsf.com or by mail at 44 Montgomery Street, Suite 2410, San Francisco, CA 94104.