Fortiphi LLC Privacy Policy

Last Updated 04/23/2015.

Thank you for visiting. Your privacy is important to us. Fortiphi LLC and its subsidiaries (“Fortiphi”) provide this Privacy Policy to help users make an informed decision as to whether to use or continue using the Website and to outline important information regarding the use and disclosure of information collected via the Website. By using the Website, you are accepting the practices we describe herein as well as the Terms and Conditions of Use. Those who choose to access the Website agree to do so on their own initiative and at their own risk, and are responsible for complying with all applicable laws, rules and regulations. For information regarding Fortiphi’s Privacy Policy relating to the Graham-Leech-Bliley Act, HIPAA, California Information-Sharing Notice or other federal or state law or regulation, please click the links on this page: Graham-Leech-Bliley ActHIPAACalifornia Information-Sharing Notice. “Fortiphi, LLC.” or “Fortiphi,” as used herein, refers to the parent company and any of its subsidiaries.

Website reserves the right to change, modify, add, or delete provisions of this Privacy Policy at any time. Please check back frequently for updates as it is your sole responsibility to be aware of all changes and to be familiar with the most current version of our Privacy Policy. Fortiphi will email redline versions of changes to those who request. Changes are effective upon posting. If you do not agree with the terms of this Privacy Policy, please refrain from providing any information to Website and from use of the Website or any of the services of products offered through or provided on the Website. To help determine whether the Privacy Policy has changed since your previous visit to the Website, please reference the “Last Updated” date at the top of this page.

Please read this Privacy Policy carefully. Your use of this Website constitutes your acceptance to be bound by this Privacy Policy without limitation.

INFORMATION COLLECTION

Website collects information from individuals by various methods, including, but not limited to, when an individual voluntarily signs up at the Website to receive offers from Website and any third parties with whom Website may contract at its sole election and in its sole discretion.

Website gathers both personally identifiable information (“PII”) and non-personally identifiable information (“Non-PII”) (collectively PII and Non-PII are referred to herein as “Information”). PII is information that identifies or can identify you as an individual. Non-PII is generally demographic information and other aggregated information that does not reveal your specific identity.

When you visit this Website, Website and third parties with whom Website may partner or contract collect Information through the Website, including but not limited to each visitor’s Internet protocol address. Additionally, cookies are used to collect Information about visitors. We may use this information as Non-PII or we may link it to PII for use as PII, as in the case of linking your IP address to PII. We may also collect information concerning you from a third party source and use that information in combination with Information provided by you or otherwise collected on the Website. If you do not want Information collected through the use of cookies, you should be able to modify your browser preferences and/or settings to provide you with choices related to cookies. Please note that if you choose to reject cookies, you may be unable to use certain services provided by this Website. Website and its third party service providers may also use pixel tags, web beacons, clear GIFs and other similar technologies in association with some pages of the Website and in certain HTML email messages to collect Information.

INFORMATION USE AND DISCLORE

Among other uses, Website uses Information, including but not limited to your email address. Website may maintain separate email lists for different purposes. If at any time you wish to end your email subscription from a particular list, please follow the instructions at the end of the email message to unsubscribe from the particular list. For assistance with any Website unsubscribe request, please email us at privacy@fortiphi.com. Please note that it may take up to 10 days for us to process an opt-out request.

Even if you have unsubscribed from receiving promotional emails from us, we reserve the right to send you other types of important e-mail communications as permitted by law because of a business relationship with you, notwithstanding any previous opt-out request (as, for example, in the case of administrative notices). Please note that opting out of receiving promotional email communications will affect only future communications from Website. If we already provided your Information to a third party before you opted out from Website, you may have to change your preferences (i.e., opt out) directly with that third party as well.

We also may disclose your Information in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from law enforcement or another government agency, or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us in our sole discretion.

SECURITY OF INFORMATION

We recognize that the security of the Information you provide to us is important. Though we take every precaution to help ensure that security, we cannot guarantee that Information supplied by visitors to the Website will be secure at all times. We assume no liability for any damages you may suffer as a result of interception, alteration or misuse of Information provided to us. If you have reason to believe that there has been any breach of the security of the Website, please contact us at privacy@fortiphi.com.

COLLECTION OF INFORMATION BY THIRD PARTIES

The Website and Website email correspondences may contain links to third-party Internet websites, which are not owned or operated by Website. We provide such links only as a convenience, and the inclusion of a link on the Website or in an email does not imply endorsement of the linked site by Website. If you provide any PII through any such third-party website, your transaction will occur on such third party’s website (not Fortiphi) and the PII you provide will be collected by, and controlled by the privacy policy of, that third party.

We are not responsible for the privacy practices or the content of such third-party websites, including such websites’ use of any PII that you provide to them. We strongly encourage you to become familiar with the privacy practices of those third party websites.

CONTACTING US

If you have any questions concerning this Privacy Policy, you may send them by email to privacy@diversiphied.com. Please be advised that email communications may not be secure, so we suggest that you not transmit sensitive information or PII in your email correspondence(s) with us.

CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you have the right to request additional information about our usage and sharing of certain categories of PII with third parties. California law gives you the right to send us a request to divulge the categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year, the names and addresses of the third parties that received that information, and, if the nature of the third party’s business cannot be determined from their name, examples of the products or services they marketed. We may provide you this information in a standard format that is not specific to you. The designated email address for any such requests is service@fortiphi.com.

OUR COMMITMENT TO SECURITY
Fortiphi has put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online.

HOW TO CONTACT US
If you have any questions or concerns about the Fortiphi online policy for this site or its implementation you may contact us at service@fortiphi.com.

Fortiphi Financial LLC Privacy Policy

Last Updated 04/23/2015.

The trust our clients have with Fortiphi Financial (“Fortiphi”) is our most valued asset. We strive to maintain your trust and confidence in our firm, an essential aspect of which is our commitment to protect your personal information. We know you value your privacy, so we will not disclose your personal information to anyone unless it is required by law, at your direction, or is necessary to provide you with our services. We have not sold and do not sell your personal information to anyone.

Information we collect, maintain and communicate 

Fortiphi may collect your personal information in a variety of ways so we can provide your investment management and net worth solutions.  In order to offer the broadest range of services, we may collect the following types of information:

Website usage: We track visitors to our website. This data allows us to provide the best service possible by helping to ensure the health of the network and services, developing and deploying new business services, researching, improving and maintaining our existing business services and providing customized services to our users.

Cookies: When you visit our website we may utilize cookies, which are small files that are placed on your computer. A cookie contains a string of characters to identify your browser and may be used to help provide a more customized user experience. Most internet browsers are set by default to accept cookies, but you may experience some issues using some of the features of our site if you have opted to not accept cookies.

Log files: When you view a website, your browser sends data about your computer system to the web server. Our servers capture this information which may include browser type, time of day, IP address, or cookie and language information.

Email submissions: We may keep records of all email communications sent to Fortiphi. These emails may be processed and used to provide feedback, answer questions, or service some other request.

Account related

  • Information we receive from you to open an investments account or comprehensive planning advice to you (such as your home address, telephone number, and detailed financial information);
  • Legal documents and tax returns to accurately represent your estate and financial plan;
  • Relevant personal information necessary to provide you with the appropriate insurance protection;
  • Information that we generate to service your investment accounts; and
  • Information that we may receive from authorized third parties with respect to your engagement (statements from insurance carriers and existing, outside investment accounts/partnerships).
  • Information provided by you on applications, contracts or other forms furnished to Fortiphi, or through other interactions you have with Fortiphi.
  • Information arising from your investments in mutual fund accounts managed by Fortiphi.

Sharing information

We do not disclose any non-public personal information about our current or former clients to non-affiliated third parties, except as required by law, to ensure compliance with this and other policies, to prevent and detect possible fraud or misuse of services, and to ensure the protection of imminent harm or danger to Fortiphi or its employees.

For example, we are permitted by law to disclose all of the information we collect, as described above, to the custodian banks and/or various funds you invest in as needed to process your transactions. Furthermore, we restrict access to your non-public personal information to those persons who require such information to provide products or services to you.

Some services you receive from Fortiphi are provided through our service providers, which include but are not limited to the custodian banks and/or various funds you invest in. All records containing your non-public personal information are also maintained at the service providers’ places of business.

In the event that you hold shares of mutual funds in accounts we manage on your behalf, through a financial intermediary, such as a broker-dealer, bank or trust company, the privacy policy of your financial intermediary would govern how your non-public personal information would be shared with non-affiliated third parties.

We may share aggregated usage data with our support vendors and third-party suppliers that do not provide a method to individually track a user, or when we have been provided your explicit consent to share the information with a third party.

Keeping data safe

We maintain physical, electronic, and procedural safeguards that comply with federal standards to protect our clients’ nonpublic personal information. These safeguards include requiring third parties that perform services for us to agree by contract to keep your information strictly confidential and secure. We maintain limits on their access to our internal information, only providing that which is necessary to complete the requested services. In the event you decide to end our relationship, we will adhere to the privacy policies and practices described above.  Fortiphi permits only authorized employees and affiliates who have signed a copy of Fortiphi’s Privacy Policy to have access to client information.  Employees violating Fortiphi’s Privacy Policy will be subject to Fortiphi’s disciplinary process.  Additionally, whenever Fortiphi hires other organizations to provide services to Fortiphi’s clients, Fortiphi will require them to sign confidentiality agreements and/or the Privacy Policy.

Teaming up against identity theft

Identity theft is a serious concern to all of us. Fortiphi takes steps to safeguard your information and help protect you from identity theft by:

  • never asking for your passwords or account login information via email request;
  • utilizing client identification and authentication procedures before initiating transactions;
  • creating a secure transmission connection to our websites. You will see a padlock icon and web address beginning with https to indicate the site is secure;
  • ensuring our employees are trained to safeguard personal information about you.

You can also help protect your identity and accounts. Here are a few steps to remember:

  • Fortiphi will never request confidential information in a non-secure or unsolicited email communication;
  • shred any documents that contain personal information or are requesting you to open an account at a company with which you do not intend to do business;
  • regularly check your credit report for unauthorized transactions and activities;
  • protect all personal identification numbers (PINs) and website passwords. Do not share this data.

Privacy is not for sale

We do not and will not sell your personal information to anyone, for any reason, at any time.

Policy changes

This policy may change from time to time as necessary or required by law. We will not reduce your rights under this agreement. Most changes should be minor in nature and will be reflected on this site with the date and revision number noted at the start of the policy. In the event the changes are significant in nature, we will provide notification through more prominent placement on the Fortiphi website.

Should you have any questions regarding the above, please contact:

Pierre Gallant, manager, Fortiphi Financial LLC.
pierre@fortiphi.com
(206) 818-4800
17865 Ballinger Way NE, Seattle, WA 98155-4234

Fortiphi Financial LLC is a Registered Investment Adviser.  Fortiphi’s Form ADV Part II is available upon request.

Gramm-Leach-Bliley Act Disclosure

DISCLOSURE NOTICE OF PRIVACY PRACTICES

Last Updated 04/23/2015.

The Gramm-Leach-Bliley Act deals in part with how we treat your non-public personal financial information, and requires any company that collects such information to inform clients of the company’s privacy practices. We at Fortiphi, LLC. and its subsidiaries (collectively, “Fortiphi”) are committed to maintaining customer confidentiality. We appreciate this opportunity to clarify our privacy practices for you.

In performing our various business services, we may obtain certain “non-public, personal financial information” about you. This “information” can include information we receive from you on applications or other forms, information about your transactions with us, our affiliates, or others, and information we receive from a consumer reporting agency.

Our Corporate Policy is:

  • We do not disclose any non-public personal information about our clients or any former clients to anyone in any way that is prohibited by federal law.
  • Permitted disclosures include, for instance, providing information to our employees and, in limited situations, to unrelated subcontractors who need to know that information to assist us in providing services to you.
  • We restrict access to information to authorized individuals who need to know this information to provide services and products to you.
  • We maintain physical, electronic, and procedural safeguards that protect your information.

If you want to learn more about the Gramm-Leach-Bliley Act, you can obtain an entire copy of this federal rule and other useful information related to the rule from the Federal Trade Commission website or if you have questions or would like to request that your information not be shared among Fortiphi and its subsidiaries, please do not hesitate to contact your Fortiphi professional, call (800) 795-7301 or send an email to service@fortiphi.com, including your full name, any account or client number, and the name of the Fortiphi company providing services to you. We value our relationship and strive to earn your continued trust.

Notice Information – Sharing Disclosure for California Residents

NOTICE INFORMATION-SHARING DISCLOSURE

Last Updated 04/23/2015.

In accordance with California law, Fortiphi LLC. and its subsidiaries (collectively “Fortiphi”) provide this Information-Sharing Disclosure in an effort to inform you of how Fortiphi shares your personal information. Fortiphi only shares client information, such as your telephone number, among third parties affiliated by common ownership. These fifty-five affiliated entities may use such shared information for marketing purposes, such as offering services to you that may be related or complementary to those you already receive from Fortiphi. Fortiphi does not disclose client information to unaffiliated third parties or mass-marketers.

Notice of Privacy Practices – HIPAA

NOTICE OF PRIVACY PRACTICES – HIPAA

Last Updated 04/23/2015.

This notice describes how medical information about you may be used and disclosed and how you can get access to this information. Please review it carefully.

STATEMENT OF OUR DUTIES
We are required by law to maintain the privacy of your personal health information and to provide you with this notice of our privacy practices and legal duties. We are required to abide by the terms of this notice. We reserve the right to change the terms of this notice and to make any new provisions effective to all of the personal health information that we maintain about you. If we revise this notice, we will provide you with a revised notice by mail, or electronically. If the notice is provided electronically, you have the right to request a paper copy of the revised notice.

  1. STATEMENT OF YOUR RIGHTS
    You have a right to know how we may use or disclose your personal health information. This notice informs you of those uses and disclosures. There are certain uses and disclosures of your personal health information that we are permitted or required to make by law without your permission. For all other uses and disclosures, we first must obtain your permission. In addition, you have the following rights:

    • The right to request that we place additional restrictions on our uses and disclosures of your personal health information. However, we are not obligated to agree to impose any such additional restrictions.
    • The right to access, inspect and copy the protected information pertaining to you that we maintain in our files about you, and the right to have us correct or amend any information that we create in error. Requests to access or amend your health information should be sent to the contact person and address provided in paragraph 6.
    • The right to receive an accounting of the disclosures of your personal health information that we make for purposes other than activities related to your treatment, or our payment functions or other health care operations.
    • The right to request that you receive communications of personal health information in a confidential manner.
    • If you received this notice electronically, you have the right to obtain a paper copy of this notice from us on request.
  1. INFORMATION WE MAY COLLECT ABOUT YOU
    We may collect the following categories of information about you from the following sources:

    • Information that we obtain directly from you, in conversations or on applications or other forms that you fill out.
    • Information that we obtain as a result of our transactions with you.
    • Information that we obtain from your medical records or from medical professionals.
    • Information that we obtain from other entities, such as health care providers or other insurance companies, in order to service your policy or carry out other insurance-related needs.
  1. PERMISSIBLE USES AND DISCLOSURES OF PROTECTED INFORMATION
    • To Carry Out Treatment Functions. We may use or disclose your health information without your permission for health care providers to provide you with treatment.
    • To Carry Out Payment Functions. We may use or disclose your health information without your permission to carry out activities relating to reimbursing you for the provision of health care, obtaining premiums, determining coverage, and providing benefits under the policy of insurance that you are purchasing. Such functions may include reviewing health care services with respect to medical necessity, coverage under the policy, appropriateness of care, or justification of charges.
    • To Carry Out Certain Operations Relating To Your Benefit Plan. We also may use or disclose your protected health information without your permission to carry out certain limited activities relating to your health insurance benefits, including reviewing the competence or qualifications of health care professionals, conducting quality assessment activities, amending, replacing or adding benefits whether through insurance contracts or otherwise, and placing contracts for stop-loss insurance or reinsurance.
    • To Plan Sponsors pursuant to the restrictions imposed on the plan sponsors in the plan documents.
    • In Situations Permitted Or Required By Law. We also may use or disclose your protected health information without your written permission for other purposes permitted or required by law, including the following:
      • As authorized by and to the extent necessary to comply with workers compensation or other no-fault laws.
      • To a health oversight agency for activities including audits or civil, criminal or administrative proceedings.
      • To a public health authority for purposes of public health activities (such as to the Food and Drug Administration to report consumer product defects).
      • To a law enforcement official for law enforcement purposes or in response to a court order or in the course of any judicial or administrative proceeding.
      • To organ procurement organizations, or to other entities for approved research purposes.
      • To a government authority, including a social service or protective services agency, authorized to receive reports of abuse, neglect or domestic violence.
    • For Any Purposes To Which You Have Not Objected. In certain limited circumstances, we may use or disclose your protected health information after we have given you an opportunity to object and you have not objected. For example, if you do not object, we may use limited information about you to maintain an office directory, to notify family members or any other person identified by you regarding issues directly related to such person’s involvement with your care or payment for that care, or in emergency circumstances.
    • For Purposes For Which We Have Obtained Your Written Permission. All other uses or disclosures of your protected health information will be made only with your written permission, and any permission that you give us may be revoked by you at any time.
  1. COMPLAINTS ABOUT MISUSE OF HEALTH INFORMATION
    You may complain either directly to us or to the Secretary of Health and Human Services if you believe that your rights with respect to our protection of your health information have been violated. To file a complaint with us, you may submit your complaint in writing that includes as many details, such as names and dates, as possible. You will not be retaliated against in any way for filing a complaint. Following is the address for filing a complaint:

Michael Ebert
Managing Partner
Fortiphi LLC
811 Cleveland Ave.

Mount Vernon, WA 98273
(800) 795-7301

  1. Our Practices Regarding Confidentiality and Security
    We restrict access to nonpublic personal information about you to those employees who need to know that information in order to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.
  1. Our Policy Regarding Dispute Resolution
    Any controversy or claim arising out of or relating to our privacy policy, or the breach thereof, shall be settled by arbitration in accordance with the rules of the American Arbitration Association, and judgment upon the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof.
  1. Contact Person For Filing Complaint or Obtaining Further Information
    For complaints about any misuses of health information or to provide further information about any issue mentioned in the notice, please contact:

Michael Ebert
Managing Partner
Fortiphi LLC
811 Cleveland Ave.

Mount Vernon, WA 98273
(800) 795-7301