Privacy Statement

Last Updated: June 2010

General Information

ByAllAccounts values and respects the privacy of our customers, partners, and other visitors to our websites. This Privacy Statement describes the types of information we may collect, under what circumstances we may collect it, how we may use it, and with whom we might share it.

Scope

ByAllAccounts operates two distinct and separate web properties: The public ByAllAccounts corporate website at www.byallaccounts.com and related sites using the byallaccounts.com domain (collectively, the “Corporate Websites”), and the ByAllAccounts service website at www.byallaccounts.net (the “Service Website”) accessible only to ByAllAccounts customers and to prospects licensed for demonstration access.

The Corporate Websites and the Service Website exist for different purposes, collect different information, and are governed by different privacy policies. See the section entitled ByAllAccounts Corporate Websites Privacy Statement for a description of the policies and practices in place for the Corporate Websites. See the section entitled ByAllAccounts Service Website Privacy and Security Statement for a description of the policies and practices in place for the Service Website.

Links to Non-ByAllAccounts Web Sites and Third Parties

The Corporate Websites and the Service Website may provide links to third-party web sites for your convenience and information. If you access those links, you will leave the ByAllAccounts site and access the third-party site. ByAllAccounts does not control those third-party sites or their privacy practices, which may differ from those of ByAllAccounts. We do not endorse or make any representations about third party web sites, and your use of those sites is not covered by the ByAllAccounts Privacy Statement. We encourage you to review the privacy policy of any third-party company before submitting your personal information.

Changes to this Privacy Statement

ByAllAccounts reviews and updates this Privacy Statement periodically. The date of the most recent revision is included above. We will post any policy changes on this page and, if the changes are significant, we will post a more prominent notice on the affect website(s) (including, for certain services, e-mail notification of the changes). Your use of the Corporate Websites accepts and assents to the terms of the ByAllAccounts Corporate Websites Privacy Statement, and your use of the Service Website accepts and assents to the terms of the ByAllAccounts Service Privacy and Security Statement. We encourage you to review the applicable section(s) of this Privacy Statement to be aware of how ByAllAccounts handles your information.

ByAllAccounts Corporate Websites Privacy Statement

This statement covers the privacy of personal information collected and used by the ByAllAccounts corporate website at www.byallaccounts.com and related sites using the byallaccounts.com domain (the “Corporate Websites”). For the statement covering the privacy and security of personal and financial information collected and used by ByAllAccounts’ services though the ByAllAccounts Service Website at www.byallaccounts.net (the “Service Website”), see ByAllAccounts Service Website Privacy and Security Statement below.

What Personal Information does ByAllAccounts Collect?

On ByAllAccounts’ Corporate Websites, you can request information, subscribe to marketing or support materials, download or view content, take a survey, enter a contest, or respond to promotional campaigns. ByAllAccounts will collect personal information from you for these purposes. Personal information for purposes of this Privacy Statement is information that identifies or can identify a specific individual or company. ByAllAccounts may collect information about individuals such as their name, address, telephone number, and email address, company, and back-office software used. Personal information collected online may be supplemented with information you provide to ByAllAccounts through other means (such as by telephone or email), with information from other sources such as trade shows or webinars, as well as with information from other industry-related databases.

ByAllAccounts does not collect personal information when you visit ByAllAccounts’ Corporate Websites unless you choose to provide it.

How does ByAllAccounts use Personal Information?

ByAllAccounts uses personal information to provide visitors to its Corporate Websites information and services and to help us better understand your needs and interests. Specifically, we use your information to welcome you, to help you learn about our products and services, and to improve the process we use to make information available. Occasionally we may use your information to contact you to complete surveys that we use for marketing and quality assurance purposes or to send promotional mailings to inform you of other products or services available.

Personal information collected on ByAllAccounts websites is processed and stored in the United States. ByAllAccounts makes no guarantee that its data privacy practices conform to the requirements of the European Union or under Safe Harbor. By entering your personal data, you consent to ByAllAccounts’ processing of your personal information.

In addition, we may use aggregate demographic information to improve our websites, but that information is not personally identifiable.

With whom does ByAllAccounts Share Personal Information?

ByAllAccounts contracts with third-party service providers and suppliers (including distributors and resellers) to deliver certain products, services and customer solutions. Examples of such services provided on our behalf are the delivery of mailings, hosting websites, hosting of webinars, processing transactions, video applications, and planning events. ByAllAccounts may share personal information with its service providers and suppliers to the extent needed to deliver the service or respond to requests for information on products or services or otherwise support the customers’ business needs. In these instances, you will not have the opportunity to opt out of having your information shared with these third party providers and suppliers, and they may contact you directly regarding such products or services.

Third party service providers and suppliers receiving personal information are expected to apply the same level of privacy protection as contained in this Privacy Statement. They are required to keep confidential and secure the personal information received from ByAllAccounts and may not use it for any purpose other than as originally intended. However, unless otherwise dictated by law or agreement, ByAllAccounts is not responsible for any improper use by such parties.

We may also disclose personal information and the content of communications in order to: (a) comply with the law or respond to lawful requests or legal process; or (b) act in good faith to protect the rights or property of our business, employees, suppliers or customers.

Some ByAllAccounts services, events and content may be co-branded and offered in conjunction with another company. If you register for or use such services, events or content, both ByAllAccounts and the other company may receive information collected in conjunction with the co-branded services.

Unless permitted by relevant laws, or you have provided consent, ByAllAccounts will not share, sell, trade or lease your personal information to others, except as provided in this Privacy Statement.

Choice and Access

ByAllAccounts does not require that visitors to ByAllAccounts Corporate Websites provide personal information. The decision to provide personal information is voluntary. If you do not provide the personal information requested, however, you may not be able to proceed with the activity or receive the benefit for which the personal information is being requested.

You can always unsubscribe or choose not to receive promotional information from us by following the specific instructions in the email you receive or by notifying us via the appropriate method below depending on which site is at issue. It may take a reasonable period of time to process your request, no longer than 30 days.

Security of Personal Information

ByAllAccounts is committed to taking reasonable efforts to secure the personal data you choose to provide us. To protect the privacy of any personal information you may have provided, ByAllAccounts employs industry-standard physical and logical access controls that change in response to the changing regulatory and threat environments including Internet firewalls, intrusion detection, anti-virus protection, and network monitoring, and, where appropriate, Secure Socket Layer (SSL) or similarly encrypted browsers.

Website Access Tracking

As is true of most web sites, ByAllAccounts collects and/or logs Internet Protocol addresses, Internet domain names, the web browser and operating system used to access its Corporate Websites, the files visited, the time spent on each page, and the time and date of each visit. ByAllAccounts collects these through the use of log files and web beacons.

ByAllAccounts also uses cookies on some of its Corporate Websites. Cookies are identifiers that can be sent from a web site via your browser to be placed on your computer’s hard drive. Thereafter when you visit a web site, a message is sent back to the web server by the browser accessing the web site. You may elect not to accept cookies by changing the designated settings on your web browser. Disallowing or blocking cookies, however, may prevent you from using certain functions and features of our sites. For example, certain materials available for download from our site contain proprietary information and are only available to “registered” visitors, where the registration is recorded using a cookie.

The information collected from the use of cookies is also used and analyzed to improve the sites, such as by gaining a better understanding of your interests and requirements regarding our website. Cookies are linked to your personal information, such as your email address or password. You can set your browser to notify you when you are sent a cookie, giving you the chance to decide whether or not to accept it. The information we collect and analyze is used to improve our service to you and personalize your web-browsing experience.

ByAllAccounts uses the services of third party vendors to help us measure the effectiveness of our advertising and how visitors use the Corporate Websites. To do this, we use web beacons and cookies provided by the vendors. The type of information we collect includes the pages visited, navigation patterns, etc. This information helps us learn things such as what product information is of most interest to our customers, and what kinds of offers our customers like to see. These third party tracking devices only collect data in the aggregate. Although the vendors log the information coming from our sites on our behalf, ByAllAccounts controls how that data may and may not be used. ByAllAccounts does not provide a way to opt out of this analysis.

Questions and Suggestions

If you have additional questions or suggestions, please contact us anytime or write to us at:

ByAllAccounts, Inc.
10 State Street
Woburn, MA 01801
Attention: Marketing
info@byallaccounts.com

ByAllAccounts Service Website Privacy and Security Statement

This statement covers the privacy and security of personal and financial information collected and used by ByAllAccounts’ services though the ByAllAccounts Service Website at www.byallaccounts.net (the “Service Website”). For the statement covering the privacy of personal information collected and used by the ByAllAccounts corporate website at www.byallaccounts.com and related sites using the byallaccounts.com domain (the “Corporate Websites”), see ByAllAccounts Corporate Websites Privacy Statement above.

Public Privacy Statement

There is nothing more important to us than protecting the privacy of our customers and safeguarding their personal and financial information (also see Security Statement). This Privacy Statement explains our practices with respect to the collection and protection of that information and addresses the concerns regarding the disclosure of personal and other information to third parties.

For the sake of this document, “personal information” is defined as any and all of the information specific to the end user that is personally submitted over the Internet or any other channel. This includes one’s name, address, phone number, email address and other information supplied when signing up for the WebPortfolio service.

What type of personal information will be collected?

During the user registration process, the following information is gathered:

  • Name
  • Email Address*

*Occasionally, we may find it necessary to contact the user regarding account status and other matters relevant to the underlying service and/or the information collected.  We will use the Name and Email Address associated with the account for this purpose; this name and address may be that of the advisor or that of the investor.

We may also send service related communications via email. This is entirely optional, and can be changed at any time from within the application.

What type of personal information will be collected?

This is usually at least a login id (which may be a user name, customer number, account number, social security number, etc), a password/PIN, an account number or other unique account identifier, and — depending on the nature of the service — a social security or tax identification number. Some financial services may require additional login or account identification information, which will also be collected. Only information required to access the financial service and to select the account(s) whose information is to be gathered is collected.

Are Cookies Used?

No, we do not use cookies of any type.

How Does a User Discontinue Service?

Use of the WebPortfolio service can be discontinued at any time via the service setup application. When the service is discontinued, all user information (current and historical) is deleted from the WebPortfolio database.

Any questions or issues about this Privacy Statement can be directed via email or by calling the support number.

Public Security Statement

We employ industry-leading technologies and policies to protect the confidentiality and privacy of each user’s financial and personal data (also see Privacy Statement), and will continue to update our systems to stay at the forefront of security processes and technologies. The following steps have been taken to provide a completely secure experience for the client:

Our People

We require that any employee with access to our production systems or to our service’s software pass both a criminal background check and a credit check before hiring. These checks are repeated on a regular periodic basis thereafter.

128-bit Secure Sockets Layer (SSL)

We use the industry standard SSL protocol currently used by leading financial service providers and banks, to encrypt and ensure the privacy of data as it moves between the user’s browser and its web servers. We support symmetric 128-bit encryption for the maximum level of security supported by the latest Microsoft and Netscape browsers.

Physical Security

All personal user information is stored in an encrypted format in our database, and is transmitted in that encrypted format within the network. Our servers and database of user information are physically protected at a highly secure third-party site. This site is protected from outside access by a series of firewalls and a comprehensive suite of security products, and is internally monitored by security personnel and under surveillance twenty-four hours a day. Only a limited number of authorized personnel are granted access to the data center, and only after successfully passing multiple forms of positive personal identification verification.

Third Party Security Review

We have completed comprehensive third-party software and hardware security audits. These audits included extensive vulnerability/intrusion analysis to verify the security of the site.

More information about these reviews is available upon request.

Third Party Policy Review

Our security and privacy policy and procedures have been reviewed by independent auditors. In addition, we keep access logs and other historical information to provide clear audit trails.