We are committed to maintaining the privacy and confidentiality of our customers’ personal information. In the course of offering and providing financial information and services, we collect and maintain certain personal information about you. This information can come from information you provide on applications or other forms, through your inquiries by mail, e-mail, or telephone, or by other means.This policy explains what personal information we collect and how we use and share such personal information. It also explains what you can do to limit the use and sharing of your personal information. We do not disclose personal information about our customers to non-affiliated third parties, except as described below.
Composer may periodically collect information from you through automated means. When you browse our site, use our services, or read our emails or newsletters, we may use “cookies” or other online tracking mechanisms (including pixel tags, web beacons, clear GIFs and device fingerprints) in order to provide better service, facilitate your use of the site or services, store online preferences, track usage of the site or services, tailor the marking of business services, or enhance security. Composer does not store login credentials used to link Account information.Some of our cookies are used for web analytics and intelligence about our site. We may also use web beacons or other technologies for similar purposes and we may include these in marketing email messages or our newsletters in order to determine whether messages have been opened and links clicked on. Web beacons do not place information on your device but may work in conjunction with cookies to monitor online activity.By using our site or applications you agree that we can place cookies on your device and use other online tracking mechanisms as explained in this privacy notice. You may be able to control your acceptance of cookies and similar technologies on a website, and most devices and browsers offer their own privacy settings for cookies. You will need to manage your cookie settings for each device and browser you use. If you do not accept cookies, you may experience some inconvenience in your use of some sites and online products. For example, a website may not be able to recognize your device and you may need to answer challenge questions or provide additional information each time you log on.To help us protect against fraud, provide our services to you, and improve our services, we collect location data, including current and historical information concerning a user’s geographic location, GPS location, transaction location, and IP addresses that are used in conjunction with our services. We collect your precise location data with your permission, and use that information, for example, to help protect against fraud by detecting and declining debit card transactions that may occur far away from your device’s location. You may decline to allow us to collect such geolocational information, in which case Composer may not be able to provide certain features or functionalities to you.We also may obtain information on the device you use, including the Universally Unique Identifier, advertising identifier (“IDFA” or “AdID”), operating system and version, wireless carrier, and network type. This information is used to identify customer device issues and for marketing purposes.If you subscribe to any of our newsletters , we will use your name and email address to send the newsletter to you. You can unsubscribe at any time following the instructions at the bottom of these emails or you can contact us at the information below. We also may collect information from you derived or resulting from voluntary surveys.By providing your phone number you expressly consent to Composer and/or its agents calling or texting you using an automated telephone dialing system and/or prerecorded messages, even if you incur charges for receiving such communications. You may request to be removed from phone or text communications by emailing email@example.com or informing the agent that contacts you.We may access your contact list, with your permission, on your mobile device or in your email accounts so that you can identify your contacts using our services and direct the invitation of your contacts for our services. We store and use this information to suggest referrals or connections and for other reasons related to our services.
With regard to our internal security procedures, we restrict access to your personal and account information to those employees who “need to know” the information in order to provide products and services to you. We maintain reasonable physical, administrative, and technical safeguards to protect your personal information. We conduct regular internal audits of our business practices and procedures in order to protect your personal information.We may also disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
Retention of Your Information
We do not knowingly collect or solicit any information from anyone under the age of 18 on our services. In the event that we learn that we have inadvertently collected personal information from a child under age 18, we will take reasonable steps to delete this information. If you believe that we might have any information from a child under 18, please contact us at firstname.lastname@example.org.
California Privacy Rights
Updates to this Policy
What does Composer Technologies Inc. do with your personal information?
Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. What? The types of personal information we collect and share depend on the product or service you have with us. This information can include:• Social Security Number and income· Account balances and transaction history· Investment experience and checking account information
When you are no longer our customers, we continue to share your information as described in this notice. How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reason Composer chooses to share; and whether you can limit this sharing.
Reasons we can share your personal informationDoes Composer Holdings Inc. share?Can you limit this sharing?
For our everyday business purposes –such as to maintain your account(s) or respond to court orders and legal investigations.YESNOFor our marketing purposes — To offer our products and services to youYESNOFor joint marketing with other financial companiesNOWe don’t shareFor our affiliates everyday business purposes — information about your transactions and experiencesYESNOFor our affiliates to market to youYESYESFor nonaffiliates to market to youNOWe don’t shareTo limit our sharingEmail us at email@example.com with the form below.
If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice.
However, you can contact us at any time to limit our sharingQuestions?Email us at firstname.lastname@example.org.
Who we are
Who is providing this notice?Composer Technologies Inc. (also “Composer”) and Composer Technologies Inc. (USA) (also “Composer”)
What we do
How does Composer collect my personal information?We collect your personal information, for example, when you:• Open an account or give us your income information,• Seek information about your investment or retirement portfolio,
We also collect your personal information from others, such a affiliates, or other companies.How does Composer protect my personal information?To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.Why can’t I limit all sharing??Federal law gives you the right to limit only:• Sharing for affiliates’ everyday business purposes – information about your creditworthiness• Affiliates from using your information to market to you
State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under certain state laws.What happens when I limit sharing for an account I hold jointly with someone else??Your choices will apply to everyone on your account.
AffiliatesCompanies related by common ownership or control. They can be financial and nonfinancial companies.
Our affiliates include companies with a Composer name; such as Composer Technologies Inc. (USA).NonaffiliatesCompanies not related by common ownership or control. They can be financial and nonfinancial companies.
Composer does not share with nonaffiliates so they can market to you.Joint marketingA formal agreement between nonaffiliated financial companies that together market financial products or services to you.
Composer doesn’t jointly market.
Other important informationState and International Laws
For Vermont Residents: In accordance with Vermont Laws, we will not share information we collect about Vermont residents with companies who are not affiliates, except as permitted by law, such as with your consent or to service your accounts. We will not share information about your creditworthiness with our affiliates without your authorization or consent, but we may share information about our transactions or experiences with you with our affiliates without your consent.
For Nevada Residents: Nevada law requires us to disclose that you may request to be placed on Composer’s internal “do not call” list at any time by calling (312) 600-2883, and that we are providing this notice to you pursuant to state law, and that you may obtain further information by contacting the Nevada Attorney General, 555 E. Washington Ave., Suite 3900, Las Vegas, NV 89101; phone 702-486-3132; email BCPINFO@ag.state.nv.us.
For California Residents: In accordance with California law, we will not share information we collect about you with nonaffiliates, except as allowed by law. For example, we may share information with your consent or to service your accounts. Among our affiliates, we will limit information sharing to the extent required by California law.
With any investment, your capital is at risk. The value of your portfolio with Composer can go down as well as up. Past performance is no guarantee of future results.