Privacy Policy
At Crowbourne Capital (2019) Corp. (“Crowbourne”) we are committed to protecting the privacy and confidentiality of personal information in our possession and control. This Privacy Policy (the “Policy”) explains to you our policies and procedures regarding the collection, use and disclosure of your personal information through the use of our website available at crowbourne.com, including all subpages and successor pages (collectively referred to as the “Site”), as well as other interactions with our clients and prospective clients. By providing information to us through the Site you agree to be bound by the Policy. If you do not agree to the terms of the Policy, please do not use the Site. The Policy may be updated from time to time and any updates will be posted to our Site. We encourage you to refer to this Policy often to obtain the latest information respecting our personal information practices.
Why does Crowbourne collect personal information?
Crowbourne collects personal information to provide and improve our Site, its features, and content and allow users to enjoy and easily navigate the Site.
Further, we are required to collect personal information in order to introduce clients and prospective clients to our network of independent financial professionals, our portfolio management referral partners, and any other service providers with which we conduct business (the “Service Partners”).
What types of personal information does Crowbourne collect?
In order to facilitate introductions to our Service Partners, Crowbourne will collect information to establish your identity, such as your name, address, phone number, occupation, title, business phone number, and email address.
Information pertaining to business clients will include your business name, address, phone number, email address, industry type, and may include detail(s) on the owner(s), operator(s), and director(s).
Crowbourne may collect information you provide on an application, such as your annual income, net worth, place of employment, marital status, number of dependents, and investments.
Additional information may be requested to help us determine your eligibility for certain products and services offered by our Service Partners.
How does Crowbourne collect personal information?
Except as otherwise set out in this Privacy Policy, we collect personal information directly from you, or through one of our referral partners.
If you are referred to Crowbourne by one of our referral partners in order to access the services made available through Crowbourne, we may collect your name, address, email address, and any other relevant information from the introducing referral partner(s) only upon your consent.
Safekeeping of personal information
Crowbourne takes the security of your Personal Information very seriously but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure.
Crowbourne maintains reasonable administrative, technical and physical safeguards in an effort to protect personal information in our custody and control against unauthorized access, use, modification and disclosure of. We train our employees to keep clients’ personal information strictly private and confidential. We ensure that departing staff understand they remain contractually obliged to respect the privacy of clients’ personal information.
We have personal information retention processes designed to retain personal information of our clients and prospective clients for no longer than necessary for the purposes set out in this Privacy Policy or to otherwise meet legal requirements.
We will make any legally required disclosures of any breach of the security, confidentiality or integrity of your Personal Information in the most expedient time possible and without unreasonable delay taking into account the legitimate needs of law enforcement or any measures necessary to determine the scope of the breach and restore the reasonable integrity of our data system.
Who is your personal information shared with?
We will not disclose, trade, rent, sell or otherwise transfer your personal information, without your consent, except as otherwise set out in this Privacy Policy.
Under certain circumstances, your personal information may be shared among Crowbourne employees, outside service providers, or other third parties, and only on a “need to know” basis in order to fulfill their job and/or service requirements.
Our employees
All employees of Crowbourne are bound under the policies and procedures of Crowbourne to maintain the confidentiality of your personal information and are available to address any questions or concerns you may have. Access to your information is restricted to authorized employees who have a legitimate business purpose for accessing it. Unauthorized access to and/or disclosure of client information by an employee of Crowbourne is strictly prohibited. All employees are required to maintain the confidentiality of client information at all times.
Outside service providers
Crowbourne provides access to third-party portfolio management firms through our network of independent financial professionals. These third-party service providers may at times be responsible for processing or handling personal information and are provided only the information necessary to perform the services. Crowbourne ensures that all third-party service providers have a comparable level of protection for your personal information.
Other third parties
We will only share your information with other third parties under the following special circumstances:
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To respond to valid and authorized information requests from domestic and international authorities.
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As permitted or required by law, to comply with laws, regulations, subpoenas, or court order.
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To identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) Crowbourne’s rights or property or anyone else that could be harmed by such activities.
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To protect the personal safety of employees, clients, or other third parties on Crowbourne’s property.
Use of personal information for communication purposes
If you contact customer service with a comment, question or complaint by email, telephone or webinar (video chat), you may be asked for information that identifies you (such as your name, address and a phone number) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may retain this information to assist you in the future and to improve our customer service and, product and service offerings.
From time to time, we may obtain your consent to send you email, and other communications about Crowbourne services or events that may be of interest to you. You can opt-out of receiving marketing and promotional email from us by following the unsubscribe instructions contained in each of our email communications.
We collect and use information when you visit our website
When you use or visit the Site, our servers automatically record information that your browser sends whenever you visit a website.
Use of Cookies
Like many websites, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard drive for record-keeping purposes. Persistent cookies are used to save your login information for future logins to the service on our Site. Session ID cookies are used to enable certain features of our Site, to get a better understanding of how you interact with the Site and to monitor aggregate usage by NPWI users and web traffic routing on the Site. Unlike persistent cookies, session ID cookies are deleted from your computer when you log off from the Site and then close your browser. By changing its options, you can instruct your browser to stop accepting cookies or to prompt you before accepting cookies from the website you visit. However, if you do not accept cookies, you may not be able to use all portions of the Site.
Website Analytics
The data we monitor and collect may include information such as your computer’s Internet Protocol (“IP”) address, pages of our Site that you visit, the time spent on those pages, information you search for on our Site, access times and dates, and other statistical information.
We may use third parties to help us gather and analyze information about the areas visited on the Website in order to better understand, evaluate and improve the user experience and the convenience of the Website.
Crowbourne and links to third party websites
Our Site may contain links to other websites that we do not own or operate. Also, links to our Website may be featured on third-party websites. Except as provided herein, we will not provide any of your personal information to these third parties without your consent. We provide links to third-party websites as a convenience to you. These links are not intended as an endorsement of or referral to the linked websites. We do not have any control over such websites, and as such we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.
Our Privacy Officer
Crowbourne has appointed Kyle Jorgensen, our President, as Privacy Officer who is responsible for overall privacy governance. The Privacy Officer may be contacted at kjrogensen@crowbourne.com.