Panoramix Privacy Statement
Simply put, your data is your data. We don’t sell it, trade it, market it, use it to sell other products to you or your clients, or expose it in ways not expressly permitted by you. Your data is stored in the United States unless your national regulations specifically and expressly require data storage inside and confined to the European Union.
United States federal statutes, specifically the Gramm Leach Bliley Act, require us to disclose certain information about our practices regarding the nonpublic personal information we obtain from you and about you in the ordinary course of business.
At Sapphire Software Services, Inc. (makers of Panoramix) your privacy is important to us. We are fully committed to protecting your privacy and earning your trust. First and foremost, our practices of collecting data begin with you. We do not collect your personal data, or the data of your clients, without your express permission to do so. Our practices of information gathering to provide you financial portfolio management and other services are:
- appropriate; and
- an acceptable method for the purposes of providing business solutions.
In providing all services Sapphire collects material commonly called nonpublic personally identifiable Information, PII, which generally means data provided directly by you, your custodian, your carriers, data aggregators you’ve authorized us to access on your behalf, otherwise obtained by us, or that results from transactions with us. It does not include information publicly available.
We collect information about people, accounts, holdings, and transactions plus advisory-level data in support of the functions and functionality provided by the Panoramix product, a portfolio management platform for financial advisors. We collect the following categories of nonpublic personal information in the normal course of business:
- Information we receive from you during the process of using our services;
- Information about your transactions with us, our affiliates, or others; and
- Information we receive from your custodian(s).
We may disclose any of the nonpublic personal information you share with us to affiliates, however, we will do so only to affiliates or to third parties with whom you have active business relationships, licenses, contracts, or other enforceable instruments and for which you have provided express integration and sharing permission. We are also subject to applicable law and law enforcement. This includes the following types of nonaffiliated entities:
- Rebalancing solution partners;
- Third-party CRM solutions;
- Risk Assessment solution partners;
- Client portal solution partners;
- Form letter, mass mailing, promotional materials partners;
- Direct-to-customer invoicing partners (for clients not paying from a custodial account)
- Government agencies with regulatory or court-ordered approval to access data; and
- Other third-party solution providers of your choosing.
You may also elect to export non-public personal information pertaining to your clients from Panoramix to either Microsoft Excel or CSV files using features of the software. Once this data is outside of Panoramix, you are fully responsible for its security, control, retention, and disposal.
Sapphire employees access customer’s and consumer’s nonpublic personal information only during their servicing of our products. We notify each employee of our strict employment policy against any employee accessing nonpublic personal information for any reasons other than to fulfill their job requirements or as permitted by law. All employees are also required to report to their supervisor any unauthorized use of customer’s and consumer’s nonpublic personal information of which any employee becomes aware, which initiates an investigation into the matter for appropriate disciplinary action, up to and including termination and referral to law enforcement as dictated by the circumstances.
California Consumer Privacy Act (CCPA)
Virginia Consumer Data Protection Act (VCDPA) and Similar State Statutes
Virginia residents have specific rights under the VCDPA related to the collection, use, and disclosure of their personal information. Panoramix contains the tools necessary for the advisor to comply with the statue. Sapphire expects the advisor and client to work together to review, edit, delete, and opt-out in accordance with the VCDPA. Any opt-out implementation may adversely affect the ability of the advisor to service the client and comply with other applicable laws based on the data in Panoramix alone. The performance and reporting/billing accuracy of Panoramix could be negatively impacted, depending on the nature of the opt-out. Likewise, the advisor’s ability to comply with other federal and state requirements, such as Annual ADV Amendment filing, Schedule 13F reporting, for examples, may be affected if the data is not fully housed in Panoramix. The advisor and the client need to work together to balance the client’s data privacy desires and the advisor’s ability to be of service and to comply with other legal requirements.
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