As agents of products and services that involve compiling personal and sometimes sensitive information, protecting the confidentiality of that information is a top priority for PURE and its employees. Whether you are a current, former, or potential client, we believe that you should know about the information we collect, our efforts to safeguard it, and situations in which we may share information with select business partners. Our website privacy statement is also available at www.purefinancial.com.
We collect only the information necessary to identify needs and appropriate solutions and services for our clients.
PURE may collect personal information and sensitive personal information that helps us serve your financial needs, provide high standards of service, develop, and offer new services, products, and strategies for our clients and to fulfill our legal and regulatory requirements.
“Personal information” is information that identifies, relates to, or could reasonably be linked with you or your household. For example, it could include your name, social security number, email address, records of products purchased, internet browsing history, geolocation data, and inferences from other personal information that could create a profile about your preferences and characteristics.
Personal information does not include publicly available information that is from federal, state, or local government records, such as professional licenses and public real estate/property records. The definition of publicly available information also includes information that a business has a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media, or certain information disclosed by a consumer and made available if the consumer has not restricted the information to a specific audience.
“Sensitive Personal information (SPI)” pertains to any private information that divulges any of the following: (a) Personal identification numbers, including social security, driver’s license, passport, or state ID card numbers; (b) Account or debit or credit card numbers combined with passwords or codes that would enable access to the accounts; (c) a consumer’s exact geolocation; (d) consumer’s racial origin, religious beliefs, or union membership; (e.g.) a consumer’s mail, email, or text message content unless the information was intentionally sent to the business.
The information collected varies depending on the products and services you request and may include the following:
- Information provided in personal meetings, telephone interviews, applications, and related forms such as name, social security number, annual income, or other personal and financial information helpful to determine an appropriate product or service.
- Responses from your employer, benefit plan sponsor, or association regarding any group products we may provide, for example name, age, address, and social security
- Information about your relationship with us, such as products or services purchased, and account balances (if applicable), which we may obtain in writing, during telephone or internet transactions or from data gathering software used when you access our web
We maintain safeguards to ensure information security.
We have implemented security standards and processes, including physical, electronic, and procedural safeguards to ensure that access to client information is limited to employees or client authorized professional service providers, who may need access to do their jobs. All persons with access are required to respect the confidentiality of all client information.
We limit how, and with whom we share information.
All financial companies need to share clients’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their clients’ personal information; the reasons PURE chooses to share; and whether you can limit this sharing .
We do not sell lists of our clients or client information. We do not disclose client information, with the exception of companies or individuals we hire to provide specific services for us and our clients, as described below.
We share client information for the following reasons:
To be more specific, there are various circumstances where we may need to process your data or disclose your personal information as follows:
- Business Transfers: Your information may be shared or transferred during negotiations of any merger, financing, sale of company assets, or acquisition of all or part of our business to another company.
- Vendors, Consultants, and Other Third-Party Service Providers: We may share your data with third-party vendors, service providers, contractors, or agents who perform services on our behalf and require access to your information to do so. Examples include payment processing, email delivery, data analysis, hosting services, customer service, and marketing efforts, as well as compliance with legal or regulatory requirements, and endorsement to financial institutions. We may also allow selected third parties to use tracking technology on our website to collect data about how you interact with our website over time, which may be used to analyze and track data and better understand online activity. We do not share, sell, rent, or trade your information with third parties for their promotional purposes, except as described in this policy. All contracts or agreements with these third parties will contain provisions requiring them to protect consumer data privacy rights and comply with applicable federal data privacy laws.
- Business Partners and Non-Affiliates: We may share your information with our business partners and non-affiliates to provide you with better services or promotions. In such cases, we require our business partners and non-affiliates to protect consumer data privacy rights in accordance with applicable federal data privacy laws.
Specific Privacy Rights for California Residents
California residents are granted specific rights regarding access to personal information.
Who qualified as a California resident?
The California Code of Regulations defines a “resident” as:
- every individual who is in the State of California for other than a temporary or transitory purpose and,
- every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose All other individuals are defined as “non-residents.”
Categories of Information Shared in the Last Twelve (12) Months
We have collected the following categories of personal information in the last twelve (12) months. The categories of information are based on the non-exclusive categories under the CCPA and CPRA.
In summary, California residents have the following privacy rights:
- Right to Access – If you are a California resident, you have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, and sell.
- Right to Correct and Delete Inaccurate Personal Information – If you are a California resident, you have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.
- Right to Opt Out of Sale of Personal Information – If you are a California resident, you have the right to “opt out” of the “sale” of your “personal information” to “third parties” (as those terms are defined in the CCPA).
- Right to Delete. – If you are a California resident, you have a right to request the deletion of their personal information held by businesses and requires those businesses to comply with such requests, subject to certain exceptions.
- Right Against Discrimination – against Californians who exercise their privacy right under the law.
- Process to Make a CCPA Request – Making Access and Deletion Requests: To make an access or deletion request, please use the contact information provided below Before completing your request, we may need to verify your identity. We will send you a link to verify your email address and may request additional documentation or information solely for the purpose of verifying your identity.
- Instructions for Authorized Agents Making Access and Deletion Requests – You may also use an authorized agent to submit an access or deletion request on your behalf. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with California probate law. Authorized agents that are business entities must be registered with the California Secretary of State to conduct business in California. Before completing requests from authorized agents, we may contact you directly to confirm you’ve given your permission and/or to verify your identity.
- Shine the Light Act – If you are a California resident, California Civil Code Section 1798.83 permits you to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
Making Requests to “Opt Out” of the “sale” of “Personal Information”
Please note that PURE DOES NOT sell personal information and notice will be given if there is a change in this policy.
If there is such a change a policy wherein, we sell personal information, you may submit a request to opt out of the sale of your personal information, you may visit our “Do Not Sell My Personal Information” page which will automatically be added in our official website if there is a change in policy. You may also send an email to the contact information provided below to request the same.
You may also use an authorized agent to submit a request to opt out on your behalf if you provide the authorized agent signed written permission to do so. Authorized agents may submit requests to opt out by email.
Information from Minors
We do not knowingly collect data from or market to children under 18 years of age. Clients, when providing their personal information, are asked to confirm that they are 18 years or older.
To Limit Our Sharing
Call us at 1 (877) 222-6044
By email: email@example.com
By mail at 3131 Camino Del Rio North, Suite 1550 San Diego, CA 92108
We verify who you are before giving you access to your data or making any changes to it by asking for certain information or documents to prove your identity.
We will respond to your request within 45 days of verifying your identity. If we require more time to respond, we will notify you of the reason and extension period in writing. We may require you to provide additional information to verify your identity and the authenticity of the request. We will not discriminate against you for exercising your consumer rights.
If you are a new client, we can begin sharing required information immediately upon the start of our relationship. When you are no longer our client; we may be required to continue to share your information as described in this policy. However, we are limited to sharing only the information required by law or regulation, such as in response to a subpoena or to comply with industry regulators.
Last updated: April 2023.
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