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WEBSITE
PRIVACY POLICY
Version Feburary 15, 2007
The privacy practices of this Privacy Policy apply to our
services available under the domain and subdomains of www.icrm.com
(the "Site"). We recognize that privacy is important
to our users, so we design and operate our Site with the protection
of your privacy in mind. This Privacy Policy outlines the types
of personal information we may gather when you visit our Site
or use our services, as well as some of the steps we take to
safeguard it. Please read this Privacy Policy to learn more
about the ways in which we protect, use and disclose your personal
information. By visiting the Site, you agree to be bound by
the terms and conditions of this Privacy Policy. If you do not
agree, please do not use or access the Site.
By accepting the Privacy Policy and the Terms of Use [include
hyperlink], you expressly consent to our use and disclosure
of your personal information in accordance with this Privacy
Policy. This Privacy Policy is incorporated into and subject
to the terms of the Terms of Use. This Privacy Policy is effective
upon acceptance for new users, and is otherwise effective on
February 15, 2007, for all users. |
Overview
We have adopted general policies and procedures concerning confidentiality,
proprietary data and privacy of customer personal information,
and the information we gather over the Site is protected by
those policies and procedures. Generally, we collect non-public
personal information about our clients and investors from the
following sources:
• Information received from clients or investors on applications
or other forms, including the information we collect on the
Site, and
• Information about clients' or investors' transactions
with us, our affiliates or others.
Our policy is that:
• We do not disclose any non-public personal information
about our clients or investors or former clients or investors
to anyone, except as permitted by law. We share non-public personal
information with certain service providers (including third-party
marketers that we have engaged to solicit clients for us, but
only if the client has acknowledged that the marketer has introduced
the client to us), to the extent permitted by law, and we require
those service providers to keep the non-public information confidential.
• We restrict access to non-public personal information
about our clients and investors to employees and service providers
who need to know that information to provide services to our
clients.
• We maintain physical, electronic and procedural safeguards
that comply with federal standards to guard clients' and investors'
personal information. |
Collection of Information
In general, you can browse the non-password protected sections
of the Site without telling us who you are or revealing any
personal information about yourself. We automatically track
certain information that your browser makes available whenever
you visit a website. This information includes your Internet
Protocol address, browser type, browser language and one or
more files that may uniquely identify your browser. We may use
this information to do internal research on our users' demographics,
interests and behavior to better understand, protect and serve
you and our clients. This information may include the URL that
you just came from (whether this URL is on the Site or not),
which URL you next go to (whether this URL is on the Site or
not), your computer browser information and your IP address.
We use this information to operate, develop and improve our
services.
We also may use data collection devices such as "cookies"
on certain pages of the Site to help analyze our web page flow,
measure effectiveness, and promote trust and safety. "Cookies"
are small files placed on your hard drive that assist us in
providing our services. We offer certain features that are only
available through the use of a "cookie". Cookies can
also help us provide information that is targeted to your interests.
Most cookies are "session cookies," meaning that they
are automatically deleted from your hard drive at the end of
a session. You are always free to decline our cookies if your
browser permits, although in that case you may not be able to
use certain features on the Site and you may be required to
reenter your password more frequently during a session. We use
cookies to better understand how people interact with us.
If you apply for a password to access password-restricted areas
on this Site, you must provide to us your name, mailing address,
email address, phone number, personal financial data, investment
portfolio and other investment information.
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Use and Disclosure of Information
We use the information we collect from our browser and data
collection devices such as cookies to improve our operations
and facilitate the services you request. We may use information
collected from you to measure interest, customize your experience
and enforce our Terms of Use. If you apply for a password, we
use that data to determine whether you are an accredited investor
and have sufficient sophistication, investment experience and
wealth to receive information about certain investment options.
We may share the information you provide to us to apply for
a password with a service that administers the Site and provides
certain other services to us. This sharing of information is
necessary to administer the Site. We may use your information
to send correspondence and perform services on your behalf in
connection with investment related activities.
You agree that we may use personal information about you to
analyze Site usage, improve our content and product offerings
and customize the Site's content, layout, and services. These
uses improve the Site and better tailor it to meet your needs,
so as to provide you with a smooth, efficient, safe and customized
experience while using the Site.
In connection with providing our services, it also may be necessary
for us to share information with other third parties to help
us process transactions relating to your account, including,
but not limited to, asset transfers from a financial institution
and processing or administering investment transactions and
portfolios. In certain instances, we may contract with third
parties that are not affiliated with us to perform services
for us, and, if necessary, we may disclose information about
you to those third parties solely for the purpose of carrying
out their assigned responsibilities. In those circumstances,
we require such third parties to treat your private information
with the same degree of confidentiality that we do. In some
instances, the third-party service provider may collect information
directly from you. In these cases, you will be notified of the
involvement of the service provider, and all additional information
you provide them and their additional uses will be strictly
up to you. If you provide additional information to a service
provider directly, their use of your personal information is
governed by their applicable privacy policy.
We may also share information about you if we believe that disclosure
is required under law. For example, we may need to disclose
information in response to a subpoena or to cooperate with regulatory
or law enforcement authorities.
We cannot ensure that all of your private communications and
other personal information will never be disclosed in ways not
otherwise described in this Privacy Policy. By way of example
(without limiting the foregoing), we may be forced to disclose
personal information to the government or third parties under
certain circumstances, third parties may unlawfully intercept
or access transmissions or private communications, or service
providers may abuse or misuse your personal information that
they collect from the Site. Therefore, although we use industry
standard practices to protect your privacy, we do not promise,
and you should not expect, that your personal information or
private communications will always remain private.
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Control of Your Password and Personal Information
You are responsible for all actions taken with your user name
and password. Therefore, we recommend that you do not disclose
your password to any third parties. You may not allow others
to use your user name or password to access or use any part
of this Site. If your password has been compromised for any
reason, you should contact us immediately for a new password.
You can review and change the information you submit to us by
contacting us at info@icrm.com.
You can change your User ID, email address, contact information,
financial information, other personal information and user preferences.
You must promptly update your personal information if it changes
or is inaccurate.
Upon your request, we will deactivate your password and remove
your contact information and financial information from our
active databases. To make this request, email info@icrm.com.
Your password will be deactivated promptly based on your account
activity and in accordance with our deactivation policy and
applicable law.
We will retain in our files the personal information you have
asked us to remove from our active databases to prevent fraud,
resolve disputes, troubleshoot problems, assist with any investigations,
enforce our Terms of Use and comply with legal requirements.
Therefore, you should not expect that your personal information
will be completely removed from our databases in response to
your requests. However, such personal information will only
be available to select employees, service providers and governmental
persons or entities.
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Security
Your information is stored on our servers located in the United
States. We use procedural and technical safeguards to protect
your personal information against loss or theft as well as unauthorized
access and disclosure to protect your privacy, which may include
encryption, "firewalls" and Secure Socket Layers.
We treat data as an asset that must be protected against loss
and unauthorized access. We employ security techniques to protect
such data from unauthorized access by users inside and outside
the company. However, "perfect security" does not
exist on the Internet. |
Children
Children (persons under the age of 18) are not eligible to use
the Site. |
Conditions Of Use
If you choose to visit the Site, your visit and any dispute
over privacy is subject to this Privacy Policy and our Terms
of Use, including limitations on damages and application
of the law of the State of California. If you have any concern
about privacy, please send a thorough description to info@icrm.com. |
Changes to this policy
Please note this Privacy Policy may change from time to time.
We may amend this Privacy Policy at any time by posting the
amended terms on the Site. All amended terms shall automatically
be effective 30 days after they are initially posted on the
Site.
If you have any additional questions, please feel free to contact
us any time at info@icrm.com.
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