Privacy Policy and Certain Information Sharing
We appreciate the trust that you place in us and we recognize the importance of protecting the confidentiality of any non-public personal information that we may obtain about you. Obtaining this information is important to our ability to ensure accuracy in record keeping, carry out requested transactions and to generate confirmations, statements and other reports in serving you. Keeping this information secure is a top priority for us.
This Privacy Policy describes the types of non-public personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information, and the steps we take to safeguard the information to protect your privacy. As used throughout this Privacy Policy, the term “Imperial Capital” refers to Imperial Capital, LLC and its affiliates.
The information we collect about you is primarily obtained from account applications or other forms and materials you submit directly to Imperial Capital during the course of your relationship with us. We may also collect information about the transactions and interactions you engage in with or through us. In addition, we may verify information or obtain additional information about you from consumer reporting agencies or other sources. We do not share non-public personal information about you outside Imperial Capital without your consent except for the specific purposes described below, in accordance with applicable laws.
In addition, in the provision of financial services to you and subject to strict compliance with applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g., recording of telephone calls and monitoring of emails and instant messages). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.
If you deal with Imperial Capital in your individual capacity, or as a settler/trustee/beneficiary of a trust, or as an owner or principal of a company or other entity organized to invest on your behalf or on behalf of your family, etc., the typical information we collect about you would include: your name, address and other contact information; your date of birth, occupation and marital status; extensive financial information, including net worth, sources of wealth, investment experience and objectives, risk tolerance and representations concerning your financial resources; certain identifying information as may be required by laws and regulations addressing money laundering, terrorism and related matters such as information from, as applicable, your passport, alien identification card, national identity card or drivers license; and a government issued personal identifier, such as, depending on your country of residence, your Social Security number, National Insurance number, Tax File number, etc.
If you are an employee/officer/director/principal, etc., of one of our institutional customers, the typical information we collect about you would include: your name and other contact information; your role/position/title and area of responsibility; and certain identifying information as may be required by laws and regulations addressing money laundering, terrorism and related matters such as information from, as applicable, your passport, alien identification card, national identity card or drivers license.
A corporation, partnership, trust, or other legal entity may need to provide other information such as its principal place of business, local office address, employer identification number, certified articles or certificate of incorporation or other charter document, government-issued business license, partnership agreement, or trust agreement.
You are not required to supply any of the personal information that we may request, but failure to do so, or if we are unable to verify your identity, may result in us being unable to open or maintain your account or to provide services to you. While we make every effort to ensure that all information we hold about you is accurate, complete and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.
In order to provide efficient and reliable services, and to improve product and service options available to you, more than one entity within Imperial Capital may be given, or have access to your non-public personal information. When so sharing your non-public personal information we adhere to applicable legal and industry standards regarding the protection of personal information. Imperial Capital does not disclose your non-public personal information to third parties, except as described in this Privacy Policy. Disclosures to third parties may include sharing information with non-affiliated companies that perform support services for us or your account, such as facilitating your transactions with or through Imperial Capital, including those that provide professional, legal or accounting advice, perform computer related or data maintenance or processing services, audit or research services, or for credit review or reporting purposes. Non-affiliated companies that assist Imperial Capital in providing services to you are required to maintain the confidentiality of such information to the extent they receive it, and to use your non-public personal information only for the purpose of providing such services.
We may also disclose your non-public personal information to fulfill your instructions, to protect our rights and interests, or pursuant to your express consent. Finally, under limited circumstances, your non-public personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations, for instance, when responding to subpoena or similar legal process, to protect against fraud, money laundering, and to otherwise cooperate with law enforcement or regulatory authorities or with organizations such as exchanges or clearinghouses.
Except in those specific limited situations, without your consent, we will not share non-public personal information about you with other companies who may want to sell their products and services to you. For example, we do not sell customer lists and we will not sell your name to a catalogue company or telemarketer.
We limit access to your non-public personal information to authorized Imperial Capital employees and registered representatives acting on our behalf, and, as described above in Disclosures of Your Non-public Personal Information, our service providers that are held to stringent standards of privacy. We also maintain physical, electronic and procedural safeguards designed to comply with applicable laws to guard against loss, misuse, damage or modification and unauthorized access or disclosure of your non-public personal information. We update and test our technology on a regular basis in order to improve the protection of customer non-public personal information.
Imperial Capital operates a website at www.imperialcapital.com. Portions of this website require users to identify and authenticate themselves prior to accessing certain services. Generally, identification and authentication take place through the use of your user name and a password. Security is a cooperative effort between Imperial Capital and the users of Imperial Capital’s website. Please remember that your username and password are personal to you and should not be made available to any other person. Also, you should discontinue your use and notify us if you have any reason to suspect that someone else may be using them.
On this website, we may use “cookies” or other technology to gather information about the website usage to help us improve the content, usability and functionality of the website, and to remember your personal settings. “Cookies” are small text files consisting of information stored on your Web browser. This information helps us authenticate you and make it easier for you to navigate the website by, among other things, “remembering” your identity so that you do not have to input your password multiple times as you move between pages or services. You can set your Web browser to inform you when cookies are set, or to prevent cookies from being set. However, if you decline to use cookies, you may experience reduced functionality, and declining to use authentication related cookies may prevent you from using certain services.
If your relationship with Imperial Capital ends, Imperial Capital will continue to treat your non-public personal information, to the extent we retain it, as described in this Privacy Policy.
We reserve the right to change this Privacy Policy at any time to reflect changes in our practices concerning the collection and use of non-public personal information. If there are material changes to this Privacy Policy, the revised policy will be effective immediately upon posting to our external website. This version of our Privacy Policy is effective as of January 1, 2008.
If you require further information regarding our privacy policies and practices, please feel free to contact us at
compliance@imperialcapital.com or at (310) 246-3700.