Last modified: December 9, 2019
EM Securities LLC and Evolution Media Capital LLC (Collectively, “Company” or “We”), respect your privacy and are committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit the website www.evolutionmediacapital.com (the “Website”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
- on the Website;
- in email, text, chat and other electronic messages between you and the Website; and/or
- through mobile and desktop applications you download from the Website, which provide dedicated non-browser-based interaction between you and the Website.
It does not apply to information collected by:
- us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
- any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.
Information We Collect About You and How We Collect It
We collect several types of information from and about users of the Website, including information:
- by which you may be personally identified, such as name, user names, screen names, e-mail address, and links to your social media accounts (“personal information”);
- that is about you but individually does not identify you, such as user employer or the company or business you are affiliated with;
- Customer Identification Program Information (“CIP Information”) Company collects about each customer; and/or
- about your internet connection, the equipment you use to access the Website and usage details.
We collect this information:
- directly from you when you provide it to us or when you apply for, access, and use financial products and services offered by Company, whether in person, by telephone, or electronically;
- automatically as you utilize the Website (information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies); and/or
- from third parties, for example, our business partners.
Information You Provide to Us. The information we collect on or through the Website may include:
- information that you provide by completing forms on the Website. This includes information provided at the time you register to use the Website and any other information you choose to provide Company via the Website;
- records and copies of your correspondence (including email addresses), if you report a problem or otherwise contact Company;
- your responses to surveys that we might ask you to complete for research purposes; and/or
- your search queries on the Website.
Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with the Website, we use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- details of your visits to the Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website; and/or
- information about your computer and internet connection, including your IP address, operating system, and browser type.
We maintain or associate information we collect automatically with personal information we collect in other ways or receive from third parties. It helps us to improve the Website and to deliver a better and more personalized service, including by enabling us to:
- estimate our audience size and usage patterns;
- store information about your preferences, allowing us to customize the Website according to your individual interests;
- speed up your searches; and/or
- recognize you when you return to the Website.
The technologies we use for this automatic data collection include:
- Flash Cookies. Certain features of the Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information Section below.
- Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Company, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information or CIP Information:
- to present the Website and its contents to you;
- to provide you with information, products, and/or services that you request from us, including maintaining accounts with Company, processing transactions requested by you, and administering Company’s business;
- to fulfill any other purpose for which you provide it;
- to provide you with notices about your account;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
- for fraud prevention or verification purposes;
- to allow you to participate in interactive features on the Website;
- to notify you about changes to the Website or any products or services we offer or provide though it;
- in any other way we may describe when you provide the information; and/or
- for any other purpose with your consent.
We may also use your information to contact you about Company’s or its affiliates’ products or services that may be of interest to you. If you do not want us to use your information in this way, please either check the relevant box located on the form on which we collect your data (the registration form) or adjust your user preferences in your account profile. For more information, see Choices About How We Use and Disclose Your Information Section below.
Disclosure of Your Information
We may disclose aggregated anonymized information about our users without restriction.
- to our subsidiaries and affiliates;
- to contractors, service providers, and other third parties we use to support our business, including Google Analytics or Elevated Third;
- to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about the Website users is among the assets transferred;
- to fulfill the purpose for which you provide it (For example, if you give us an email address to use the “email a friend” feature of the Website, we will transmit the contents of that email and your email address to the recipients.);
- for any other purpose disclosed by us when you provide the information; and/or
- with your consent.
We may also disclose your personal information:
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- if we believe disclosure is necessary or appropriate to protect the rights, property, or interests of Company, our clients, or others (This includes exchanging information with other companies and organizations for the purposes of fraud protection and verification purposes.).
International Data Transfers
When you use the Website and provide information to Company through the Website, your information will be transferred to the United States. The United States has not received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Company has executed agreements between its affiliates and subsidiaries in accordance with Article 46 of the GDPR. Company also relies on derogations for specific situations set forth in Article 49 of the GDPR in order to transfer personal information across international borders outside of Company, its affiliates, and subsidiaries. In particular, Company transfers personal information across international borders only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Company in a manner that does not outweigh your rights and freedoms.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Promotional Offers from Company. If you do not wish to have personal information collected via the Website used by Company to promote Company’s or its affiliates’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration form), by logging into the Website at any other time and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes, or by sending us an e-mail stating your request to firstname.lastname@example.org. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
To the extent required by law, Company provides you with (i) reasonable access to the personal information collected through the Website, and (ii) the ability to review, correct, export, and delete such personal information. Please contact us using any of the methods identified in the “Contact Information” section if you would like to exercise your individual rights and for information on any fee required to obtain copies of your personal information. We may need to obtain or confirm certain personal information in order to accommodate your request. We will not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of the Website that are California residents to request certain information regarding our use of personal information for direct marketing purposes. To make such a request, please send an e-mail to email@example.com or write us at: 2000 Avenue of the Stars, Los Angeles, CA 90067.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Evolution Media Capital LLC
2000 Avenue of the Stars
Los Angeles, CA 90067
European Union: You have the right to lodge a complaint with a supervisory authority if you believe we have processed your personal data in a manner inconsistent with your privacy rights. We kindly request that you contact us first so that we may address your concern. You can request copies of Company’s GDPR Article 46 agreements from us using the contact information above.