Privacy Policy

Applicability of this policy

This policy applies to visitors to the www.HILLCREST WEALTH ADVISORS.com website (the “Site”).  If you are present in the European Union when you access the Site, please refer to the European Union Privacy Addendum.

HILLCREST WEALTH ADVISORS - NY, LLC is committed to maintaining the privacy and security of your personally identifiable information.  As part of our commitment to information privacy, we have adopted this Privacy Policy to inform you of our information gathering practices and the ways in which we may use the information we receive.  This Privacy Policy applies to all personal information submitted to HILLCREST WEALTH ADVISORS for use with or in connection with its website located at http://www.HILLCREST WEALTH ADVISORS.com.  By providing your personal information to us on our Site, you consent to the collection and use of that information in accordance with this Policy.

Information We Collect and How We Use It

“Personal Information” means any information by which you can be identified, including name, postal address, e-mail address, location IP address and telephone number.

HILLCREST WEALTH ADVISORS gathers Personal Information about you in order to respond to your requests and provide you with appropriate information about HILLCREST WEALTH ADVISORS’s products, services, and events.  The information is collected and used in the following ways:

Requests for Information: When you enter information into the “Contact Us” online inquiry form on our Site to request general information about HILLCREST WEALTH ADVISORS’s products, services, and events, or to register for an event, you may be required to provide some or all of the following Personal Information: name, email address, company name and location, title, telephone contact information.

Submission of Requests for Information about Jobs at HILLCREST WEALTH ADVISORS: When you send an email to the email address listed on our Site for our Human Resources department.

HILLCREST WEALTH ADVISORS may use this information to respond to your requests, including retaining information in order to better respond to further requests or inquiries we receive from you.  HILLCREST WEALTH ADVISORS may also send you information from time to time regarding products, services and events that we think may be of interest to you.  Please see the “User Choice” section below for instructions on how to change your mailing preferences if you do not wish to receive such information.

Contacting Us By E-mail: When you send HILLCREST WEALTH ADVISORS an e-mail from our Site, you may be required to provide some or all of the following Personal Information: name, email address, company name and address, title, telephone contact information.  HILLCREST WEALTH ADVISORS may use this information to respond to your requests, including retaining the information you provide, the content of your e-mail, our response, and any follow-up questions and further requests and inquiries you may have.  HILLCREST WEALTH ADVISORS may also use information sent by e-mail for market research and to improve our products and services.

Employment: If you choose to apply for employment with HILLCREST WEALTH ADVISORS online, you will be required to provide your name, address, contact information and work authorization status, and upload a resume or curriculum vitae (CV).  HILLCREST WEALTH ADVISORS will only use this information to match you with available employment opportunities.

Cookies: HILLCREST WEALTH ADVISORS uses technology such as “cookies” on our Site that helps us analyze the use of our website.  “Cookies” are small files placed on your hard drive that assist us in providing our services.  Certain features on our Site may only be available through the use of “cookies.”

Other Web Technologies: HILLCREST WEALTH ADVISORS uses technology, including through the use of third party analytics providers, that lets us know what type of browser you are using, the website from which you enter our Site, the type of device you are using, the pages you view as you visit the Site, and other information related to your technology or use of the Site.  This technology does not identify you personally – it simply helps us compile aggregate statistics about our guests and their use of our Site.  We use these statistics and analytics services to improve our Site design and content, to evaluate how the Site is used, analyze traffic patterns, and to prepare and deliver our marketing programs and materials.

To Whom We Disclose Information

HILLCREST WEALTH ADVISORS will not share your Personal Information with third parties, except as follows:

• HILLCREST WEALTH ADVISORS will share your Personal Information with some of its affiliates, and business partners and service providers who perform services for us.
• HILLCREST WEALTH ADVISORS will share your Personal Information with others when you have given us permission to do so in writing or through user preferences selected on the Site.
• HILLCREST WEALTH ADVISORS will disclose Personal Information without your permission when we believe in good faith that such disclosure is required by law or is necessary to investigate and protect against harmful activity to HILLCREST WEALTH ADVISORS, its customers, its employees and others, or its property, including this Site.
• If HILLCREST WEALTH ADVISORS or a substantial part of its assets are transferred to another entity (by merger, consolidation, sale or bankruptcy process), Personal Information may be one of the assets transferred.
• HILLCREST WEALTH ADVISORS may share aggregate data developed from Personal Information with third parties for research, education or marketing purposes.  Such aggregate data will not include any information that can be used to identify any particular individual. User Choice Regarding Collection, Use and Distribution of Personal Information
• The extent and type of Personal Information HILLCREST WEALTH ADVISORS collects depends on the information you provide to us through our e-mail and/or through the registration processes on the Site. You may choose not to provide us with any Personal Information

Third Party Links

This Site may contain links to other websites maintained by third parties over whom HILLCREST WEALTH ADVISORS has no control.  When you click on one of those links, you are accessing a website that is not owned, operated, or controlled by HILLCREST WEALTH ADVISORS, and your visits to those websites are not covered by this Privacy Policy.  The operator of such website may have its own privacy policy (which we encourage you to read carefully), and that policy will govern the collection and use of your data on that website.  HILLCREST WEALTH ADVISORS does not share your Personal Information with these parties and is not responsible for their privacy policies.

Our Commitment to Children’s Privacy

HILLCREST WEALTH ADVISORS understands the importance of protecting children’s privacy.  For that reason, we do not collect and maintain information from those we actually know are under 13 years of age, and no part of the Site is structured to attract anyone under 13 years of age.

Data Security

HILLCREST WEALTH ADVISORS will take reasonable precautions to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration, and destruction.  However, these measures, standing alone, are not sufficient to ensure the security of your Personal Information.  It is also important for you to guard against unauthorized access to your passwords and the unauthorized use of your computer.

Privacy Shield

HILLCREST WEALTH ADVISORS is significantly invested in protecting our clients private data, which is why we comply with the EU-U.S. Privacy Shield Framework maintained by the United States Department of Commerce. This framework details the proper collection, use, and retention of personal data transferred from the EU to the U.S. For more information, please review the linked document here.

Your California Privacy Rights

Individual customers who reside in California and have provided their Personal Information to HILLCREST WEALTH ADVISORS may request information about our disclosures of certain categories of Personal Information to third parties for their direct marketing purposes.  Such request must be submitted to us at the following address: 101 Crawfords Corner Road, Suite 1311, Holmdel NJ 07733, attn: dan.yu@hcwadvisors.com.  Within 30 days of receiving such a request, we will provide a list of the categories of Personal Information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties.  This request may be made no more than once per calendar year.  We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.

HILLCREST WEALTH ADVISORS tracks your movement through our website through use of “cookies.” Cookies help assist us provide services to visitors to our website.  You should be aware that certain features on our Site may only be available through the use of “cookies.”

Hillcrest Wealth Advisors does not track your activities online over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.

Effective Date and Changes to Privacy Policy

This Privacy Policy was effective on August 17, 2018.

We reserve the right, at any time and without notice, to add to, change, update, or modify this Privacy Policy simply by posting such change, update, or modification on this Site.  Any such change, update, or modification will be effective immediately upon posting on the Site.  The date in this section will be updated whenever this Privacy Policy is changed.  You agree that we may notify you about material changes in the way we treat Personal Information by placing a notice on the Site.

If you have any additional questions after reading this Policy or would like to give us feedback, please e-mail us at dan.yu@hcwadvisors.com.

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European Union Addendum To Privacy Policy

This Addendum to our Privacy Policy applies to you only if accessing the Site from within the confines of the European Union.   THIS ADDENDUM TO THE PRIVACY POLICY DOES NOT APPLY TO THE UNITED STATES OF AMERICA OR ANY OF ITS TERRITORIES. 

Additional Information requirements pursuant to Art. 13 GDPR (EU General Data Protection Regulation)

This privacy policy addendum applies solely to our processing of the personal data of data subjects who are in the European Union, where they use, browse or interact with our Site.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

This privacy policy addendum is issued on behalf of HILLCREST WEALTH ADVISORS - NY, LLC, so when we mention “HILLCREST ADVISORS", we", "us" or "our" in this privacy policy, we are referring toHILLCREST WEALTH ADVISORS - NY, LLC responsible for processing your data. HILLCREST WEALTH ADVISORS - NY, LLC is the controller and responsible for this Site.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1. The data we collect about you on or through the Site
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

1. • Identity Data includes first and last name and company name.
   • Contact Data includes email address.
   • Technical Data may include internet protocol (IP) address, geolocation data, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Site.
   • Usage Data may include information about how you use our website and services.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).  Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in forms on the Site, or by corresponding with us by email using one of the email addresses posted to our Site. This includes personal data you provide when you:

• Submit a question or comment through the “contact us” feature on our Site; or
• When you send an email to any email address posted to our Site.

Automated technologies or interactions. As you interact with our Site, we will automatically collect Technical Data about you, your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.  We may also receive Technical Data about you if you visit other websites employing our cookies, if any.  A list of cookies we use on our Site is available upon request.

We use the following analytics providers to help us understand traffic and manage our Site:

By using our Site, you consent to our use of such service providers and services, and the collection of your personal data.

3. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• When you submit a request for information on our Site, so that we can respond to your request;
• When you submit a comment or provide feedback to us on our Site, so that we can act on the feedback and respond to your comment;
• To send you marketing emails using the information you provided to us on the Site;
• When you submit an inquiry or apply for work through the use of contact details provided on our Site, so that we can process that information and your application, if any;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us or using the ‘unsubscribe’ link in our e-mails to you.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing
  
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Thought Pieces and Legal Updates

We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and information may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any time by following the ‘unsubscribe’ link on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service we provide to you or to a third party and which may involve your personal data.

Cookies

Please see the section above in our general Privacy Policy regarding our use of cookies on our Site.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  We may also use your personal data to send you marketing emails.

Please note that we may process your personal data without your knowledge or consent, in compliance with the rules set forth in this Privacy Policy, where this is required or permitted by law.

4. Disclosures of your personal data  

We may share your personal data with certain third parties, as required for the operation of our business, which includes processors and sub-processors.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We contract with our third-party service providers to require that they do not use your personal data for their own purposes and to authorize them to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers

We may share your personal data within the HILLCREST WEALTH ADVISORS Group, which may involve transferring your data outside the European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, we endeavour to ensure a similar degree of protection is afforded to it by following the safeguards set forth in our Privacy Shield Notice.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

6. Data security

Please see the section above in our general Privacy Policy regarding data security measures used in an attempt to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, or disclosed to unauthorized third parties. 

7. Data retention

We are developing a data retention policy which will dictate how long we retain your personal data collected through or on our Site, with the intent that we will retain your personal data only for so long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the HILLCREST WEALTH ADVISORS Group acting as joint controllers or processors and who are based in the United States, India or Israel.

External Third Parties

• Service providers acting as processors or sub-processors, who provide information technology services, software/web development services, website management services, hosting services to make our Site available to you or to store the data collected through or on the Site, and search engine marketing and optimization services.  We will provide a list of such parties upon reasonable request.
• We may share your personal data with our legal and insurance advisers, such as our attorneys and insurance brokers.  Such parties are not listed herein for security reasons.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.