Effective January 1, 2008
INFORMATION THAT IS COLLECTED
We only collect the personally identifiable information that you provide to us.
If you request certain services available on this Website, you may be asked to provide certain personally identifiable information, such as your first and last name, e-mail address, telephone number, date of date of birth, investment experience, risk tolerance, and any information about your personal investment goals or objectives. Information about your transactions with or through us, such as your account balance, trading activity, and account history, if applicable.
We may use personally identifiable information in order to develop, offer and deliver products and services; respond to inquiries from you or your representative(s); or to fulfill legal and regulatory requirements. CASPIAN may collect nonpublic personal information about you from any of the following sources:
- From you or your representative(s) on applications, registrations or other forms (e.g., your contact information);
- From you or your representative(s) regarding your preferences (e.g., based on your activity on the Website);
- From other interactions with CASPIAN (e.g., discussions with our customer service staff or your entry of information into our interactive tools); or
- From e-mail correspondence from you (e.g., we may retain the information in a file specific to you).
We also may collect certain non-personally identifiable information when you visit the Website. This information includes the type of Internet browser and operating system you are using, the domain name of your Internet service provider, your IP (Internet Protocol) address, pages visited and average time spent on the Website. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve the Website design and functionality. When you contact us through the Website, you consent to CASPIAN’s review and internal use of your communication. We also may use non-personally identifiable information in the aggregate to analyze Website usage and to gather broad demographic information.
HOW WE USE AND DISCLOSE THE INFORMATION
As a general rule, CASPIAN will not share, rent, sell or otherwise disclose any of your personal information, except with your permission. We use and disclose personal information for the purposes that we have disclosed to you, except as otherwise permitted by law. We will request your consent before we use or disclose your information for any materially different purpose. Unless specifically described below, consent may be obtained in any legally sufficient method. For example, depending on the circumstance and the laws of your jurisdiction, consent may be obtained by providing you with notice and the opportunity to opt-out.
CASPIAN may disclose your personal information:
- to unaffiliated persons or entities whom you designate;
- to affiliates, including affiliated services providers;
- to our third party contractors, service providers and agents who perform services for CASPIAN, provided that such contractors, service providers and agents use the personal information only for the purposes of such services;
- as part of a merger, acquisition or other sale or disposition of our assets or business;
- to other organizations, with your consent or as directed by your representative(s); or
- to other organizations, as permitted or required by the laws that protect your privacy (for example, for fraud prevention).
In addition, we may disclose aggregated information to advertisers and for marketing or promotional purposes. In these situations, we do not disclose to these entities any information that could be used to personally identify you.
We require each of the above parties to adhere to our privacy standards and to use this information only for the limited purpose for which it was shared. Individuals interact with us in a variety of ways, and under some of these variations, we may exchange information with parties in addition to those described above.
If you are a former customer, your information is treated in the same manner as the information of current customers. If you have any questions or concerns regarding your privacy with CASPIAN, please contact us at [email protected].
Except as described above, we do not reveal information about you to unaffiliated third parties. We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain reasonable physical, electronic, and procedural safeguards to guard your nonpublic personal information. With respect to information given on the Internet, CASPIAN uses a variety of proven protections to maintain the security of your online session. This may include the use of firewall barriers, encryption techniques and authentication procedures.
LINKED WEBSITES AND OTHER THIRD PARTIES
HOW YOU CAN ACCESS OR CORRECT INFORMATION
For details on how to access your personally identifiable information collected through this Website, and how to update that information or correct factual errors in it, please contact us at [email protected]. For our records, we may retain original and updated information for reasons such as technical constraints, dispute resolution, troubleshooting, record retention and agreement enforcement. For security purposes, we may request information to help verify your identity before granting access or making changes to the information.
REQUEST OF CERTAIN INFORMATION
You may request certain information from us regarding our disclosure of your personal information to unaffiliated third parties for their direct marketing purposes. To make such a request, please send an e-mail to [email protected] or write us at:
Attn: Privacy Department, CASPIAN,
1440 Chapin Ave, Suite 205
Burlingame, California 94010