Updated: March 21, 2023
This notice describes our current privacy practices. For as long as we have your PI, we will protect it pursuant to this policy.1
Information We Collect through the Alto Platform
The type of PI we collect includes the following:
- When you complete forms, applications, or instructions; visit our website; or speak with one of our representatives, you give us information that may include:
- Your name, address, date of birth, social security number, driver’s license number, email address, certain pre-existing IRA or qualified plan account information, personal financial information and other non-public information.
- Additional information from you or third parties to validate or supplement this information.
- Payment information, such as credit card, bank account, or other account information.
- We may collect information from other sources, such as consumer reporting agencies to verify information we receive from you.
- Non-personal data, such as information collected through cookies,2 number of visits to our Site, and domain names of your internet service provider.
Except to the extent required by law, your use of Do Not Track features in your browser will not affect our collection of information.
Use and Disclosure of Your Personal Information
We may share your PI within our company, with affiliates, third parties with whom we have contracted in furtherance of our business, and with those third parties you have authorized us to share such information. We or they use this information for identification purposes, to execute transactions, to communicate with you, to operate our systems, to market on our behalf, to identify investment opportunities that may interest you or be available to you, to provide customer service, or to analyze3 in order to enhance our services.
Federal law requires us to give you this notice about your ability to limit marketing by our affiliates. Certain information collected by one Alto company cannot be used as the basis of marketing by another Alto company if you opt out of the use of such information. This information includes, among other things, financial information and your account history with us. For example, information collected by Alto Solutions cannot be used by Alto Securities (our broker-dealer) to market its products or services to you if you opt out of the use of information for marketing purposes. Your choice to limit marketing offers from our affiliates will apply until you tell us to change your choice. If you have already made a choice to limit marketing offers from our affiliates, you do not need to act again. To limit marketing offers, please see the “contacting us” section below.
Security of Information
We have an important responsibility to keep your information safe. We use physical, electronic and procedural safeguards to protect your information from unauthorized disclosure. Our employees are trained and authorized to access your information only when they need it to provide you with services. Employees who have access to your PI are required to keep it confidential. Employees are trained on the importance of data privacy. When we share PI with third parties for the purposes noted above, we ensure there are contractual restrictions on their use and disclosure of that information. Please be mindful that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
Your Rights Regarding your Personal Information
- Accuracy of Information: We strive for accurate records. Please tell us if you receive any incorrect materials from us or if you feel the PI we have about you is inaccurate, incomplete, or not current by emailing us at the below address. We will correct any inaccurate or outdated information as soon as possible.
- Access: We will tell you what PI we have about you that we are required by law to provide to you at your request (“Disclosable PI”). Upon written, email or phone request, you may obtain a copy of the Disclosable PI within 45 business days (or such shorter period required by law, if any). We will not provide you with information we have collected in connection with, or in anticipation of, a claim or legal proceeding.
500 11th Avenue North, Suite 790
Nashville, TN 37203
Updates and Amendments
3) For example, we use Google Analytics, which may collect information including but not limited to your browser history, cookies, and/or IP address when you interact with the Site or our applications. For more information on how Google collects and processes and safeguards this data, visit Google’s disclosures and information at https://policies.google.com/technologies/partner-sites and https://support.google.com/analytics/answer/6004245.
We may also convert PI into general information by excluding information that is personally identifiable. General information may include cookies, tags, scripts, Internet service providers, and other system information. Alto or its service providers may use such general information in order to analyze trends, administer the Site, and track visitor and user movement to, from and around the Site. General information is the property of Alto and Alto has the right to use such general information as it determines in its sole discretion.