Last Updated: November 4, 2020
Collection of Personal Data.
When you access certain restricted areas of the Site and/or use the services of Black Diamond Performance Reporting™ (linked through “MySAM), Betterment for Advisors™, (linked through “SAM Digital”), Fidelity NetBenefits® or Newport Group™ (linked through “SAM Retirement Plans”), or Fidelity Investments® (linked through Fidelity), you will be required to submit a Sign-In and Password. This information is linked to personal data that you provided to us (and which is provided to Black Diamond Performance Reporting™, Betterment for Advisors™, Fidelity NetBenefits®, Newport Group™ and Fidelity Investments®) during the registration process for such services.
In addition, when you sign up for any of our alerts, newsletters, or other communications or contact us via e- mail, you will be required to provide us with personal information about yourself, which may include your name, address, e-mail address, and other personal information. All information that we collect pursuant to this Section is collectively referred to herein as “Personal Information.”
We do not collect any Personal Information from you when you use the Site unless you provide us with the Personal Information voluntarily or authorize us to access it.
Collection of Non-Personal Information.
As you navigate through a website, certain information that does not identify you personally can be automatically collected without your providing the information. For example, when you visit the Site, we may collect information including but not limited to your IP address, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, and sections of the Site visited.
All information that we collect pursuant to this Section is collectively referred to herein as “Non-Personal Information.” The Non-Personal Information and the Personal Information are collectively referred to herein as the Information.
We use such Non-Personal Information to diagnose problems with our servers, report aggregate information, determine the fastest route for your computer to use in connecting to the Site, and administer and improve the Site.
Protection of Information.
We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. All personal information in our computers is protected from unauthorized access by a secure firewall and databased architecture. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
With respect to your Personal Information, we employ and maintain physical, electronic, and procedural safeguards that comply with applicable law.
SAM will take reasonable measures to dispose of personal information so that it cannot be read or reconstructed for unauthorized use. SAM will determine the appropriate method of disposal on an as needed basis.
Use and Disclosure of Information.
Important Notice to Non-U.S. Residents.
The Site is operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using the Site and/or providing us with any Information, you irrevocably and unconditionally consent to this transfer.
Links to Other Web Sites.
How to Contact Us.
Satovsky Asset Management, LLC
232 Madison Avenue, Suite 400
New York, NY 10016