Privacy Policy

Last updated: May 18, 2024

Introduction

Investment Advisers are required by law to inform their clients of their policies regarding privacy of client information. Federal law gives clients the right to limit some but not all sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information. The Privacy Policy below discloses our practices regarding information collection and usage for the website located at paduafinancial.com, as well as any subdomains thereof and the related mobile website (collectively, the “Service”). Padua Financial Services, LLC (“Padua Financial“, “Company“, “we“, “our”, “us”) is committed to safeguarding the confidential information of all current, former, and potential clients. All personal information provided to our firm is held in the strictest confidence. These records include personal information we collect from you in connection with the Padua Power Plan process, Padua Power Management service and any other services provided by the Company. We use your information in helping you meet your personal financial goals while guarding against any real or perceived infringements of your rights of privacy. By using or accessing the Service, you signify your agreement to be bound by this Privacy Policy. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY YOU MAY NOT ACCESS OR OTHERWISE USE OUR SERVICE OR PARTICIPATE IN OUR SERVICES.

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 our website at https://www.paduafinancial.com (the “Website“), as well as any subdomains thereof and the related mobile website, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Website.
• In email, text, and other electronic messages between you and this Website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
• Applications or other forms such as customer or account agreements.
• Your account transactions such as purchases, sales and account balances.
• Third-party analytics services that evaluate your use of the Website.
• Surveys that we may conduct from time to time.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by the 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

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy as set forth in this policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13 with the exception of beneficiary information provided by a child’s parent or guardian. If you are under 13, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information with the exception of beneficiary information provided by a child’s parent or guardian. If you believe we might have any information from or about a child under 13, please contact us at [email protected].

If at any time in the future we plan to collect personally identifiable information from children under 13, such collection and use, to the extent applicable, shall, when required, be done in compliance with the Children’s Online Privacy Protection Act (“COPPA”) and appropriate consent from the child’s parent or guardian will be sought where required by COPPA.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, social security number, date of birth, banking information and financial account numbers and/or balances, sources of income, and credit card numbers(“Personal Information”);
• That is about you but individually does not identify you, such as IP host address, web pages viewed, browser type, operating system, referring service, search information, device type, page views, usage and browsing habits on the Service and similar data; and/or
• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website or any account or client forms. This includes information provided at the time of registering to use our Website, subscribing to our service, or requesting further services.
• This includes information you may provide such as assets and income; investment experience, transaction history, credit history and wire transfer instructions, if any.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Website. You may be required to provide financial information before placing an order through our Website.
• Your search queries on the Website.
• We may also ask you for information when you report a problem with our Website.

You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. We do not limit access to public areas of the Website, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
• We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). We do not currently respond to opt out requests for behavioral tracking on this website.

Please contact [email protected] for more information. The information we collect automatically is only statistical data and does not include Personal Information, but/or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our 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 our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our 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 .
• Web Beacons. Pages of our 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 the Company, for example, to count users who have visited those pages or opened an email and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third- parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information, as defined in this privacy policy:

• To present our Website and its contents to you.
• To market our products and services to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account/subscription, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• To allow you to participate in interactive features on our Website.
• To provide investment advisory services to you.
• To process a transaction for your account.
• To respond to court orders and legal investigations.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may share your personally identifiable information with third parties to further the purpose for which you provided such information to us (collectively, the “Third Party Vendors”). For example, we may share your information with payment service providers such as, for example, Moonclerk, for the purpose of processing your payment. We may also share your information with Google, for the purpose of using the document system called GSuite. We urge you to read the privacy practices of all of our Third Party Vendors before submitting any personally identifiable information through the Service.

We may transfer your personally identifiable information in connection with the sale or merger or change of control of the Company or the division responsible for the services with which your personally identifiable information is associated.

We may share your personally identifiable information with an affiliate of Padua Financial who is in the same corporate family as us as long as their privacy practices are substantially similar to ours.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose Personal Information that we collect or you provide as described in this privacy policy:

• To our subsidiaries, affiliates, contractors, service providers, and/or other third parties that assist us in servicing your account and have a need for such information . These businesses are bound by contractual obligations with the Company to keep Personal Information confidential and use it only for the purposes for which we disclose Personal Information to them.
• 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 the Company ’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Padua Financial about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.

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.
• To enforce or apply our terms of use and terms of service and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

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:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Promotional Offers from the Company and Opt-Out Requests. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, please contact [email protected]. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
• Targeted Advertising and Opt-Out Requests. If you do not want us to use information that we collect or that you provide to us to deliver advertisements, you may opt-out by contacting [email protected].

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.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information. To learn more about your California privacy rights, visit.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].

Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions and your Personal Information will be encrypted using SSL technology.

The safety and security of your Personal Information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information through SSL technology, we cannot guarantee the security of your Personal Information transmitted to our 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.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ Personal Information, we will notify you by email to the email address specified in your account and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: [email protected]