Privacy Notice
October 7, 2010
Information we collect
When you obtain services from us, we collect information such as name, address, telephone number, e-mail address, date of birth, income, employment, dependent information, financial products owned (type and amount), tax bracket and net worth.
How we collect information
We collect nonpublic personal information about you from applications, statements, other written forms, electronic files completed by you or us, our website and from other oral and electronic communications such as e-mail.
Who we share the information with
Except as provided below, we do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law.
We share information with third parties where necessary in order to help us provide the services you seek from us. We may also provide nonpublic information about you to non-affiliated third parties as permitted or required by law.
We do not sell information about current or former customers to any third parties.
Protecting your information
We restrict access to nonpublic personal information about you to those representatives and employees who need to know this information to provide products or services to you. We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information.
Simply put, we do not and will not sell or rent your personal information to anyone, for any reason, at any time. CoPilot uses and discloses your personal information only as follows:
- to analyze site usage and improve the Service;
- to deliver to you any administrative notices, money alerts and communications relevant to your use of the Service;
- to fulfill your requests for certain products and services;
- for market research, project planning, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity;
- to third-party contractors that provide services to CoPilot Financial and are bound by these same privacy restrictions;
- to enforce CoPilot Financial’s Terms of Use; and
- as otherwise set forth in this Privacy and Security Policy.
In the event that you access the Service as brought to you by one of our co-brand partners, through a co-branded URL, your email address used for registration on the Service may be provided to that co-brand partner.
Sharing information with 3rd parties offering other products or services
There are a number of separate products and services offered by third parties advertised by us on our Site and through the Service that may be complementary to your use of CoPilotFinancial.com, such as accountants, lawyers and mortgage lenders (collectively, “CoPilot Offers”). If you choose to use these separate products or services, disclose information to the providers, or grant them permission to collect information about you, then their use of your information is governed by their privacy policies. You should evaluate the practices of external services providers before deciding to use their services. CoPilot Financial is not responsible for their privacy practices. If you click on a link to a third party site, CoPilot encourages you to check the privacy policy of that site. CoPilot may present links in a format that enables us to keep track of whether these links have been followed and whether any action has been taken on a third party Web site. We use this information to improve the quality of the CoPilot Offers and to customize content on the Service.
Contests, Giveaways and Surveys
From time to time, CoPilot may offer you the opportunity to participate in contests, giveaways and other promotions. Any information submitted in connection with such activities will be treated in accordance with this Privacy and Security Policy, except as specifically set forth in the rules for those contests, giveaways or promotions. From time to time, CoPilot may also ask you to participate in surveys designed to help CoPilot Financial improve the Site. Any personal information provided to CoPilot Financial in connection with any survey will be used only in relation to that survey and as elsewhere set forth in this Policy.
Disclosure of your information to protect our rights or if required by law
Notwithstanding the foregoing, CoPilot reserves the right (and you authorize CoPilot) to share or disclose your personal information when CoPilot determines, in its sole discretion, that the disclosure of such information is necessary or appropriate:
- To enforce our rights against you or in connection with a breach by you of this Privacy and Security Policy or the CoPilotFinancial.com Terms of Use;
- To prevent prohibited or illegal activities; or
- When required by any applicable law, rule regulation, subpoena or other legal process.
Email communications from us
We provide our registered customers with weekly summaries of their Account Information and email alerts. We also allow users to subscribe to email newsletters and from time to time may transmit emails promoting CoPilot Financial or third-party goods or services.
CoPilotFinancial.com subscribers have the ability to opt-out of receiving our promotional emails and to terminate their newsletter subscriptions by following the instructions in the emails. Opting out in this manner will not end transmission of service-related emails, such as email alerts.
Your data is secure
We use a combination of firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of your online session and to protect CoPilotFinancial.com accounts and systems from unauthorized access.
Our servers are in a secure facility. Access requires multiple levels of authentication, including biometrics recognition procedures. Security personnel monitor the system 7 days a week, 24 hours a day.
Our databases are protected from general employee access both physically and logically. All backup drives and tapes are encrypted.
We enforce physical access controls to our buildings.
No employee may put any sensitive content on any insecure machine (i.e., nothing can be taken from the database and put on an insecure laptop).
However, it is important to understand that these precautions apply only to our Site and systems. We exercise no control over how your information is stored, maintained or displayed by third parties or on third-party sites.
We update this Privacy & Security Policy periodically. The date last revised appears at the top of the Policy. Changes take effect immediately upon posting.
Terms and Conditions
Click here to download this information as a PDF.
AGREEMENT WITH COPILOT FINANCIAL
I have called __________________ and spoken to a CoPilot Financial (“CoPilot”) representative. I want CoPilot to provide the services checked below. I am a resident of _________________ (state and country)
SERVICES REQUESTED:
/_/ “Wheels Up Financial Planning”: I will provide the information necessary for CoPilot to prepare a financial plan that will include a personal/family balance sheet; a preliminary budget to meet my retirement and other stated financial goals; a detailed projection of expected future income, expenses and savings; an evaluation of the risks and merits of my current assets and investments; an evaluation of my insurance needs; a general analysis of the risks involved in meeting my goals; methods for managing or eliminating those risks; recommendations regarding suitable types of investments to meet my goals; and, if applicable, recommendations regarding non-investment decisions, such as debt refinancing.
Cost: $749 payable upon delivery of the financial plan, pending customer approval.
/_/”Northstar” Investment Advice: A quarterly summary of the economy, markets and other pertinent investment environment issues, and an asset allocation recommendation based on the environment, my risk profile, and the length of my investment time horizon. The advice will be tailored to me based on my responses to the Investor Profile questionnaire or my financial plan (if one has been prepared). The quarterly reports will include recommended percentages of investments by type or sectors (e.g. large cap stocks, European stocks, bonds, energy, real estate) which will be based on my responses to the Investor Profile questionnaire. The summary will also make a recommendation on where to ideally place these types of investments (between taxable and tax deferred accounts). It will include recommendations for appropriate passive investments (eg. ETFs and/or indexed mutual funds), but will not provide recommendations of specific stocks or bonds.
Cost - $75/quarter and payable 10 days before the end of the quarter and prorated for partial quarters, payable upon customer approval and cancellable at any time. I can cancel simply by not paying. Failure to pay will automatically terminate further service unless I bring my account current or enter into a new agreement and pay a re-initiation fee of $100.
/_/ “Navigator” Investment Advice: A quarterly service that provides specific investment recommendations for my taxable and tax-deferred accounts, based on my approved financial plan (if one has been prepared) or based on my responses to the Investor Profile questionnaire. The investment recommendations will be reviewed at least quarterly and I will be able to meet personally or over the phone with CoPilot for a detailed review and discussion about my investments and financial plan once a year. The annual meeting will include a review of any changes in my investment objectives or financial condition, and a comparison of the performance of my investments with appropriate market indexes. I can also call CoPilot for advice at any time while receiving the service on any financial issue that directly affects me. Areas of advice may include:
• Advice on how to manage stock benefit plans or stock options received from my employer
• Asset protection vehicles (life insurance, disability, health, liability, long-term care)
• Education funding for children
• Mortgages and personal debt
• Portfolio management questions/general education
Cost - $249/quarter payable 10 days before the end of the quarter and prorated for partial quarters, payable upon customer approval and cancellable at any time. I can cancel simply by not paying. Failure to pay will automatically terminate further service unless I bring my account current or enter into a new agreement and pay a re-initiation fee of $300.
Assignment: CoPilot will not assign this agreement or its responsibilities described herein to any other person or entity without my prior written consent.
My Duties: I will provide accurate information to CoPilot. If there are material changes to the information I have provided in my Investor Profile questionnaire, I will revise my answer and notify CoPilot. I will carefully review all plans, reports and recommendations that I receive from CoPilot and notify it promptly if I have questions including any question regarding the appropriateness of any recommendation or if I feel that any recommendation may be too risky for me.
What CoPilot Will Not Do: CoPilot will only provide advice that in its judgment is appropriate to my latest responses to the Investor Profile questionnaire or financial plan as last revised if one has been prepared. It will not verify the information I provide. CoPilot will not act as my agent or buy or sell securities or any other financial product for my account. I will open my own investment accounts with broker-dealers that I select. I will do my own trading and decide how, when and whether to use the advice provided by CoPilot. I understand that CoPilot’s advice is meant to be promptly followed and that if I delay in taking action on the advice, it may become out-dated. CoPilot does not provide tax or legal advice. I will obtain such advice from others. CoPilot does not guarantee the future performance of any investment or guarantee that my objectives will necessarily be met if I follow its advice.
Privacy: The information I give CoPilot is confidential and it will not be disclosed to any person other than as CoPilot must do so to provide the services that I request or as may be required by law. I will receive a copy of its Privacy Notice when this agreement is accepted and annually thereafter.
Termination: This Agreement may be terminated by either party at any time by written notice.
Brochure Delivery: When required by state law or if I request it by checking here /_/, I will receive a copy of Part II of CoPilot’s Form ADV (“Brochure”). If requested or provided, I may terminate this agreement without penalty at any time for a period of five business days after I have received the Brochure.
Notices. Any notice, advice or report to be given to me by CoPilot, or given by me to CoPilot, may be delivered electronically by e-mail to the e-mail addresses shown below, or may be given in person, by U.S. mail or overnight courier (postage prepaid) at the addresses on the signature page of this Agreement or at such other addresses as it may designate in writing by me or CoPilot.
Name(s) of
Client(s) _________________________ Date _______________
_________________________
Address:
Telephone:
Email address:
Payment
_________________________ _________________________
Client Signatures
Michael Bergines, President
COPILOT FINANCIAL,
A division of BERGINES
& ASSOCIATES, INC., a California corporation
_________________________
Address: 1544 Rosecrest Terrace
San Jose, CA 95126
Click here to download this information as a PDF.
