The links below will take you to sections of this Policy explaining the following topics and together with the information contained in the below sections, constitute our Notice at Collection:
Information We Collect
Janney may collect or generate personal information about you in a number of ways and from a number of sources depending upon the services we provide and the relationship we have with you. The following is a list of categories of personal information,
along with some descriptions and examples, that we may collect or generate about you.
| Category | Description |
|---|
A. Personal Identifiers | A real name, alias, postal or e-mail address, unique personal ID, account name, social security number, government-issued ID number, and other similar identifiers. |
B. Device and Online Identifiers and Related Information | Online identifiers, IP address, mobile/wireless carrier device identifier, and other device information |
C. Internet, Application, and Network Activity | Data related to user activity including emails, browsing history, search and clickstream history, online website tracking information, other data related to user activity, and URL referral header information |
D. Commercial information | Records of products or services purchased, obtained, or considered through Janney or its advisors. |
E. Internet or other similar network activity | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. |
F. Geolocation Data | Region, country, city, information about geolocation and mobile device including a unique identifier for your device; in some instances, location can be estimated from your IP address or through your Wi-Fi connection. |
G. Sensory Data | Audio recordings of telephone conversations related to account activity. |
H. Protected Classification Characteristics | Sex, marital status, age, race, citizenship, and/or national origin. |
I. Sensitive Personal Information | Some of the personal information that we collect and generate, and which is described above is considered sensitive personal information. This may include information related to your health, marital status, age (40 years or older), or
citizenship.
|
How We Use Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- to fulfill or meet the reason for which the information is provided; for example, if you provide us with personal information in conjunction with an order, we will use that information
- to provide you with information, products, or services that you request from us;
- to provide you with email alerts, event registrations and other notices concerning our products or services, or news, that may be of interest to you;
- to improve our website and present its content to you;
- to comply with valid legal process including subpoenas, courts orders, or search warrants, and as otherwise authorized by law; in cases involving danger of death or serious injury to any person or other emergencies;
- to protect against fraudulent, malicious, abusive, unauthorized or unlawful use of our products and services;
- to advance or defend against complaints or legal claims in court, administrative proceedings, and elsewhere;
- to a third party that you have authorized to verify your account information;
- to external auditors providing professional advice and regulators
- with your consent
To Whom We Disclose Personal Information
We may disclose personal information as set forth below:
Janney Affiliates: We may disclose personal information with members of the Janney family of companies in order to provide services, improve products, or for other purposes permissible under applicable law and regulations.
Vendors: We may disclose personal information with non-affiliated companies that perform support service for us, such as data analytics, risk management, security services, customer support, mail services, email delivery, information technology,
and other service providers and business partners.
We may also use and disclose data that we collect on an aggregate, de-identified or anonymous basis for various business purpose, where permissible under applicable laws and regulations or when you provide your consent or direction.
How Long We Retain Personal Information
The length of time that we retain each category of Personal Information will depend on a number of criteria, including (i) the length of time we are required to retain Personal Information in order to comply with applicable legal and regulatory requirements,
(ii) the length of time we may need to retain Personal Information in order to accomplish the business or commercial purpose(s) for which such Personal Information is collected, used or disclosed (as indicated in this Notice), and (iii) whether you
choose to exercise your right, subject to certain exceptions, to request deletion of your Personal Information.
Information Security: How We Protect Your Privacy
We have implemented appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. We also limit access to personal information to authorized employees, agents,
contractors, or vendors.
Cookies And Other Tracking Technologies
A "cookie" is a small text file which is stored on the user's hard drive or mobile device. Cookies perform a number of functions associated with browsing websites and are used for a variety of different purposes, such as storing preferences or tracing
users from page to page on an internet site, thereby enhancing a user's browsing experience. They are generated by web servers when the user enters an internet page and are passed to the user's computer or mobile device and stored for subsequent future
access.
From time to time, we may use “cookies” to keep track of your visit and your use of the Janney website and/or Janney’s mobile app. You can choose whether to accept cookies by changing the settings of your browser, but some functionality
of the website and/or mobile app may be impaired or not function as intended if you choose not to accept cookies. Each browser is a little different, so look at your Help menu to learn the correct way to modify or delete your cookies.
Statistics and Log Files:
We collect aggregate information about our visitors, including the IP address, type of information used and browser software. In addition, we track what portion of our websites are visited, the number of visitors, and time spent on our websites. We keep
this information for our internal use for statistical purposes, to analyze trends, and to improve our websites.
Web Beacons and Geolocation:
We have the ability to track the physical location of your mobile device or web browser when accessing our websites in order to improve user experience and performance. Wi-Fi and IP addresses received from your device or browser may be used to determine
your approximate location. You will always have control over whether to transmit your physical location, and you can prevent such disclosure by disabling Bluetooth and Wi-Fi, using a web proxy, or adjusting your privacy settings.
“Do Not Track” Signals
Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services that you visit. Like many websites and online services, Janney currently does not alter its practices when it receives
a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com.
Social Network Cookies
Janney websites may offer the opportunity to "Like", "Follow" or "Share" site content via social networks. These networks almost always use cookies. If you are a member of one or more of the following social networks and do not want the social network
cookies to be placed on your system, we suggest that you refrain from using such sharing tools.
Facebook: https://www.facebook.com/about/privacy/
Google: https://www.google.com/policies/privacy/
LinkedIn: https://www.linkedin.com/legal/pop/pop-privacy-policy
Twitter: https://twitter.com/privacy
By using our website, you agree to the Janney Cookie Policy, and you consent to our use of cookies in accordance with the terms of the policy.
If you do not agree you can do one of the following:
- Stop using our website and delete any cookies that may have been stored on your computer on your arrival to our site.
- You can also block all cookies or block only third-party cookies, or alternatively, clear all cookies once you have closed your browser.
- You can browse the site using your browser's anonymous usage setting ("Incognito” in Chrome, “InPrivate" in Internet Explorer, "Private Browsing" in Firefox and Safari etc.). The help section of your specific browser will aid you in selecting these settings.
If you block or delete any cookies, you may have to manually adjust some preferences every time you visit the site, and some services and functionalities may not work.
Protecting Children’s Privacy Online
Janney’s websites are not directed to individuals under the age of thirteen (13), and those children should not provide Personal Information through the websites. We do not knowingly collect information from children under 13 without parental
consent.
Changes to this Policy
Changes in Internet technology and the services we provide on our website may result in changes to this privacy policy. If we make changes to this Policy, we will update the “Effective Date” at the top of this Policy. Any changes will
become effective when posted unless indicated otherwise.
The Privacy Notice has been updated to reflect recent regulatory guidance regarding format and language.