Effective October 16, 2018
What we collect and where we collect it
In the course of establishing a client relationship and in our ongoing dealings with you as a client, we may obtain nonpublic personal information about you. Personal information we collect may include information about you, such as your name, address, tax identification number and e-mail address. We also collect information about your transactions with us and with the service providers to your account.
Other information may be nonpersonally identifiable, such as information collected by cookies. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies when you visit this Site, you may be unable to use all of the functionality of this Site if your browser rejects our cookies.
In addition, NCG collects information that is sent to us automatically by your web browser or mobile device. This information typically includes your IP address, the name of your operating system, the name and version of your browser, the date and time of your visit, and the pages you visit. The information we receive may depend on your browser or device settings. The information we receive from your web browser and device may or may not be personally identifiable. However, we may combine it with other information in an attempt to identify you or we may combine it with information that does identify you.
Your browser may deliver a “Do-Not-Track (‘DNT’) signal” to this Site. Because of the changing state of technology and indecision within the technology and marketing industries regarding the meaning of DNT signals, we currently do not make any guarantee that we will honor DNT signals.
How We Use Information Collected Through This Site
Generally, we use the information we collect through this Site
- to provide the information, products and services you request;
- for security, credit or fraud prevention purposes;
- to provide you with effective customer service;
- to invite you to participate in surveys and provide feedback to us (in accordance with any privacy preferences you have expressed to us);
- to improve the content, functionality and usability of this Site;
- to improve our products and services; and
- for any other purpose identified in an applicable privacy notice or other agreement between you and us.
To whom we disclose the information
We do not sell any nonpublic personal information about you or any of our former clients to any third parties. We do not disclose nonpublic personal information about you or any of our former clients to any other businesses for the purposes of marketing or business leads. We do not disclose any nonpublic personal information about you or any of our former clients, except as required or permitted by law.
We provide personal information to third party service providers when it is essential for the servicing of your account (namely, transactional services). We disclose such information to other third parties when it is necessary for the conduct of our business, where disclosure is required by law, or where you have authorized or directed us to do so. Where appropriate, we will subject such disclosures to confidentiality agreements.
We use information collected through this Site to create a compiled, aggregate view of usage patterns. We may share aggregate information with third parties so we and they can better understand our user base. We may also share with third parties information about how particular individuals use this Site, but only on a de-identified basis (“Individualized Data”). Individualized Data is not personally identifiable, but it does reflect the usage patterns of a particular Site user, as opposed to Site users collectively.
Your information may be transferred to successor organization if, for example, we transfer the ownership or operation of this Site to another organization if we merge with or are acquired by another organization, or if we liquidate our assets. If such a transfer occurs, the successor organization’s use of your information will still be subject to this Policy and the privacy preferences you have expressed to us.
Protecting your confidential information
Your information is protected in various manners. To protect information about you, we restrict access to nonpublic personal information to those employees and authorized agents who need to know the information in order to provide services to you. All employees are subject to a policy regarding confidentiality. Employees who violate our Policy are subject to disciplinary process. In addition our internal systems are secured through encryption technology, passwords and physical safeguards. We strive to maintain the confidentiality of your account and any other personal information.
How long we retain your data
Any data we gather from you from this Site is retained for as long as we determined may be necessary.
This Policy May Change