1. Introduction
This policy provides information about the companies under PTMA Financial Solutions, which includes Public Trust Advisors, LLC (Public Trust) and Prudent Man Advisors, LLC (doing business as PMA Asset Management, LLC (PMA)), both SEC Registered Investment Advisors doing business as PTMA Investment Advisors (PTMA Advisors). PTMA Financial Solutions also includes PMA Financial Network, LLC and PMA Securities, LLC, an SEC and MSRB registered Broker-Dealer.
At PTMA Financial Solutions (“PTMA,” we,” or “us”), protecting your privacy is important to us. We have policies and procedures in place to maintain the confidentiality and security of your personal non-public information. We want our customers to understand what information we collect and how we use it. This policy is designed to describe the types of information we collect from you when visiting our websites and utilizing the services we offer.
This policy applies to the websites of the entire PTMA Financial Solutions network, including the PMA Website, Public Trust Advisors Website, PMA and PTMA administered fund websites, the PMA GPS portal, PMA Cashflow, and any other online services that the PTMA Companies provides to its customers. This policy explains what information we collect, how we use the information, how we protect the security and confidentiality of the information, and more.
2. Who are our customers?
The majority of clients that PTMA provides financial services and solutions to are public entities, such as state and local governments, school districts, and other public agencies. PTMA also has retail clients, charitable organizations, insurance companies, other investment advisors, and corporations as clients. Our customers are primarily not natural persons, but legal entities that are subject to public disclosure laws and regulations. Therefore, the information that we collect from our customers through our website and online services may be subject to public disclosure by our customers or by us, as required by law.
3. What do we collect?
We collect information from our customers and their authorized users when they access our website and online services listed above. The information that we collect may include:
- Name, title, email address, phone number, tax-identification numbers and other contact information of the customer or the authorized user.
- Account number, password, and other login credentials for the online services we offer.
- Information about the customer’s financial transactions, balances, holdings, and activities with PTMA or its affiliates, or other financial institutions such as account numbers, account balance, account history, financial history including accounts payable, payroll and financial information, and bank routing numbers.
- Information about the customer’s preferences, settings, and feedback regarding our website and online services.
- Information about the customer’s device, browser, operating system, IP address, location, and other technical data when they access our website and online services.
- Cookies, web beacons, and other similar technologies that we use to enhance the functionality and security of our website and online services.
- Date, times, and duration of use of services.
- Information on actions taken when using our services, such as page views and website navigation patterns.
4. Why do we collect information?
We gather non-public personal information about our customers and their authorized users so we can deliver products tailored that meet the organization’s needs, to know who their authorized users are and thereby prevent unauthorized access to information, and to comply with applicable laws and regulations that govern us
5. How do we collect information?
We may collect personal information about you, meaning information that can uniquely identify you, from various sources, such as:
- Directly from you when you use our services, such as when you fill out a form or contact us via e-mail
- Social networks through which you may interact with us.
- Our service providers, business partners, and other third parties.
6. How do we use the information we collect?
We use the information that we collect from our customers and their authorized users for the following purposes:
- To provide, maintain, improve, and secure our website and online services, and to fulfill the requests and needs of our customers and their authorized users.
- To communicate with our customers and their authorized users about our website and online services, and to provide them with updates, alerts, notifications, and other information that may be of interest to them.
- To comply with applicable laws, regulations, and legal obligations, and to cooperate with law enforcement and regulatory authorities, as necessary or appropriate.
- To protect the rights, property, and safety of PTMA, our customers, our affiliates, and our service providers, and to prevent fraud, abuse, and unauthorized access or use of our website and online services.
- To perform analytics, research, and marketing activities, and to improve our products, services, and customer relationships.
- Process orders you place and complete other transactions you have requested using our services.
- Provide you with products and services you request.
- Send you information, reports, or materials you request.
- Respond to your questions and comments and provide customer support.
- Communicate with you about our products, services, offers, and promotions.
- Enforce our Terms and Conditions (please see PTMA websites) and other agreements.
7. How do we share information?
We may share the information that we collect from our customers and their authorized users with the following parties:
- Our affiliates, subsidiaries, and partner third parties that we hire to help us provide products and services to you, as specifically authorized by you, or as otherwise allowed or required by law. Examples of third parties we may hire are custodians, administrators, transfer agents, other broker-dealers, accountants, and attorneys.
- Our service providers, contractors, and vendors, who perform functions on our behalf or provide services to us, such as hosting, data storage, data analysis, data security, data backup, data recovery, data destruction, customer support, email delivery, and marketing.
- Our customers and their authorized users, who may access, use, or disclose the information that we collect from them or their authorized users through our website and online services, as permitted or required by law or by their own policies and practices.
- From time to time, we must provide information about our business to regulatory authorities. This may include personal information about you.
- Other third parties, as required or permitted by law, such as law enforcement, courts, subpoenas, warrants, legal processes, or other valid requests or orders.
- To enforce or apply our Terms and Conditions (please see PTMA website) other agreements;
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of PTMA, users of our services, or others; and with your consent.
- We do not sell non-public personal information about our customers, present or former, to anyone.
8. How do we protect your data?
We have implemented measures, including adoption of policies based on the National Institute of Standards and Technology (NIST), intended to protect your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All the information provided to us is stored on secure servers behind firewalls. Access to your information is restricted to Public Trust employees, registered representatives, and designated software service providers used for legitimate business purposes. Any payment transactions will be encrypted using SSL technology. Please note that the electronic transmission of information is not completely secure.
Despite the above measures, there are inherent risks involved in the sharing of information via electronic means. We cannot guarantee that the security measures we have in place to safeguard personal information will never be defeated or fail, or that such measures will always be sufficient or effective. Any transmission of personal information is at your own risk.
9. How do we respond to do not track signals?
Your web browser may let you choose your preference as to whether you want to allow the collection of information about your online activities over time and across different websites or online services. At this time, our services do not respond to the preferences you may have set in your web browser regarding such collection of your information, and our services may continue to collect information in the manner described in this Privacy Policy.
10. Your choices
We offer you the following choices about the information we collect from you and how we communicate with you:
- Cookies
- Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of the features of the Services.
- Promotional Communications
- If you have received a promotional email from us, you can opt out of receiving future promotional emails from us by following the unsubscribe instructions contained in such email.
11. Closed Accounts
Our information use and privacy policies apply equally to our former customers. We will continue to adhere to the policies and practices described herein even after your account is closed or becomes inactive.
12. Changes to our privacy policy
PTMA reserves the right to update or change this Privacy Policy at any time. If we make a material change to our Privacy Policy, we will provide notice to our clients that our privacy practices have changed and will provide a link to the new policy. In the event we make a material change to how we use your personal information, we will provide you with an opportunity to opt out of such new or different use.
13. Data Transfers
PTMA is based in the United States of America. When we obtain information about you, we may transfer, process, and store such information outside of the country in which you reside, including the United States. By using our services, you consent to the transfer to and processing and storage of your information in countries outside of your country of residence, which may have different data protection laws than those in the country where you reside.
14. Other California Privacy Rights
For clients of PTMA based in California, California’s “Shine the Light” law (Civil Code Section § 1798.83) and California Consumer Privacy Act of 2018 (CCPA) provides additional rights to users of our services that are California residents. For additional information, please visit our California Privacy Notice.
15. Availability of Disclosure
This disclosure policy is available at our offices and on our websites at www.pmanetwork.com and www.publictrustadvisors.com. Additionally, this notice is provided to each customer who opens an account and to all customers at least once annually.
16. Contact Us
If you have any questions about tis Privacy Policy or our information practices, please call us at 888- 976-8884, or email us at privacypolicy@ptma.com.