The Personal Information we collect or disclose is handled with the utmost respect for your privacy and is motivated by our desire to serve you better.
- We do not allow individuals or companies that provide services to Wasatch to use your personal information for their own marketing purposes.
- We maintain contracts with individuals or companies providing services to Wasatch’s shareholders that require them to protect the confidentiality of your Personal Information.
- We afford the same protection of Personal Information to prospective and former shareholders that we do to current shareholders.
- We consider all of the information we have about you to be confidential, including whether you are a Wasatch shareholder (unless you tell us otherwise).
- We restrict access to your Personal Information to employees who service your accounts.
- We maintain physical, electronic and procedural safeguards designed to maintain the confidentiality of your information.
- In order to complete certain transactions or account changes that you direct, it may be necessary to provide identifying information about you to companies, individuals, or groups that are not affiliated with Wasatch. For example, if you ask to transfer assets from another financial institution to Wasatch, we will need to provide certain information about you to that company to complete the transaction.
Information We Collect and Its Sources
“Personal Information” includes any information that we collect that, alone or in combination with other information, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual. It generally means the same as the terms “personally identifiable information,” or “personal data,” or “nonpublic personal information” as defined under applicable data protection laws.
Most of the Personal Information we collect comes directly from you. The ways we gather it may include:
Account applications. When you open an account or enter information in an online account application.
Transactions. To manage your account and provide information to you such as account statements, we maintain current and historical records of each of your transactions and accounts with Wasatch.
Third-Parties. We may receive information about you that you authorize third-parties to provide to us. We also may obtain personal information from third-party service providers in order to verify your identity, to prevent fraud, or to help us identify products and services that may be of interest to you.
Website. We collect some information on this Website through the use of “cookies.” For example, we may identify the web pages your browser requests or visits. For more information, please read the “Cookies” and “Third-party analytics” sections below.
Personal Information we collect may include:
- Identifiers and certain protected information, like your name and address, email address, telephone number, signature, driver’s license number, Social Security or taxpayer identification number, and date of birth;
- Information about protected characteristics regarding your citizenship, race or ethnic origin, marital status, or sex/gender information;
- Financial information like assets, income, account balances, financial account credentials, investment activity, and accounts at other institutions;
- Employment-related information, including information about your job and title;
- Education information, including level of education attained, where you attained your education, and what years you were there;
- Commercial information, such as Services purchased, obtained, or considered or other purchasing or consuming histories or tendencies.
- Audio or visual information, such as recordings of telephone calls or visual calls to Wasatch;
- Internet or other similar network activity, including usage information regarding the pages you view, links you click or hover over, selections you make on the Website, features you use, preferences you set, other actions that you perform on our websites, the internet protocol (“IP”) address of the device you are using to access the Services, computer browser type, device manufacturer, operating system, domain name, average time spent on certain website pages; browser type and version; user agent string; internet connection type; mobile network provider; date and time of your visit; time since your last visit; your general geographic location (e.g., your city, state, or zip code); and the website visited before our Website.
- Inferences drawn from other personal information, including information we collect and use about your use of this Website
Some of the information above, such as Social Security numbers and driver’s license numbers, is considered “sensitive personal information” under applicable law.
We may combine the Personal Information collected on this Website with Personal Information collected from or about you in other contexts. This may include Personal Information collected through publicly available sources or online, such as through our email exchanges with you, or from offline sources, such as information that we collect when you establish your account with us or call customer service. We will treat such combined Personal Information in accordance with this policy.
If you do not wish to provide Personal Information to Wasatch, we may be unable to provide certain products or services to you.
How We Use Your Personal Information
We and third-parties working on our behalf may use the information we collect about you for various purposes, including:
- To respond to your requests or to communicate with you;
- To provide you with information or services you requested;
- To personalize your experience on this Website or with our products or services;
- To send email communications or information about our products or services that may be of interest to you;
- To analyze usage trends;
- To improve and enhance the functionality of this Website or our products and services;
- For recruitment and employment-related purposes (including conducting background checks and employment eligibility verification, for interview purposes, payroll administration and employee timekeeping, benefit administration);
- For other legitimate business purposes; and
- For other purposes, with your consent.
In certain circumstances, we may aggregate and/or de-identify information collected for additional purposes.
Information We Disclose
We disclose Personal Information about our current and former shareholders to third-parties for the following purposes:
- To service your account and process your transactions. We may share your Personal Information with non-affiliated companies or individuals that we contract with in order to provide services. These may include payment processing; printing and mail services; providing products or services to you on our behalf; creating or maintaining our networks, systems, and databases; analytics; providing support; marketing our products and services; or responding to inquiries.
- To do as you request. For example, you may direct us to send your statements and confirmations to a third-party.
- To share information within the Wasatch group, including with subsidiaries and affiliates.
- To comply with laws or regulations. We may disclose or report Personal Information as required by law, for example, to respond to a subpoena, court order or regulatory demand made by the proper authorities.
- To the extent permitted by law. For example, the law permits us to respond to a request for information from a consumer reporting agency.
- Business Transactions. In the event of a merger, sale of the business, bankruptcy proceeding, or similar transaction, we may exchange your personal information with the other entity involved in the transaction.
- To protect our interests, rights, safety, or property or those of others.
- Any other sharing or disclosure with your consent.
Transfer of Personal Information
The Personal Information we collect about you may be transferred to or stored by Wasatch or our service providers in the United States or elsewhere, as permitted by law. If you reside outside the United States and use our website or otherwise provide information to us, you acknowledge that your information will be transferred to and processed in the United States and in accordance with the laws of the United States, which may not provide the same levels of privacy protection as the laws in your jurisdiction.
Online Privacy Protections
Our concern for the privacy of our shareholders naturally extends to those who use our website, wasatchglobal.com. Our website and Services use secure forms of online communication, including data encryption, transmission encryption, user names and passwords, and back-end fraud and account monitoring. However, no security system is entirely secure. As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information you transmit to our Services.
If you are a Wasatch shareholder who has registered for secure online access to your Wasatch account, we are able to combine the information we collect about your usage of our website during a secure (logged-on) session with other information we know about you, such as any account transactions you conduct during your session. We can also identify your computer or device on each online visit to Wasatch, even if you do not log on, and link information about that visit to you. We may use this combined information to assess the appeal and usefulness of the information and tools offered on our website, as well as to identify Wasatch Services that may be of interest to you.
Some web browsers have “do not track” or similar features that allow you to tell each website you visit that you do not want your activities on that website tracked. Our website does not track your browser’s “do not track” settings.
We may partner with third-parties to collect the information discussed above to engage in analysis, auditing, research, and reporting. These third-parties may set and access cookies on your computer or other device and may use web beacons to collect information about your activity on our website. In particular, our website may use third-party analytics services to help collect and analyze certain information for the purposes discussed above.
Google Analytics collects certain Automatically Collected Information from visitors to our Websites for these purposes. For more information about Google Analytics, please review Google Analytics’s Privacy and Terms, located here.
Your Rights Under California Law
Under the California Consumer Privacy Act (“CCPA”), California residents have certain privacy rights, as provided therein. In addition, the CCPA provides certain exemptions that may apply to the Personal Information we collect from or about you. For example, personal information subject to the protections of the Gramm-Leach-Bliley Act of 1999 or the California Financial Information Privacy Act may be exempt from the requirements of the CCPA. To the extent that your Personal Information does not fall under an enumerated exemption, California residents have the following rights:
- The Right to Know: You have the right to request that we disclose to you details about the personal information we collect, use, disclose, or sell. This includes the specific pieces of personal information we have collected from or about you.
- The Right to Request Deletion: You have the right to request that we delete any of your personal information under our control.
- The Right to Correct: You have the right to request that we correct any inaccurate information that we maintain about you.
- The Right to Limit the Use and Disclosure of Sensitive Personal Information: As described above, some of the information we collect may be considered sensitive personal information. You have the right to request that we limit the use and disclosure of your sensitive personal information to that use which is necessary to provide you with Services you have requested and for certain other limited purposes as provided for under the CCPA.
- The Right to Non-Discrimination: If you choose to exercise any of these rights, you will not receive any discriminatory treatment from us.
Verification. In order to protect the integrity of our products and services, as well as your Personal Information, we may need to verify your identity before processing any requests. We will not fulfill any request unless we have sufficient information to reasonably verify you are the individual about whom we collected Personal Information.
Authorized Agent. Under California law, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. Please note, any authorized agent must have written permission from you to make such a request, and will be subject to identity verification.
Sale or Sharing of Personal Information. Wasatch does not “sell” or “share” Personal Information, as those terms are defined in CCPA. Wasatch has not sold or shared Personal Information in the prior 12 months.
Other California Privacy Rights. Under California’s “Shine the Light” law (California Civil Code Section 1798.83), California residents are entitled to request and obtain from Wasatch once per calendar year information about when we share your Personal Information with third-parties for those third-parties’ own direct marketing purposes. We do not share Personal Information with third-parties for their direct marketing purposes; however, to request more information, please email us at the address indicated below, and note “California Shine the Light” in the subject line.
To exercise your rights s under the CCPA please send a detailed request to:
P.O. Box 2172
Milwaukee, WI 53201-2172
We do not knowingly collect Personal Information from children under the age of 16. If we discover that we have inadvertently collected any information from a child under the age of 16, we will promptly delete it. If you are a parent or guardian and believe your child provided us with their Personal Information without your consent, please contact us.
We may email marketing correspondence to you about our Services. To unsubscribe from these communications, please follow the unsubscribe instructions contained in the emails or contact us using the contact information below.
What You Can Do and Contact Information