At Wasatch, we understand that our relationship with you and all of our shareholders is one of trust. As such, we go to great lengths to protect the information we collect about you or your accounts.
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 will not disclose your personal information to anyone unless it is necessary to provide you with our services, at your direction, or required by law.
- 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 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 that comply with federal standards for maintaining 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, Its Sources, and How We Use It
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.
- Web site. We collect some information on our web site through the use of “cookies.” For example, we may identify the web pages your browser requests or visits. On the web site, we can only identify you if you choose to identify yourself, for example, if you open an account or make a transaction online. For more information, please read the Online Privacy Protection section below.
Personal information collected from any source may include, among other things:
- Identifiers like your name and address, Social Security or taxpayer identification number, date of birth
- Other information like assets, income, account balances, investment activity, and accounts at other institutions.
The 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.
We may combine the information collected on our website with information collected from or about you in other contexts. This may include information collected 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 information in accordance with this policy.
If you do not wish to provide information to Wasatch, we may be unable to provide certain products or services to you.
Information We Disclose
We disclose information about our current and former shareholders to parties outside of Wasatch for the following purposes:
- To service your account and process your transactions. For example, transfer agents collect and store account and transaction data.
- To do as you request. For example, you may direct us to send your statements and confirmations to a third party.
- To print and mail materials to you. We use companies that provide printing and mailing services, and we prohibit them by contract from using your information in any way other than the purpose for which it was provided.
- 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, or similar transaction, we may exchange your personal information with the other entity involved in the transaction.
- Sales. Wasatch does not, and will not, sell your personal information.
Online Privacy Protections
Our concern for the privacy of our shareholders naturally extends to those who use our website, wasatchglobal.com. Our website uses some of the most secure forms of online communication available, including data encryption, transmission encryption, user names and passwords, and back-end fraud and account monitoring. These technologies provide a high level of security and privacy when you access your account information, initiate online transactions, or send secure messages.
We may use a variety of online technologies, such as cookies, web beacons, and similar mechanisms, as described further below, to collect information that helps us understand how our website are used. Specifically, when you visit Wasatch’s website, we or our third-party service providers may automatically collect a variety of technical and navigational information about you via these technologies, including, as applicable: your computer or device type; operating system version; browser type and version; user agent string; internet connection type; mobile network provider; date and time of your visit; time since your last visit; pages you view; links you click; searches you conduct; the internet protocol (IP) address used to access our website; your general geographic location (e.g., your city, state, or zip code); and the website visited before our site. We also may use similar tracking technologies in emails that we or third parties send to you, as further described below. This information may be used, for example, to alert you to software compatibility issues or to resolve technical or service problems. We also may analyze this information, with the assistance of our service providers, to improve our website design and functionality, to enhance our ability to serve you and your accounts, and to tailor our communications to you regarding our products and services.
Our website and the emails that you receive from Wasatch may use an application known as a web beacon (also known as a pixel tag or clear gif). A web beacon is an electronic file that usually consists of a single-pixel image, embedded in a web or mobile application page or an email to measure usage and activity. In some cases, a web beacon triggers the placement of a persistent cookie on your device.
We and our service providers may use web beacons and cookies to determine whether and when you receive and open our emails; these beacons and cookies may also capture information such as the type of device, operating system, email program, and web browser used to view the email, the IP address from which you opened the email, and whether you click any links in the email. These technologies enable us to gauge the effectiveness, relevance, and value of our email communications, as well as to target relevant advertising to you and to measure the impact of that advertising on your Wasatch relationships.
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 and the effectiveness of our online advertising, as well as to identify Wasatch products and services that may be of interest to you.
Third-party analytics and interest-based advertising
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. The information generated about your use of our online services may be transmitted to and stored by servers of third-party analytics services outside your country of residence.
We may use third-party service providers’ technologies that enable us to establish connections among related devices (such as smartphones, tablets, and computers). This means that information about your interactions with our online services and online advertising through different devices may be combined. By making these connections, we may be able to better understand the relevance of our content and the impact of our advertising and to customize that content and advertising for you.
Your Rights Under California Law
If you are a resident of California, you have rights that you may exercise over the personal information in our possession. Specifically you have:
- 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 in our possession.
- The Right to Non-Discrimination: If you choose to exercise any of these rights, you will not receive any discriminatory treatment from us.
To exercise your right to know or your right to request deletion, please send a detailed request to:
P.O. Box 2172
Milwaukee, WI 53201-2172
In order to protect the integrity of our services, as well as your personal information, we may need to verify your identity before processing any requests. 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 also be subject to identity verification.
What you can do