PRIVACY FOR CONSUMERS AT EMPIREAMERICA

Our goal is to maintain your trust and confidence when handling personal information about you.

YOU HAVE CHOICES

As an EmpireAmerica customer, you have the opportunity to make choices about how personal information about you may be shared. As you consider this, we encourage you to make choices that enable us to provide you with quality products and services that help you meet your financial needs and objectives.

SECURITY OF PERSONAL INFORMATION

The security of personal information about you is our priority. We protect this information by maintaining physical, electronic, and procedural safeguards that meet applicable law. We train our employees in the proper handling of personal information. When we use other companies to provide services for us, we require them to protect the confidentiality of personal information they receive.

ONLINE PRIVACY POLICY

Our Online Privacy Policy describes how we may collect, use and share information you provide when you visit this website, receive our emails or interact with advertisements we have on third-party websites.

OUR ONLINE PRIVACY STATEMENT DOES NOT COVER:

Information collected and used on EmpireAmerica social media sites
Information you provide to the websites we advertise on and may link to

We encourage you to read the privacy policies located on each individual website

WHAT INFORMATION DO WE COLLECT?

We collect two types of online information: non-personal and personal.

NON-PERSONAL INFORMATION

When you visit our site, we collect the IP address of the device you use to connect to the Internet. In addition, we gather information such as what browser and which version of it you’re using, the type of operating system you have, and which site you came from. This information helps us provide an online experience that matches your device.

When you browse our site or receive one of our emails, EmpireAmerica and companies we work with, use cookies and/or pixel tags to collect information and store your online preferences. Cookies are widely used and most browsers are set up to accept them automatically. If you would prefer, you can choose to not accept cookies.

It’s important to note that cookies and pixel tags do not capture any information that can personally identify you. The information they gather helps us improve your online experience and may include:

Whether or not you respond to one of our emails
Time and duration of your visit to our site
Pages you viewed while on our site

PERSONAL INFORMATION

In addition to the information described in the previous section, we may also gather personal information that you provide to us such as your name, address, phone number, and email. Collecting this personal information enables us to offer you online experiences that help you with your financial needs. For example, we collect personal information when you are:

APPLYING FOR A NEW PROGRAM OR MORTGAGE

If we have personal information from you, or information that’s publicly available from other sources, we may use it in combination with the information that EmpireAmerica has collected online. We can use this information to better tailor and personalize our service and marketing communications with you, both online and offline.

Please see the Privacy Statement, which we provide to all our customers, for a comprehensive explanation of how we collect, use and share personal information and what you can do to limit the use and sharing of your information.

HOW DO WE USE THE INFORMATION WE COLLECT?

EmpireAmerica uses the information we collect about and from you to manage our business and to offer an enhanced, personalized online experience on our site and third-party websites.

THE INFORMATION WE COLLECT ALLOWS US TO:

Recognize you when you return to our site
Process applications and transactions
Respond to your requests

CAN YOU CONTROL YOUR INFORMATION THAT’S COLLECTED AND USED ONLINE?

It’s important to note that the information we use about you helps us provide you with products, services and experiences that benefit you. You have the ability to control how your non-personal information is collected and used online.

COOKIES

You can control whether to accept cookies or not. If you decide to not accept cookies, some features and services on our site may not work properly because we may not be able to recognize and associate you with your EmpireAmerica account.

If you would prefer not to accept cookies, you can:

Change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it.
Set your browser to automatically not accept any cookies.

NOTICE OF CHANGES

From time to time, we may change this Online Privacy Policy. The effective date of this policy, as stated below, indicates the last time it was revised or materially changed. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the policy.

EFFECTIVE DATE

This policy was last modified April 17, 2013.

COMPANIES WE WORK WITH

These companies are any third-party agents that conduct business on behalf of EmpireAmerica. The services they provide include, but are not limited to, communications (e.g., email), marketing, data processing, and customer acquisition and servicing.

When we use other companies to provide services for us, we require them to protect the confidentiality of information they receive.

COOKIES

A cookie is a small text file that a web server may place on your computer when you visit a site. The file uniquely identifies a computer. Information stored in a cookie sent by EmpireAmerica can only be read by EmpireAmerica or companies we work with.

IP ADDRESS

An Internet Protocol address is a unique number, assigned to a computer or device that connects to the Internet that identifies that computer or device.

PERSONAL INFORMATION

Information such as name, addresses, telephone number, and email address that identifies a person.

PIXEL TAG

A pixel tag is a transparent graphic image, sometimes called a web beacon or tracking beacon, placed on a web page or in an email, which indicates that a page or email has been viewed. In addition, a pixel tag may tell your browser to get content from another server.

The pixel tags are on EmpireAmerica’s sites. In order to ensure the safekeeping of your information, network advertising companies and publishers are not permitted to directly collect information on our site.

THIRD-PARTY WEBSITES

These are sites that are not operated by EmpireAmerica and are not subject to our Online Privacy Statement. We encourage you to read the privacy policies on these sites.

OVERVIEW

At EmpireAmerica, client confidentiality is the cornerstone of our business. Accordingly, ensuring data security of our clients is a top priority.

While EmpireAmerica employs various security practices and measures in order to protect the confidential information of its clients, as the end user, you play an important role in safeguarding against risks such as those related to virus attacks, unauthorized access and fraudulent online transactions.

Below are best practices and guidelines to help you protect yourself and understand your role with respect to the Internet. This guidance is applicable to both wholesale and retail clients.

INTERNET FRAUD AND PHISHING

Phishing, the practice of using fraudulent e-mails and copies of legitimate websites to extract financial data and other personal information from unsuspecting computer users, continues to expand in sophistication and customers of financial institutions and brokerages are increasingly targets of these scams.

Because phishing materials often look genuine and may appear to originate from real people, organizations, institutions, and websites, the following precautions are suggested:

E-MAIL PRECAUTIONS:

Be cautious about clicking any links, opening any attachments, or downloading any files from e-mails regardless of file type or who sent them.

Never open a website using a link provided in a suspicious e-mail. Links and the e-mail sender address can be forged.

Avoid including sensitive personal information in e-mail messages. A better practice is to call a company directly.

Be wary of any request that asks you to perform an urgent action (e.g., “Security Check”, “Activation”, “Verification” or any request to wire funds or make other payments).

ONLINE BANKING AND FINANCIAL SERVICES PRECAUTIONS:

Always type the official website address (URL) when logging into your financial institution or brokerage.

When logging into the website, check for a letter ‘s’ immediately after the “http” prefix and for the closed lock icon at the right-hand bottom of the screen. This indicates that both the site and connection are encrypted. A green background may also be evident in the address bar which may also indicate a higher level of security.

Review financial services websites for their privacy policies and guidance on staying safe online.

COMPUTER SYSTEM PRECAUTIONS:

Keep computer software (e.g., system patches, anti-virus, and anti-spyware) up to date with the latest security patches.
Contact the relevant institution immediately if you notice anything irregular with your bank account or other online accounts.

If your computer and/or Internet connection appear erratic or crash unusually during an online session, disconnect the session and contact your institution’s IT support desk for assistance.

UNSOLICITED COMMUNICATIONS

E-mail fraud is a common way that thieves attempt to steal your information. Here are some examples of methods used:

Illegitimate offer e-mails advertise the sale of items at a reduced or even unrealistic price in order to obtain credit card or other financial information. Usually, the purchased products are not delivered.

Requests for assistance scams usually offer the recipient large sums of money in exchange for financial assistance. A common example involves requesting a user’s bank account information in order to facilitate a deposit into the user’s account. This information is then likely used for fraudulent purposes.

Phony sender e-mails purport to come from executives of an organization (e.g. John Doe, CEO). These e-mails often request personal or confidential information and may contain a “special” offer in order to solicit a response.

When contacting your financial institution or sender to verify a request for information, use only a phone number that comes from a reliable source (e.g., the back of your bank card, the phonebook, or bank statements).

EmpireAmerica will periodically contact clients through different channels such as email and phone, but will never request that the client provide their electronic credentials or passwords on an unsolicited basis.

Spam messages are targeted, mass-distributed, unsolicited e-mails. These e-mails may contain offers to buy items, attempt to solicit your business, or invite you to visit a website. Unfortunately, while these offers may appear legitimate, many people have lost money responding to offers that are often fraudulent.

HERE ARE SOME TIPS TO HELP YOU AVOID SPAM SCAMS:

Protect your information. Do not share any personal or financial information with unverified or questionable organizations or individuals.

Question the provider. Know who the business is and its contact information.

Time is on your side. Be wary of e-mails that implore you to “act immediately.”

Read the fine print. All contracts should be in writing and carefully reviewed prior to transmission.

Be wary of free offers. Never exchange payment or financial information on order to obtain a free item.

Never buy anything advertised in an unsolicited message.

Be proactive in securing your data. It is advisable to periodically evaluate the risks that you face when conducting business online and take the appropriate steps to ensure that your business activities and data are safeguarded.

HOW TO CONTACT EMPIREAMERICA

Contact EmpireAmerica when you notice any suspicious activity or experience any information security related events.