Kolden Consulting (KC) is committed to safeguarding the use of your personal information that is obtained during the normal course of business. KC’s policy is to protect the security and confidentiality of personal information and ensure that such information is used for proper business purposes in connection with the management or servicing of your account. KC’s relationship with you is our most important asset and we understand that you have entrusted KC with your private information, and will do everything we can to maintain that trust. This Privacy Policy has been adopted to promote the protection of client non-public information.

KC respects the privacy of its clients and acts to meet the expectations of its clients in this regard. KC does not sell your non-public personal information to anyone. Nor does KC provide such information to others except for discrete and proper business purposes in connection with the servicing and management of accounts as discussed below. Details of KC’s approach to privacy and how your personal non-public information is collected and used are set forth in this privacy policy.

Information Kolden Consulting Collects

KC typically receives personal information when you complete the paperwork required to become a Client. Your information may include:

Name and address

Email address

Phone number

Social security or taxpayer identification number

Accounts at other institutions

Assets

Income

Account balance

Investment activity

Usage Data

In addition, KC may collect non-public information about you from the following sources:

Information KC receives on Brokerage Agreements, Managed Account Agreements and other Subscription and Account Opening Documents; Information KC receives in the course of establishing a customer relationship including, but not limited to, applications, forms, and questionnaires; Information about your transactions with KC or others.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Information from Third-Party Social Media Services

The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:

Google

Facebook

Instagram

Twitter

LinkedIn

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service's account, such as Your name, Your email address, Your activities or Your contact list associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

Cookies or Browser Cookies

A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.

Web Beacons

Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session"
Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Information Kolden Consulting May Disclose

KC works to provide products and services that benefit our customers. KC typically does not share non-public client information with non-affiliated third parties (such as brokers and custodians) other than as necessary for KC to provide agreed services and products to you consistent with applicable law.

For example, KC may disclose non-public personal information to other financial institutions with whom there are joint business arrangements for proper business purposes in connection with the management or servicing of your account. In addition, your non-public personal information may also be disclosed to you, persons KC believes to be your authorized agent or representative, regulators in order to satisfy KC’s regulatory obligations, and as otherwise required or permitted by law.

Lastly, KC may disclose your non-public personal information to companies KC hires to help administrate our business. Companies hired to provide services of this kind are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality. KC limits their use of your personal information to the performance of the specific service(s) that are requested.

To repeat, KC does not sell your non-public personal information to anyone.

Information About Former Clients

KC does not disclose, and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer clients.

Confidentiality and Security

KC employees understand the requirement to respect the confidentiality of customers’ non-public personal information and KC periodically trains and educates employees in the handling and safeguarding of personal information in accordance with applicable laws, rules, and regulations. Additionally, KC maintains physical, procedural and electronic safeguards in an effort to ensure the security and confidentiality of customer records and to protect the information from access by unauthorized parties. Employees who violate these policies are subject to disciplinary action, up to and including termination.

KC understands the need to provide a secure environment for physical and electronic non-public client information. In addition to building security provided by building management, KC has various controls in place to protect the security of the firm’s offices. Administrators in each office monitor visitors to the office and are trained on procedures for handling unauthorized individuals.

KC regularly assesses its ability to protect the firm’s network against unauthorized access to its electronic data by outside parties, and has systems designed to prevent intrusions. Systems are monitored and any potential security breaches are reviewed immediately and resolved on a high priority basis.

KC’s vendor websites utilized for reporting account information to KC clients have security features designed to protect against unauthorized access to client information. KC will perform assessments of the contract provisions and confidentiality and privacy policies of the service provider(s) to determine if appropriate safeguards for protecting customer information accessible to the provider are in place.

KC will annually test the information safeguards to ensure that they remain effective. KC will also attempt to annually identify reasonably foreseeable risks to information security and assess the effectiveness of existing safeguards for controlling these risks.