Privacy Policy

Your privacy is important to us. Protego Trust Company and its affiliate (collectively, the “Company,” “we” or “us”) wants you to be familiar with how we collect, use and disclose Personal Information online. This Privacy Policy describes our practices in connection with Personal Information that we collect through:      

  • Websites operated by us, including the one from which you are accessing this Online Privacy Policy (the “Websites”);
  • HTML-formatted e-mail messages that we may send to you that link to this Privacy Policy.

Collectively, we refer to these Websites and e-mails as the “Services.” This Privacy Policy, together with the Terms and Conditions posted on the Website, set forth the general rules and policies governing your use of our Website.

Personal Information

“Personal Information” is information that identifies you as an individual or that relates to you as an identifiable individual.  The Services collect Personal Information, including:

  • Contact information, such as name, e-mail address and telephone number;
Collection of Personal Information

We and our service providers collect Personal Information through theServices in a variety of ways.  For example, we collect Personal Information when you use the “Contact Us” feature of our Website to send us a message.

Use of Personal Information

We and our service providers use Personal Information for the following purposes:

  • Delivering products and services to you or your business, such as:

<ul role="list" class="list-dash"><li>To support the functionality of the Services, such as providing you with related customer service.</li></ul>

<ul role="list" class="list-dash"><li>To send administrative information to you, such as changes to our terms, conditions and policies.</li></ul>

  • Accomplishing our business purposes, such as:

<ul role="list" class="list-dash"><li>For data analysis, for example, to improve the efficiency of our Services.</li></ul>

<ul role="list" class="list-dash"><li>For audits, to verify that our internal processes function as intended and to address legal, regulatory and contractual requirements.</li></ul>

<ul role="list" class="list-dash"><li>For fraud prevention and monitoring and cybersecurity purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.</li></ul>

<ul role="list" class="list-dash"><li>For developing new products and services.</li></ul>

<ul role="list" class="list-dash"><li>For enhancing, improving, repairing, maintaining and modifying our current products and services.</li></ul>

<ul role="list" class="list-dash"><li>For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.</li></ul>

  • Providing you with our newsletter and/or other marketing materials, such as:

<ul role="list" class="list-dash"><li>To send you marketing related e-mails, with information about our services, new products and other news about our company.</li></ul>

  • Analyzing Personal Information to improve and provide personalized services, such as:

<ul role="list" class="list-dash"><li>To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.</li></ul>

<ul role="list" class="list-dash"><li>To better understand your interests and preferences, so that we can personalize our interactions with you and provide you within formation and/or offers tailored to your interests.</li></ul>

  • Aggregating and/or anonymizing Personal Information.

<ul role="list" class="list-dash"><li>We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information.  We do so to create other data that no longer identifies you and which we may use and disclose for any purpose.</li></ul>

Disclosure of Personal Information

We disclose Personal Information:

  • To our affiliates for the purposes described in this Privacy Policy.
Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate:

  • To comply with applicable law and regulations.
  • To cooperate with public and government authorities and law enforcement, such as:

<ul role="list" class="list-dash"><li>To respond to a law enforcement request or provide information we believe is necessary or appropriate.</li></ul>

<ul role="list" class="list-dash"><li>To respond to a regulator’s examination requests.</li></ul>

  • For other legal or audit reasons, such as:

<ul role="list" class="list-dash"><li>To enforce our terms and conditions.</li></ul>

<ul role="list" class="list-dash"><li>To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others. </li></ul>

  • To facilitate or evaluate a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock(including in connection with any bankruptcy or similar proceedings).
Other Information

Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual.  The Services collect Other Information, such as:

  • Browser and device information
  • App usage data
  • Information collected through cookies, pixel tags or other technologies
  • Demographic and other information provided by you that does not reveal your specific identity
  • Information that has been aggregated in a manner such that it no longer reveals your specific identity
Collection of Other Information

We and our service providers may collect Other Information in a variety of ways, including through:

  • Your browser or device.

<ul role="list" class="list-dash"><li>Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language and Internet browser type and version. We use this information to ensure that the Services function properly.</li></ul>

  • Cookies.

<ul role="list" class="list-dash"><li>Cookies are pieces of information stored directly on the computer that you are using.</li></ul>

Cookies allow us to collect various information, such as browser type, time spent on the Services, pages visited, language preferences and other traffic data.  We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively and to personalize your experience.  We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.  We do not currently respond to browser do-not-track signals.  If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website.  You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html.  If, however, you do not accept cookies, you may experience some inconvenience in your use of or may not be able to access certain of the Services.  By continuing to use the Services without changing your cookie settings, you hereby acknowledge and agree to our use of cookies.

  • Pixel tags and other similar technologies.

<ul role="list" class="list-dash"><li>Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including e-mail recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.</li></ul>

<ul role="list" class="list-dash"><li>Analytics.  We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.  This service may also collect information regarding the use of other websites, apps and online resources.  You can learn about Google’s practices by going to www.google.com/policies/privacy/‌partners/, and can exercise the opt-out right provided by Google by downloading theGoogle Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.</li></ul>

<ul role="list" class="list-dash"><li>Invisible reCAPTCHA. We use Google’s invisible reCAPTCHA application on our Services in order to protect against spam and other automated abuse.  The reCAPTCHA tool may make use of cookies, as well as other information like IP address, date, time, language, screen size and resolution, and mouse movements.  The use of the reCAPTCHA tool and any information collected through the tool are subject to Google’s privacy policy, available at https://policies.google.com/privacy, and Google’s terms of service, available at https://policies.google.com/terms?hl=en.</li></ul>

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.  In some instances, we may combine Other Information with Personal Information.  If we do, we will treat the combined information as Personal Information.

Security

We seek to use reasonable organizational, technical and administrative measures that are designed to protect Personal Information within our organization.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us as provided in the “Contacting Us” section below.

Third-Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy or other practices of any third parties, including any third party operating any website or service to which the Services may link.  The inclusion of a link on the Services does not imply endorsement of the linked site or service by us.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Services.

Use of Services by Minors

The Services are not directed to individuals under the age of thirteen (13).  We do not knowingly collect Personal Information from individuals under the age of 13.

Updates to this Privacy Policy

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy on the Services. Your continued use of the Services after any change in this Privacy Policy will constitute your acceptance of such change.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at inquiries@protegotrust.com.

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