Website Terms & Conditions of Use, Privacy Policy, Mobile App Policy, Form ADV Parts 2A & 2B

Welcome to Portfolio Solutions! Please carefully read these Terms and Conditions of Use (“Terms of Use”), Privacy Policy and Mobile App Policy carefully before using this website ("Site").

Acceptance of the Terms of Use

This website is owned and operated by Portfolio Solutions, LLC ("Portfolio Solutions"). Portfolio Solutions is a Registered Investment Advisor (“RIA”), with the U.S. Securities and Exchange Commission (“SEC”) that maintains a principal place of business in the State of Michigan. Portfolio Solutions owns and operates this website ("Site"). Portfolio Solutions provides investment advisory and related services for clients nationally. Portfolio Solutions will maintain all applicable registration and licenses as required by the various states in which Portfolio Solutions conducts business, as applicable. By using the Site, you agree to be legally bound by these Terms of Use and you agree to the processing of your personal data in accordance with our Privacy Policy.

If you do not agree with these Terms of Use or Our Privacy Policy, you should not use the Site. Please save and/or print a copy of these Terms of Use and Our Privacy Policy for your future reference. These Terms of Use set out the terms and conditions on which we agree to make available and you agree to access and use the Site. Portfolio Solutions may modify, suspend, discontinue, or restrict the use and availability of any portion of this Site at any time, without notice or liability. Your use of this Site may be monitored by Portfolio Solutions and used for Portfolio Solutions' internal business purposes, without liability.

The information in this Site is based on data gathered from what we believe to be reliable sources and is intended to provide general information about Portfolio Solutions and its services. Portfolio Solutions does not guarantee the accuracy of the information contained in this Site. Information throughout this Site, whether stock quotes, charts, or any other statement or statements regarding market or other financial information is not guaranteed for timeliness or accuracy and is not intended as the primary basis for investment decisions. It should also not be construed as advice meeting the particular investment needs of any investor or to offer or deliver investment advice in any way. Information regarding investment services are provided solely to gain an understanding of our investment philosophy, our strategies and to be able to contact us for further information. Asset allocation may be used to manage risk and enhance returns. It does not, however, guarantee a profit or protect against loss. Performance of the asset allocation strategies depends on the underlying investments. There is no guarantee that you will be profitable using any of the ideas or strategies presented in this Site. Examples in our materials are not to be interpreted as a promise or guarantee of earnings. Past performance cannot be an indication of possible future results.

Email Disclosures

Portfolio Solutions often communicates with its clients and prospective clients through electronic mail (“email”) and other electronic means. Your privacy and security are very important to us. Portfolio Solutions makes every effort to ensure that email communications do not contain sensitive information. We remind our clients and others not to send Portfolio Solutions private information over email. If you have sensitive data to deliver, we can provide secure means for such delivery.

Amendments to Terms of Use

We may amend these Terms of Use from time to time. If we do, we will publish the changes on the Site. It is your responsibility to check the Site periodically for changes to these Terms of Use. The date at the top of this webpage indicates when these Terms of Use were last updated. Amendments to these Terms of Use will take effect 5 days after the date on which we publish the amendments on the Site, and from then on will govern the relationship between you and us in respect of your use of the Site. If you do not agree with the amended Terms of Use, you must not continue to use the Site after the date on which the amendments take effect.  Your use of the Service is governed by the version of these Terms of Use in effect on the date of use.                     

Your obligations

You agree not to: Use or access the Site for any fraudulent or unlawful purpose; Use or access the Site to impersonate any person or entity; Interfere with or disrupt the operation of the Site or access to it; Transmit or otherwise make available in connection with the Site or access to it any virus, worm, Trojan horse, time bomb, spyware, or other malicious computer code, file, or program; Restrict or inhibit the ability of any other person to access or use the Site; Modify, adapt or translate any portion of the Site; or Remove, obscure or modify any copyright, trade mark, or other proprietary rights notice from the Site.

PORTFOLIO SOLUTIONS® FORM ADV PARTS 2A & 2B

Portfolio Solutions® is registered and regulated by the U.S. Securities and Exchange Commission (SEC). The SEC requires that all clients and potential clients have access upon request to a copy of Form ADV Parts 2A & 2B that outlines important information about Portfolio Solutions®, business methods, fees, professional qualifications and all other pertinent business information. Form ADV Parts 2A & 2B provides details of the services we offer as well as the backgrounds of principals. It also includes a narrative of our fees, investment strategies and how we conduct business. Form ADV Parts 2A & 2B can be downloaded here.

Applicable Law and Venue

The laws of the State of Michigan, United States of America, without regard to principles of conflict of laws, govern these Terms of Use and any dispute that might arise between you and Portfolio Solutions. This is the case regardless of whether you reside or transact business with Portfolio Solutions in Michigan or elsewhere. If you take legal action relating to these Terms of Use, you agree to submit to the personal and exclusive jurisdiction and to file such action either in the 6th Circuit Court of Oakland County, Michigan, or the United States District Court for the Eastern District of Michigan and in no other venue, and you consent and submit to the personal jurisdiction of those courts for the purposes of litigating any such action.

 

BLOG DISCLOSURE

Performance data shown represents past performance, which is not a guarantee of future results. Inherent in any investment is the potential for loss as well as the potential for gain. Investment returns and principal value will fluctuate, so investors’ shares, when sold, may be worth more or less than their original cost. Current performance may be lower or higher than the performance data cited. Investing involves risk, including possible loss of principal. “It should not be assumed that the recommendations made in the future will be profitable or will equal the performance of the securities in this article.” Therefore, no current or prospective client should assume that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Portfolio Solutions®) referred to directly or indirectly by Portfolio Solutions® in its web site, or indirectly via a link to an unaffiliated third-party web site, will be profitable or equal the corresponding indicated performance level(s). Different types of investments involve varying degrees of risk, and there can be no assurance that any specific investment will either be suitable or profitable for a client or prospective client’s investment portfolio nor that the future performance of any specific investment or investment strategy (including those undertaken or recommended by Portfolio Solutions®), will be profitable or equal any historical performance level(s). Future returns may differ significantly from the past due to materially different economic and market conditions and other factors. Investments within portfolios, and therefore, portfolios, involve risk and the possibility of loss, including a permanent loss of principal. Investment Return comparisons may employ a variety of popular indexes. Exposure to an asset class represented by an index is available through investable instruments based on that index. Portfolio Solutions® does not sponsor, endorse, sell, promote or manage any investment fund or other investment vehicle that is offered by third parties and that seeks to provide an investment return based on the performance of any index. Portfolio Solutions® makes no assurances that investment products based on the index will accurately track index performance or provide positive investment returns. A decision to invest in any investment fund should not be made in reliance on any statements set forth in this article. Prospective investors are advised to make an investment in any such fund only after carefully considering the risks associated with investing in such funds, as detailed in the offering memorandum, prospectus or similar document that is prepared by or on behalf of the issuer of the investment fund. Inclusion of a mutual fund, REIT or bond fund within an index is not a recommendation by Portfolio Solutions® to buy, sell or hold such security, nor is it considered to be investment advice. This document has been prepared solely for information purposes based upon information generally available to the public from sources considered to be reliable. Hypothetical illustrations are not exact representations of any particular investment, as you cannot invest directly in an index or fund-group average. Bond funds are subject to the risk that an issuer will fail to make payments on time, and that bond prices will decline because of rising interest rates or negative perceptions of an issuer’s ability to make payments. Diversification does not ensure a profit or protect against a loss in a declining market. A complete list of all Portfolio Solutions’ recommendations for the immediately preceding period of not less than one year is available upon request. Holdings are subject to change. The holdings identified do not represent all of the securities purchased, sold or recommended for advisory clients. Portfolio Solutions® or one or more of its officers, may have a position in the securities discussed herein and may purchase or sell such securities from time to time.

Copyright Policy, Notice, and Claim Information

All data, information, content, software, RSS and podcast feeds, products, services, or other materials on, generated by or obtained from this Site, whether through links or otherwise (collectively, "Materials") on this Site, whether separate or compiled, including, but not limited to, text, graphics, audio clips, logos, buttons, images, digital downloads, data compilations, software, icons, html code and xml code, as well as all copyright, patent, trademark, trade dress, and other rights therein, are owned or licensed by Portfolio Solutions and its third-party information providers, and are protected by United States and international intellectual property laws.

Pursuant to Section 512(c)(2) of the Copyright Revision Act, as enacted through the Digital Millennium Copyright Act, Portfolio Solutions designates an agent as described below to receive notifications of claimed copyright infringement by mail: Florence Affatato, Chief Legal Officer, Portfolio Solutions, LLC, 900 Wilshire Drive, Suite 200, Troy, MI.

 

Data, Information, and Content

The Materials on this Site are for information, education, and noncommercial purposes only. Although Portfolio Solutions may provide data, information, and content relating to investment approaches and opportunities to buy or sell securities and/or mutual funds, you should not construe any such information or other content available through this Site as legal or tax advice.

You are responsible for evaluating the merits and risks associated with the use of any Materials on this Site before making any decisions based on such Materials. In exchange for using such Materials, you agree not to hold Portfolio Solutions liable for any possible claim for damages arising from any decision you make based on the Materials made available to you through this Site. By providing access to other websites, neither Portfolio Solutions nor any of its affiliates is recommending the purchase or sale of the stock issued by any company, nor are they endorsing services provided by any website's sponsoring organization.

 

International Use

Because of the global nature of the Internet, you agree to comply with all local rules with respect to your account and your online conduct, including all laws, rules, codes, and regulations of the country in which you reside and the country from which you access this Site, including without limitation, all laws, rules, codes, regulations, decrees, acts, orders, directives, legislation, bills, and statutes pertaining to tax, contracts, intellectual property, securities, e-commerce, banking, technology, computers, fraud, and privacy. In addition, you agree to comply with all applicable laws, rules, codes, and regulations regarding the transmission of technical data exported from the United States. Each investment product and service referred to on this Site is intended to be made available only to U.S. residents. This Site will not be considered a solicitation for or offering of any investment product or service to any person in any jurisdiction where such solicitation or offering would be illegal.

 

Liability and Indemnity

ANY MATERIALS DOWNLOADED OR OTHERWISE OBTAINED THROUGH THIS SITE ARE DONE AT YOUR OWN RISK. YOU ARE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR COMPUTER SYSTEM OR OTHER EQUIPMENT, OR LOSS OF DATA THAT RESULTS FROM SUCH DOWNLOAD.NEITHER PORTFOLIO SOLUTIONS NOR ITS AFFILIATES, SUBSIDIARIES, DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, LICENSORS, OR ANY THIRD-PARTY INFORMATION PROVIDERS AND VENDORS WILL BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES, INCLUDING BUT NOT LIMITED TO, DAMAGES FOR LOSS OF PROFITS, REVENUE, INCOME, GOODWILL, USE, DATA, OR OTHER INTANGIBLE LOSSES, OR DAMAGES CAUSED BY THEFT, UNAUTHORIZED ACCESS, SYSTEMS FAILURE, OR COMMUNICATIONS LINE FAILURE, OR THE COST OF PROCURING SUBSTITUTE GOODS OR SERVICES, CAUSED BY THE USE OF OR INABILITY TO USE THE SITE, MATERIALS OR ANY PRODUCTS OR SERVICES PROVIDED HEREIN, OR ANY OTHER MATTER RELATING TO THIS SITE, EVEN IF PORTFOLIO SOLUTIONS HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THE ABOVE EXCLUSIONS OR LIMITATIONS MAY NOT APPLY TO YOU. TO THE EXTENT THAT A JURISDICTION DOES NOT PERMIT THE EXCLUSION OR LIMITATION OF LIABILITY AS SET FORTH HEREIN, THE LIABILITY OF PORTFOLIO SOLUTIONS AND ITS AFFILIATES, SUBSIDIARIES, DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, LICENSORS, AND ANY THIRD-PARTY INFORMATION PROVIDERS AND VENDORS IS LIMITED TO THE EXTENT PERMITTED BY LAW IN SUCH JURISDICTIONS.

You agree to indemnify, defend, and hold harmless Portfolio Solutions, its subsidiaries and affiliates, and each of its and their officers, directors, employees, and agents, from and against all claims, demands, liabilities, damages, losses, or expenses, including attorney's fees and costs, arising out of or related to your improper access to or use of this Site, or any violation by you of these Terms of Use.

 

Limited License and Restrictions on Use

Portfolio Solutions grants you a limited, revocable, nonexclusive, non-transferable license to view, store, bookmark, download, and print the pages within this Site solely for your personal, informational, and noncommercial use or as expressly authorized by Portfolio Solutions in writing. You are responsible for obtaining and maintaining all equipment, services, and other materials that you need to access this Site. Portfolio Solutions reserves all rights not expressly granted in these Terms of Use. Except as otherwise stated in these Terms of Use or as expressly authorized by Portfolio Solutions in writing, you may not (or enable others to): Modify, copy, screen capture, distribute, forward, transmit, post, display, perform, reproduce, publish, broadcast, license, create derivative works from, transfer, sell, or exploit any Materials; Redeliver any page, text, image, or Materials on this Site using "framing" or other technology; Engage in any conduct that could damage, disable, or overburden (i) this Site, (ii) any Materials or services provided through this Site, or (iii) any systems, networks, servers, or accounts related to this Site, including without limitation, using devices or software that provide repeated automated access to this Site, other than those made generally available by Portfolio Solutions; Probe, scan, or test the vulnerability of any Materials, services, systems, networks, servers, or accounts related to this Site or attempt to gain unauthorized access to Materials, services, systems, networks, servers, or accounts connected or associated with this Site through hacking, password or data mining, or any other means of circumventing any access-limiting, user authentication or security device of any Materials, services, systems, networks, servers, or accounts related to this Site; Modify, copy, obscure, remove, or display Portfolio Solutions 's name, logo, trademarks, text, notices, or images without Portfolio Solutions' express written permission; Include the term " Portfolio Solutions," or any Portfolio Solutions trademark or executive's name, or any variation of the foregoing, as a meta-tag, hidden textual element, or any other indicator that creates an impression of affiliation, sponsorship, or endorsement by Portfolio Solutions. To obtain such permission, you may e-mail us at legal@portfoliosolutions.com.

Linking Conditions

You may not link to this Site unless you comply with these linking conditions ("Linking Conditions"). Portfolio Solutions grants you a limited, revocable, nonexclusive right to create a hyperlink to this Site ("Link"), provided you always comply with the following conditions: The Link must resolve to www.portfoliosolutions.com, and must be unaltered in any way; The text of the Link must read either "Portfolio Solutions," or "www.portfoliosolutions.com."  You may not use any Portfolio Solutions’ logo or graphic, or any other Portfolio Solutions’ trademark, as part of the Link without Portfolio Solutions’ express written permission consent; and the Link and surrounding context on the linking site must not: (a) falsely represent or misrepresent any relationship between the linking site and Portfolio Solutions, including suggestions of affiliation, endorsement, or sponsorship; (b) portray Portfolio Solutions or its affiliates, or their products or services, in a false, misleading, derogatory, or otherwise offensive manner; or (c) deliver the Materials in a framed environment or alter the layout, content, look, or feel of the Site. If you have created a Link that conforms to these Linking Conditions, then you also may include one or more Links to any internal or subsidiary page of this Site that is located one or several levels down from the homepages (known as "deep links"), provided, however, that all such deep links must be in close physical proximity to the Link that conforms to the Linking Conditions. You may not maintain numerous or pervasive Links to this Site.

 

You agree not to use the Site to:

  • Submit, upload, post, e-mail, transmit, or otherwise make available any User Content that is unlawful, harmful, threatening, abusive, menacing, harassing, tortious, defamatory, vulgar, pornographic, obscene, offensive, blasphemous, libelous, unlawful, invasive of another’s privacy or publicity rights, hateful, or racially, ethnically, or otherwise objectionable;   
  • Submit, upload, post, e-mail, transmit, or otherwise make available any User Content that personally attacks or is derogatory toward Portfolio Solutions as an entity, Portfolio Solutions employees, any Portfolio Solutions products or services, or any Portfolio Solutions Materials; 
  • Harm minors in any way, including, but not limited to, submitting, uploading, posting, e-mailing, transmitting, or otherwise making available content that violates child pornography laws, child sexual exploitation laws, or laws prohibiting the depiction of minors engaged in sexual conduct; 
  • Impersonate any person or entity, or falsely state or otherwise misrepresent your affiliation with a person or entity; 
  • Forge headers or otherwise manipulate identifiers to disguise the origin of any User Content transmitted through the Site; 
  • Submit, upload, post, e-mail, transmit, or otherwise make available any User Content that you do not have a right to make available under any law or contractual or fiduciary relationships or obligations; 
  • Submit, upload, post, e-mail, transmit, or otherwise make available any User Content that infringes, violates, or misappropriates any patent, trademark, trade secret, copyright, or other intellectual property or proprietary right or any moral right of any party; 
  • Submit, upload, post, e-mail, transmit, or otherwise make available any personal information or specific account details about yourself or any person or entity; 
  • Submit, upload, post, e-mail, transmit, or otherwise make available any advertising, promotional materials, junk mail, spam, chain letters, pyramid schemes, or any other form of solicitation; 
  • Submit, upload, post, e-mail, transmit, or otherwise make available any material that contains viruses, or any other computer code, files, or programs designed to interrupt, destroy, or limit the functionality of any computer software or hardware or telecommunications equipment; or 
  • Intentionally or unintentionally violate any applicable local, state, national, or international laws, rules, regulations, decrees, acts, orders, directives, legislation, bills, or statutes.

Third-party Links and Content

At certain places on our Site we offer direct access or ‘links’ to other internet sites. These sites contain information that has been created, published, maintained or otherwise posted by institutions or organizations independent of Portfolio Solutions. Portfolio Solutions is not responsible for, and does not prepare, edit, or endorse, the content, advertising, products, or other materials on or available from any website owned or operated by a third party that is linked to this Site via hyperlink. The fact that Portfolio Solutions has provided a link to a third party's website does not constitute an implicit or explicit authorization, sponsorship, or affiliation by Portfolio Solutions with respect to such website, its owners, providers, or services. Your use of any such third-party content is at your own risk and you agree that Portfolio Solutions is not liable for any loss or damage that you may suffer by using third-party websites or any content, advertising, products, or other materials in connection therewith.  Data and other materials appearing on this Site that are provided by third parties are believed by Portfolio Solutions to be obtained from reliable sources, but Portfolio Solutions cannot guarantee and is not responsible for their accuracy, timeliness, completeness, or suitability for use.  Portfolio Solutions shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused with use of such websites or content. Your use of such websites or resources shall be subject to the terms and conditions set forth by them. All such information is provided solely for convenience and information purposes. Visitors to these Sites should not use or rely on the information contained therein until consulting with an independent finance professional.

Social Websites

Portfolio Solutions may utilize third-party websites, including social media websites, blogs and other interactive content. Portfolio Solutions considers all interactions with clients, prospective clients and the public on these sites to be advertisements under the securities regulations. As such, Portfolio Solutions generally retains copies of information that Portfolio Solutions or third-parties may contribute to such sites.

Information provided on these sites is for informational and/or educational purposes only and is not, in any way, to be considered investment advice nor a recommendation of any investment product. Advice may only be provided by Portfolio Solutions’ financial advisors after entering into an investment management agreement and provided Portfolio Solutions with all requested background and account information.

Timeliness of Content

All content on this Site is presented only as of the date published or indicated and may be superseded by subsequent market events or for other reasons. In addition, you are responsible for setting the cache settings on your browser to ensure you are receiving the most recent data.

 

Trademarks

All trademarks, service marks, and logos appearing on this Site are the exclusive property of their respective owners. All Portfolio Solutions’ graphics, logos, page headers, and service names are trademarks, service marks, or trade dress of Portfolio Solutions. Portfolio Solutions’ trademarks, service marks and trade dress may not be used in connection with any product or service that is not Portfolio Solutions’, in any manner that is likely to cause confusion among customers or investors, or in any manner that disparages or discredits Portfolio Solutions. Nothing contained on this Site should be construed as granting any license or right in or to any trademarks, service marks, or trade dress of Portfolio Solutions.

CFA®and Chartered Financial Analyst® are trademarks owned by the CFA Institute.

 

Certified Financial Planner Board of Standards Inc. owns the certification marks CFP®, CERTIFIED FINANCIAL PLANNER™, CFP® (with plaque design) and CFP® (with flame design) in the U.S., which it awards to individuals who successfully complete the CFP Board’s initial and ongoing certification requirements.

Warranty Disclaimers

YOU EXPRESSLY UNDERSTAND AND AGREE THAT: YOUR USE OF THIS SITE IS PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS. TO THE FULL EXTENT PERMITTED UNDER APPLICABLE LAW, PORTFOLIO SOLUTIONS AND ITS AFFILIATES, SUBSIDIARIES, DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, LICENSORS, AND ANY THIRD-PARTY INFORMATION PROVIDERS AND VENDORS EXPRESSLY DISCLAIM ALL WARRANTIES, WHETHER EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION, ANY IMPLIED WARRANTIES OF TITLE, MERCHANTABILITY, NONINFRINGEMENT, AND FITNESS FOR A PARTICULAR PURPOSE, AND ALL WARRANTIES REGARDING SECURITY, CURRENCY, CORRECTNESS, QUALITY, ACCURACY, COMPLETENESS, RELIABILITY, PERFORMANCE, TIMELINESS, OR CONTINUED AVAILABILITY, WITH RESPECT TO (I) THE SITE; (II) ANY MATERIALS, PRODUCTS, OR SERVICES AVAILABLE ON OR THROUGH THE SITE; (III) USE OF THE SITE, MATERIALS, PRODUCTS, OR SERVICES; AND (IV) THE RESULTS OF THE USE OF THE SITE, MATERIALS, PRODUCTS, OR SERVICES.

FURTHER, PORTFOLIO SOLUTIONS AND ITS AFFILIATES, SUBSIDIARIES, DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, LICENSORS, AND ANY THIRD-PARTY INFORMATION PROVIDERS AND VENDORS EXPRESSLY DISCLAIM ALL WARRANTIES WITH RESPECT TO ANY DELAYS OR ERRORS IN THE TRANSMISSION OR DELIVERY OF ANY MATERIALS, PRODUCTS, OR SERVICES AVAILABLE THROUGH THIS SITE. EXCEPT AS PROVIDED BY LAW, NEITHER PORTFOLIO SOLUTIONS NOR ITS THIRD-PARTY INFORMATION PROVIDERS AND VENDORS HAS ANY RESPONSIBILITY TO MAINTAIN THE MATERIALS, PRODUCTS, OR SERVICES OFFERED ON THE SITE OR TO SUPPLY CORRECTIONS, UPDATES, OR RELEASES FOR THE SAME. TO THE EXTENT ANY JURISDICTION DOES NOT ALLOW THE EXCLUSION OF CERTAIN WARRANTIES, SOME OF THE ABOVE EXCLUSIONS MAY NOT APPLY TO YOU. THIS WARRANTY GIVES YOU SPECIFIC LEGAL RIGHTS, AND YOU MAY HAVE OTHER RIGHTS, WHICH VARY FROM JURISDICTION TO JURISDICTION.

 

Your Account

Certain parts of this Site may be protected by passwords or require a login. Further, for authentication purposes, certain features on this Site may require you to answer a designated security question. You agree to use this Site to access only those accounts on which you are authorized to act, and you agree to use your own user names, logins, passwords, and security questions and answers when accessing accounts on which you are authorized to act. You agree not to obtain or attempt to obtain unauthorized access to such parts of or features on this Site, or to any other protected Materials or information, through any means not intentionally made available to you by Portfolio Solutions. These Terms of Use govern your access to and use of certain personal information retrieval, management and analytic capabilities (the "Service"), owned and maintained by Black Diamond. The Service is made available to you by Portfolio Solutions.

 

You are responsible for maintaining the confidentiality of any account information, user names, logins, passwords, and security questions and answers that you use to access any page or feature on this Site, and for logging off your account and any protected areas of the Site. Further, you are fully responsible for all activities occurring under your accounts, user names, logins, passwords, and security questions and answers that result from your negligence, carelessness, misconduct, or failure to use or maintain appropriate security measures. If you become aware of any suspicious or unauthorized conduct concerning your accounts, user names, logins, passwords, or security questions and answers, you agree to contact your Financial Advisor at Portfolio Solutions immediately. Portfolio Solutions will not be liable for any loss or damage arising from your failure to comply with this paragraph. Products and services provided to you through this Site may involve the electronic transmission, including via any e-mail address you provide to us, of promotional and marketing materials, and you consent to such transmission.

 

This site has been prepared solely for information purposes is not intended to be a solicitation, offer or sale of securities products or investment advisory services to anyone who resides outside of the United States.

 

Mobile App Policy

 

This mobile privacy policy governs your use of the software application PS Portal (“Application”) for mobile devices that was created by Black Diamond. The Application features include uploading, storing, viewing and sharing documents.

What information does the Application obtain and how is it used?

The Application collects User Provided Information such as login credentials, your photo and location. The Application obtains the information you provide when you download the Application.  However, please keep in mind that you may not be able to use some of the features offered by the Application unless you register with us.

Automatically Collected Information 

In addition, the Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, and information about the way you use the Application.

Does the Application collect precise real time location information of the device?

This Application does not collect precise information about the location of your mobile device. 

Do third parties see and/or have access to information obtained by the Application? Third parties do not see and/or have access to information obtained by the Application.

Only aggregated, anonymized data is periodically transmitted to Black Diamond to help us improve the Application and our service. We will share your information with third parties only in the ways that are described in this privacy statement.

We may disclose User Provided and Automatically Collected Information:

  • as required by law, such as to comply with a subpoena, or similar legal process;
  • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
  • with our trusted business partner Black Diamond who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.
  • if Portfolio Solutions is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

What are my opt-out rights?

You can stop all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You can also request to opt-out via email, at info@portfoliosolutions.com.

Data Retention Policy, Managing Your Information

We will retain User Provided data for as long as you use the Application and for a reasonable time thereafter. We will retain Automatically Collected information and thereafter may store it in aggregate. If you’d like us to delete User Provided Data that you have provided via the Application, please contact us at info@portfoliosolutions.com and we will respond in a reasonable time. Please note that some or all of the User Provided Data may be required in order for the Application to function properly.

 

Children 

 

We comply with the Children’s Online Privacy Protection Act (COPPA)We do not use the Application to knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at info@portfoliosolutions.com. We will delete such information from our files within a reasonable time.

 

Security

We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Application. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

 

Changes

 

We may update our Privacy Policy from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here and informing you via email or text message. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes. You can check the history of this policy by clicking here.

 

Cookies

 

Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device's internal memory. This Service does not use these “cookies” explicitly.

Service Providers

We may employ third-party companies and individuals due to the following reasons:

  • To facilitate our Service;
  • To provide the Service on our behalf;
  • To perform Service-related services; or
  • To assist us in analyzing how our Service is used.

We want to inform users of this Service that these third parties have access to your Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.

Your Consent

By using the Application, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. "Processing,” on a computer/hand held device means using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place in the United States. If you reside outside the United States your information will be transferred, processed and stored there under United States privacy standards. Contact us If you have any questions regarding privacy while using the Application, or have questions about our practices, please contact us via email at info@portfoliosolutions.com.

 

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