Privacy policy.
Effective Date: September 24, 2024
General
Linden Thomas and Company is committed to respecting the privacy of consumers and its customers, including visitors to our websites. This Privacy & Cookie Policy sets out how we collect, use, and share personal information. This Privacy & Cookie Policy also explains how we use cookies and similar technologies on our websites and subsites.
Linden Thomas and Company Securities is registered as a broker-dealer with the U.S. Securities and Exchange Commission (the “SEC”) and FINRA. Linden Thomas Advisory Services, LLC is registered with the SEC as an investment adviser. Both entities are affiliated, collectively owned by Linden Thomas Financial Group, LLC, and do business as “Linden Thomas and Company” or “Linden Thomas.” Additionally both entities are required to comply with SEC Regulation S-P (“Reg. S-P”), as well as the U.S. Gramm-Leach-Bliley Act of 1999 (the “GLB Act”) which require Linden Thomas to have policies and procedures in place to protect the security and confidentiality of the non-public personal information of consumers and customers, and to provide a privacy notice to such persons describing our privacy policies and procedures.
Use of this Linden Thomas’ website constitutes acceptance of this Privacy Policy and the continued use of our website following this posting and any future changes, constitutes your acceptance of such changes.
Glossary
“Consumer” – an individual, or an individual's legal representative, that obtains or has obtained a financial product or service to be used primarily for personal, household or family purposes. A person becomes a consumer even if a questionnaire or application is withdrawn or denied or a brokerage account or advisory agreement does not become effective.
“Customer” – a consumer that has an ongoing relationship with Linden Thomas and Company, whereby Linden Thomas provides one or more financial products or services to the consumer.
“Nonpublic personal information” –
All personally identifiable financial information.
While the GLB Act excludes publicly available information (e.g., a list of persons and their publicly listed telephone numbers), nonpublic personal information includes any list, description or other grouping of consumers (and publicly available information pertaining to them) derived using any nonpublic personally identifiable financial information that is not publicly available.
What information Linden Thomas collects
Linden Thomas collects the following information:
Linden Thomas collects information from individuals who request informational materials, including name, address, telephone number, email address and investment-related questions.
Linden Thomas may record and/or monitor phone calls and electronic communications for quality assurance and training purposes.
Linden Thomas collects relevant information on applications and resumes from prospective employees via our Careers website.
Linden Thomas collects information provided orally and in writing via email, mail, online or in person from prospective clients, clients, prospective employees and employees.
Our websites use cookies and other online tracking technologies to collect and share technical information, such as data reflecting IP address, browser used to view the website, operating system, resolution of screen, location, language settings in browser, the site directing to our site, keywords searched, clickstream data, the number of page views, inferences drawn from any personal information etc. Please see “Cookie Policy” below.
How Linden Thomas uses and shares information collected
Linden Thomas may combine personal information collected and use the information for the following reasons:
Internal record keeping.
To improve products and services.
For quality assurance and training purposes.
To follow up, either by email, phone or mail, with people who have requested information and/or materials.
To periodically send promotional email or mail about services, recent developments or other information individuals may find interesting using the email address or mailing address provided when requesting information.
To optimize and personalize marketing.
To access certain special features or areas of this website.
To evaluate prospective employees for positions, and to employ its personnel.
To analyze the financial situation of prospective clients and to provide investment advisory and management services to clients.
As otherwise permitted by law.
Linden Thomas discloses information externally as permitted or required by law to affiliates, vendors, and regulatory agencies, or where individuals have provided permission.
How to contact Linden Thomas
If you have any questions or concerns regarding this Privacy & Cookie Policy, we can be contacted as follows:
Linden Thomas and Company, LLC
516 N. Tryon Street
Charlotte, NC 28202
(704) 554-8150
Please ensure that full name and address are provided in exactly the form in which it was originally provided to Linden Thomas to avoid any possible confusion with a different individual.
To unsubscribe from Linden Thomas email communications, send an email to info@lindenthomas.com. Please put “UNSUBSCRIBE” in the subject field and include the email address where you received the content, along with any additional email addresses you would like suppressed. We will do our best to prevent you from receiving our email content in the future.
YouTube and Podcasts
All opinions expressed in these programs are for general informational purposes only and are not intended to provide specific advice or recommendations for any individual or on any specific security. These programs are only intended to provide information and education about the financial markets. To determine which investments may be appropriate for you, consult Linden Thomas prior to investing. Any past performance discussed during this program is no guarantee of future results. Any indices referenced for comparison purposes are unmanaged and cannot be invested into directly. As always, please remember that investing involves risk and possible loss of principal.
Security
In order to prevent unauthorized access or disclosure, Linden Thomas has put in place suitable physical, electronic and managerial procedures to safeguard and secure information. Nevertheless, due to the nature of the Internet and Internet technologies, security and privacy risks cannot be eliminated, and Linden Thomas cannot guarantee that information will not be disclosed in ways not otherwise described in this privacy policy.
Other Websites
The Linden Thomas website may contain links to enable users to visit other websites of interest easily. However, once users have used these links to leave this site, users should note that Linden Thomas does not have any control over that other website. Therefore, Linden Thomas cannot be responsible for the protection and privacy of any information which users provide while visiting such sites and such sites are not governed by this Privacy & Cookie Policy. Individuals should exercise caution and look at the privacy and cookie policies applicable to the website in question.
Cookie Policy
A cookie is a small text file downloaded to an individual’s computer (or other device) when accessing webpages that use them. Cookies and other online tracking technologies, such as pixels, tags, or web beacons (collectively referred to in this policy as “cookies”) allow a website to store and retrieve information about visitors’ online activity. Cookies are, for example, how a website remembers what pages you visited, how long you viewed the page, or what items you put into your online shopping cart.
Cookies can be categorized by who places them:
First-party cookies: These cookies are downloaded to an individual’s computer from a server or domain managed by the publisher of the website whose service the individual is requesting.
Third-party cookies: These cookies are downloaded to a computer from a server or domain that is not managed by the publisher, but by another entity that may be seeking data obtained through cookies.
Cookies can also be categorized by their duration:
Session cookies: These cookies are designed to collect and store data while the individual accesses a web page. They are often used to store information for the duration of a visit to the site (e.g., what account you are logged into). Once an individual leaves the website, the session cookie is deleted.
Persistent cookies: These cookies store data on a computer for the duration of the period set within the cookie’s file, which is determined by the entity controlling the cookie, and can range from a few minutes to several years, or until manually deleted.
Lastly, cookies can be categorized by the function they serve. Linden Thomas uses the following types of first- and third-party cookies:
Functionality Cookies
These cookies allow the website to remember choices you make (such as your geographic region or preferred text size). Functionality cookies do not collect any personal information. Enabling functionality cookies may be necessary to access the full content of website material.
Personalization Cookies
Personalization cookies allow a website to remember information that changes the page’s appearance or behavior, such as, for example, the language selected for viewing the page.
Analytics Cookies
Analytics cookies collect pseudonymized information to analyze how individuals browse a website and enable Linden Thomas to measure the number of visitors to its websites, as well as to measure and analyze how individuals interact with the site. We use this information to improve our websites and the products or services offered.
Behavioral Advertising Cookies
Linden Thomas serves advertisements on various websites using third party companies. If an individual visits a website or clicks on one of Linden Thomas’ advertisements, behavioral cookies will be placed on the individual’s computer. Behavioral cookies allow Linden Thomas to manage and optimize its digital marketing (e.g., banner ads, pages offering informational brochures, email campaigns, etc.). Behavioral cookies may be used to build a profile to provide content more relevant to an individual’s interests. They adapt advertising and the content the individual sees on other websites based on browsing habits, including how the individual navigates websites, as well as how the individual interacts with internet advertising.
“Do Not Track” Signals
Some internet browsers send signals to each website visited, giving notice of the user’s privacy preferences. Linden Thomas websites recognize signals sent through “Global Privacy Control” and will honor requests to limit information sharing. Please keep in mind that Global Privacy Control signals are limited to the device and browser. Users should enable Global Privacy Control on each device and browser. If users block or clear cookies, they may need to re-enable Global Privacy Control.
How to Manage Cookies
To learn more about behavioral advertising cookies and to opt in or out of multiple advertising networks at once, you can visit the website YourAdChoices. Some advertising networks do not participate in the YourAdChoices service. To opt out of some of these networks, please visit the consumer opt-out page of the Network Advertising Initiative.
As explained above, cookies help you to get the most out of the websites that make use of this technology. Disabling cookies may affect the functionality of many of the websites you visit. If you do disable cookies, performance and functionality will be affected. If you wish to delete, disable, or re-enable cookies, you may do so through your browser as follows:
Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/view-cookies-in-microsoft-edge-a7d95376-f2cd-8e4a-25dc-1de753474879
Chrome: https://support.google.com/chrome/answer/95647?hl=en
Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
All other browsers: Please look for a ‘help’ function in the browser or contact the browser provider.
Changes to Privacy Policy
From time to time, Linden Thomas may use data for new uses not previously disclosed in its Privacy & Cookie Policy. If its information practices change at some time in the future, Linden Thomas will post the policy changes to our website to notify users of these changes and provide the ability to opt out or unsubscribe from these new uses. For the most up-to-date information on how Linden Thomas uses personal information, please review the privacy policy link on our website.
California & Oregon Residents Only
California and Oregon residents have rights relating to their personal information described in the chart below. A California or Oregon resident with questions about our privacy policies should contact us by email at info@lindenthomas.com. A California or Oregon resident with a disability seeking privacy information in an alternative format should contact us in the same manner. For other contact information, refer to “How to contact Linden Thomas” above.
Information Collected and How it is Used
Categories of Personal Information
Purposes of Collecting and Using Personal Information
Identifiers including name, address, telephone number, email address, investible assets, and other identifying information relating to individuals
Marketing purposes, including targeted advertising and delivering informational materials to prospective clients who request them and offering financial services
Commercial information limited to records of informational materials requested and other individual interactions with us
Marketing purposes, including tracking responses from prospective clients and research to improve offerings
Electronic network activity information including IP addresses, interaction with websites or advertisements and other information as described in “Cookie Policy” above
Marketing purposes, including direct marketing optimization, insight on performance of web-based advertising, and targeted advertising
Employment-related information, including sensitive personal information
Promote employment opportunities; evaluate qualifications; perform background checks; verify right to work; and administer employment relationship, including payroll and expense reimbursement
Financial and other information obtained while providing investment advice and other services
Provide investment advisory, investment management, other financial services, and non-financial services; enhance client service capabilities; and meet Linden Thomas’ regulatory obligations
Vendor contact information
To engage with vendors. This includes making payments and communicating with vendor contacts
Linden Thomas obtains information used for marketing purposes directly from individuals who request informational materials, through cookies and other online tracking technologies, from existing clients and other referral sources, and from list vendors that gather and sell identifying information. Employment-related information is obtained from third party recruiters, employee referrals, directly from individuals, and background check providers. Information relating to non-financial services is obtained directly from individuals.
Linden Thomas discloses personal information to service providers and/or data processors as defined under applicable law for the business purposes identified in the chart above. Linden Thomas discloses personal information to regulatory agencies, law enforcement authorities, and other third parties when required or authorized by law. Linden Thomas discloses email addresses and electronic network activity information to certain advertising and analytics partners, including social media platforms. These third parties use the information to show you ads targeted to your interests. This type of disclosure is defined as “selling” or “sharing” or “targeted advertising” under California and Oregon law. You may opt out of this disclosure by clicking here. As described above under “Do Not Track Signals,” enabling the Global Privacy Control setting in your browser is another way to limit disclosure.
Information used in connection with investment advice, investment management, and other financial services is collected pursuant to the GLB Act and Reg. S-P, directly from prospective clients and clients and from other authorized sources, such as securities account custodians. The privacy notice required by the GLB Act (described above) explains how Linden Thomas shares this information.
Linden Thomas uses and discloses sensitive personal information only for the purposes allowed by California law.
Linden Thomas does not knowingly “sell” or “share” the personal information of California residents under 16 years of age, as those terms are defined in California law.
Linden Thomas retains personal information for internal use in accordance with applicable law and for as long as it is needed to establish, exercise, or defend any legal claims.
California and Oregon residents may exercise the following rights in relation the personal information that Linden Thomas holds about them. California and Oregon residents have the right to:
Request disclosure of the categories of personal information collected, specific pieces of personal information collected, categories of sources, purposes for collecting and using, and categories of third parties to whom the information is disclosed, “sold” or “shared,” as those terms are defined in California and Oregon law.
Request deletion of their personal information.
Request correction of inaccurate personal information.
Not be discriminated against for exercising their rights with respect to personal information.
To exercise these rights, California and Oregon residents or their authorized agents should email us at info@lindenthomas.com or call (704) 554-8150. Requests must include sufficient information to verify the requester’s identity, including name, email, phone, and zip code. Deletion and correction requests will require additional confirmation. For requests submitted by agents, proof of authority, such as a copy of a valid power of attorney, will generally be required.