This website (the “Site”) is
owned by the North American Securities Administrators Association, Inc.
collection, use and disclosure practices regarding information that we collect
gathered on and through the Site, and does not apply to any other information
periodically as we may update it from time to time. Each time you visit
the Site or provide us with information, you are, by doing so, accepting the
that by using the Site you are expressly and affirmatively consenting to our
use and disclosure of the information you provide in accordance with this
This Site has two sections: a
section available to the general public; and a section that is restricted to
registered filers (“Filers”) and registered state regulators (“State
Regulators”, collectively with “Filers” the “Registered Users”) that we call
the “Filing Section.” In the Filing Section of the Site, Registered
Users may file securities documents with relevant state agencies. Participating
“states” include the fifty United States, the District of Columbia, and U.S.
generally to both parts of the Site, certain sections apply only to the
Registered Users, as discussed in further detail below. But, if a
State Regulators, or Registered Users, then the section applies to all
information we collect through the Site.
We value the privacy of our
Site’s visitors. Therefore, we will not sell your personal
information without your consent.
of our data collection and use practices.
This section gives a brief
overview of our data collection and use policies. Please see below
for a more detailed discussion of each topic.
collect the following information through the Site from all users:
· Information that your browser
routinely shares with websites.
collect the following information only from our Registered Users:
· Personal information that
Registered Users provide to set up an account to use the Filing Section of the
Electronic Filing Depository System (“EFD System”).
· “Filing Data” that Filers
provide to use our EFD System to file documents with state agencies.
· Information that State
Regulators provide to facilitate the use of our EFD System and to facilitate
use and disclose the information we collect from our Registered Users for the
· To provide and perform the
services that our Registered Users request.
· To state agencies in order to
facilitate the electronic filing of securities documents.
use and disclose information that we collect from all users for the following
· To our contractors who
provide support services for the Site, but only on terms consistent with this
· To protect our business
interests or the rights of others, when required by law, to cooperate with law
track of our Site’s users and for their protection and convenience.
beacons, or other similar technology to track movements across our website and
to keep track of our registered users and their preferences.
Other details about our policies and practices:
· Although the Site may contain
links to other websites, this policy only applies to this Site.
· We use your personal
information only for the purposes for which it is collected and consistent with
this policy, and we retain your information as permitted by applicable law.
· We may update this policy
from time to time, but we will allow you to opt in to any material changes in
how we use personal information we’ve previously collected.
The public section of the
Site is primarily an informational website that provides information about us
and our services, and allows members of the public to access public records
relating to state securities filings. You may access and browse the
public section of our Site without providing any personal information.
Like many other web sites,
and regardless of whether you are visiting the public section or Filing Section
of the Site, we may record information that your browser routinely shares, such
as your Internet Protocol (“IP”) address, browser type, browser language,
software and hardware attributes, the URL you came from or go to (whether this
URL is on our Site or not), mouse clicks, mouse movements, and the date and
time of your visit (collectively “Aggregate Information”).
Collected in the Filing Section. The Filing Section of the Site is
available only to Registered Filers and State Regulators who establish an
account with us. In order to establish an account as a Registered
Filer or State Regulator, we require certain personal information, such as your
name, email address, physical address, and telephone number. However,
when we collect your personal information, it is so we can provide a service to
you and/or communicate with you about that service.
information from Registered Users. Further, for Registered Filers to file
securities documents with a state and State Regulators to facilitate state
filing fee calculations and receive state filings, we require additional,
non-personal information so we can provide the service and communicate with you
about that service. For example:
Registered Filers: In order to use the EFD
System to file documents with state agencies and calculate the appropriate
filing fees, each time you use the EFD System to file documents with state
agencies we collect information such as which states you would like to file the
documents in, which securities you are filing, and the first date of sale of
the securities (the “Filing Data”). This Filing Data will be shared
with, and owned by, the individual state(s) in which the filing(s)
occurs. More information about how Filing Data is shared can be
State Regulators: In order to
register to receive filings from the EFD System, State Regulators must complete
our System Entitlement and Settings Form which includes providing information
such as the applicable state filing fees and accepted methods of review for
different notice types.
we use the information we collect.
We will generally use the
information that we collect to help us understand our users and their
preferences. For information that we collect from Registered Users,
we will generally use the information to operate the Site and to provide
requested services such as the EFD System. The following provides a
more specific discussion of our uses and disclosures of the information that we
Personal Information we collect from Registered Users: We may use your personal information
to contact you and deliver administrative notices or communications applicable
to your use of the Site and to provide the services you request. We
will seek your consent before we use your previously collected personal
information in a materially different manner than as discussed below. And,
unless otherwise indicated on the Site, if we allow our business partners to
access the personal information we’ve collected, it will be for limited
of Filing Data to State Agencies: All Filing Data,
including documents, that Filers
provide to us will be shared with the state(s) in which the Filer has requested
the filing occur. The Filing Data, including documents, are owned by the state and may be made publicly
available by the state under applicable state laws, such as the Freedom of
Information Acts. Filing Data,
including documents, filed with a state using the EFD System may be
publicly accessible using the EFD System. Filing Data, including documents, may also be shared by a
state with another state, federal, and/or local governmental agencies or
authorities by law or under interagency agreements.
Statistical Analyses of the information: We may use
an analytics provider, such as Google Analytics, to help us gather statistical
information about the visitors to our site and how they use the site on an
anonymous, aggregate basis but will not associate this data with personally
identifiable data unless required to do so to cooperate with law enforcement
activity or other governmental request or to comply with law. We may
use this information to gain a better understanding of the visitors to our site
and to improve our website and service or product offerings. Depending
on the type of browser and device that you use, you may have the ability to
control the type of information that Google Analytics uses. To understand how Google
Analytics collects and processes data, please visit www.google.com/policies/privacy/partners.
information with our business partners: We may use business partners
to help us design and operate the Site or provide other services to support the
Site. For example, we may hire a company to host the website or help
us analyze data we collect from the Site. Any information shared
with our business partners will be shared in compliance with this Privacy
operations, law enforcement and legal actions: We may release your
information without prior notice when we believe it is appropriate to prevent
fraud; to comply with law or to cooperate with law enforcement activity or
other governmental request; to respond to subpoenas, court orders or
administrative agency requests for information; to enforce our policies; to
protect the rights, property and safety of our business and of others; or when
required or otherwise permitted by law. For example, we may share information
with law enforcement to reduce the risk of fraud or if someone uses or attempts
to use our site for illegal reasons. If there is a sale or merger of the
company, division or business unit that operates this site, we may also
transfer the information we have collected in connection with such sale or
track of our Site’s users and for their protection and convenience. A
“cookie” is a small text file containing alphanumeric characters that is stored
on your computer and uniquely identifies your web browser. Cookies
allow us to, for example, authenticate users, determine if this is a user’s
first visit to our Site, and remember our user’s preferences. Most
Internet browsers enable you to erase cookies from your computer hard drive,
block all cookies, or receive a warning before a cookie is stored. Please
be aware however, that some of the Site’s features or services may not function
properly without cookies.
We, or our contractors who
host the Site on our behalf, use commercially reasonable means to protect the
integrity of the Site and to limit access to the personal information of our
Registered Users. We also use commercially reasonable means to
protect the security of information during transmission on the Site by using
Secure Sockets Layer (SSL) or comparable software. However, we
cannot provide absolute assurances against, and will not be liable for, any
breaches of data security or confidentiality due to system failures or
unauthorized access by third parties, or other causes beyond our reasonable
to this policy.
Our business and the laws
that regulate us change from time to time, and we therefore reserve the right
to change this policy. But, if we do change this policy, we will
post the revised version on the Site. And, if we propose to change
this policy in a way that would permit us to make additional or different uses
of personal information that we had previously collected about you, we will
obtain your affirmative, express consent before using that previously collected
personal information in a materially different way.
At this time the Site does
not recognize automated browser signals regarding tracking mechanisms, which
may include “do not track” instructions. However, you can change
through your browser.
If you have any questions or
comments about our policies or practices, please contact us at firstname.lastname@example.org.
This Policy was last updated on February 18, 2015.