Privacy Policy, Terms and Disclosures
Privacy Policy
Protecting the privacy of our members is very important to us at Fieldpoint Private and each of our affiliates. As a provider of financial services, the collection and use of personal information is fundamental to day-to-day operations. We strongly believe in protecting the confidentially and security of the information by whatever means possible. This policy describes how we handle and protect the information we receive from and about our members.
Why We Collect Information: We collect and use nonpublic personal information only for business purposes in order to serve the needs of our members. These business purposes include activities such as evaluating a request for a loan, opening a private banking deposit account, authenticating and executing member-requested transactions, and servicing members’ investment management needs. We may also use member information to inform you of other products or services that may be of interest to members.
What Information We Collect: We collect nonpublic information about you from the following sources: Information we receive from you on applications or other forms, information about your transactions with us, or others and information we receive from consumer reporting agencies.
How We Protect Information: We treat all information in a highly confidential manner. Fieldpoint Private Colleagues are required to protect the confidentiality of all information. Our Professional staff may access information only when there is an appropriate reason to do so, such as to support member servicing. Our Internet Banking Product uses industry-approved security technology such as passwords, firewalls and encryption, to protect member information from tampering. We also maintain physical, electronic and procedural safeguards to protect information and these safeguards comply with or exceed applicable laws. Everyone servicing your relationship and accounts is required to comply with established policies of Fieldpoint Private. We do not disclose any nonpublic personal information about you to anyone, except as required by law.
Information We Share: We do not disclose any nonpublic information about our members or former members to anyone, except as permitted by law.
Correction of Information: If you notify us that any information is incorrect, we will review it promptly and make all appropriate corrections to our records.
Further Information: Federal law establishes privacy standards and requires Fieldpoint Private to provide our privacy notice to members each year. If you have any questions about our privacy practices you may write us at Fieldpoint Private, 100 Field Point Road, Greenwich, CT 06830.
Online Security Statement: Member Information security is a top priority at Fieldpoint Private. Fieldpoint Private has built a secure network architecture utilizing well-vetted technology. Our firm will continue to adopt new technologies to ensure confidentiality, flexibility, and a superior member experience.
We want your online banking experience and usage of the Fieldpoint Private website to be safe while easy to navigate. Secure systems are a combination of technology, policies and people. Our architecture utilizes a multi-layered approach to information security, providing safeguards and privacy throughout the process.
Fieldpoint Private built a site offering multifactor authentication, data integrity, complete transactional privacy, and above all, resistance to all forms of hacking attempts. Layered security means that, rather than relying on a single security measure, Fieldpoint Private uses layers of technology within the security architecture to distance harmful intrusions as far as possible from the core of sensitive information and resources.
The first layer of security is our members. Please be aware of several straight forward security tips when using any internet site containing sensitive information:
• Please use a strong password. Choose passwords that are difficult for others to guess and use a different password for each of your online accounts. Use both letters and numbers and a combination of lower case and capital letters.
•Change your online banking passwords often. You can do this quickly and easily by signing on and going to the designated area.
• Make sure your home computer has the most current anti-virus software. Anti-virus software needs frequent updates to guard against new viruses. We recommend that you use a program that automatically updates your virus protection on a regular basis.
• Install a personal firewall to help prevent unauthorized access to your home computer. This is important if you are connected to the internet via a cable modem or a digital subscriber line (DSL) modem.
• When your computer is not in use, please shut it down or disconnect from the internet.
Act quickly if you detect fraud. If you believe someone is trying got commit fraud and/or you think you may have provided personal or account information in response to a fraudulent email or web site, report the incident immediately, change your passwords.
General Data Protection Regulation (GDPR)
Privacy Notice for EEA Residents
This Privacy Notice describes how Fieldpoint Private (the firm”) collects and secures the personal data of individuals domiciled in the European Economic Area (EEA). The information in this Notice is provided to the extent that the European Union’s General Data Protection Regulation (“GDPR”) applies to your business with Fieldpoint Private.
Please note that Fieldpoint Private’s data collection and retention procedures are subject to U.S. laws and banking and securities regulations. As a result, your rights under the GDPR may be limited by those laws and regulations.
Basis for and Purpose of Data Processing
Fieldpoint Private collects and processes your personal data when such processing is required for the performance of our contract with you. The firm also processes your personal data to comply with applicable U.S. laws and regulations.
Personal Data Obtained from Outside Sources
Fieldpoint Private obtains personal information about you from other sources to enable us to confirm your identity and financial history. These sources may include paid third-party service providers and publicly accessible data.
Recipients of Personal Data
Fieldpoint Private shares your personal data with third-party service providers to help conduct business on your behalf. These arrangements are subject to due diligence and ongoing oversight to ensure that these service providers have adequate data protection procedures in place. Fieldpoint Private’s service providers may include:
Investment management firms;
Audit, accounting or recordkeeping services;
Clearing and custody firms;
Statement services;
Credit bureaus, background-check providers and legal data services;
Prospectus/corporate action mailing service;
Other vendors as necessary.
How Long Does Fieldpoint Private Retain Your Personal Data?
Fieldpoint Private processes and retains your personal data for at least the duration of our contract with you. Note that the firm will preserve some data longer to comply with U.S. law and the rules of the banking and securities regulatory authorities who oversee our activities.
Your GDPR Rights
Under GDPR, you have fundamental rights regarding your personal data, and you may exercise those rights — subject to other banking and securities laws or regulations that Fieldpoint Private must observe. These rights include:
Right to be informed. You have the right to be informed that a file of your personal information is being collected, retained and processed by Fieldpoint Private.
Access. You have the right to obtain free access to your personal data.
Rectification. You have the right to ask that incorrect or incomplete personal data be corrected.
Erasure. You have the right to request that personal data be erased, subject to applicable legal and regulatory
constraints.
Restriction on processing. You have the right to request the restriction of the processing of your personal data in specific cases.
Objection to processing. You have the right to object to the processing of your personal data for marketing purposes or based on your own circumstances.
Portability
You have the right to receive your personal data in a machine-readable format and to transmit it to another controller.
Rights for California Residents
If you are a California resident, you may have certain rights under the California Consumer Privacy Act (Cal. Civ. Code §1798.100 et seq.) (“CCPA”) regarding your personal information. These include:
The right to know about the personal information a business collects about them and how it is used and shared;
The right to delete personal information collected from them (with some exceptions);
The right to opt-out of the sale of their personal information; and
The right to non-discrimination for exercising their CCPA rights.
To exercise your rights, you may call Fieldpoint Private at 1-800-288-5513, or e-mail us at:
fpscompliance@fieldpointprivate.com.
Point of Collection Notice
Personal Information We Collect
Fieldpoint Private collects personal information from clients, employees, job applicants, directors and vendors, among others. This information includes, but is not limited to:
Personal identifiers. Examples include your full name, date of birth, marital status, spouse’s name, residential address, mailing address, e-mail address, telephone number, online identifiers, driver’s license, Social Security number, passport information or other government issued identification;
Financial data: Including your investment experience, as well as specific information about banking or investment products or services previously purchased such as mortgages or insurance;
Characteristics of protected classifications under federal or California law: Examples include age and gender;
Internet or other network activity information: Such as your IP address, information regarding your interaction with our websites and applications, biometric information (such as voice authentication and call recording);
Publicly available information from the internet including social media sites;
Professional or employment-related information;
Education and professional certifications;
Inferences that we draw from the information collect.
Sources for the Personal Information We Collect
We gather personal information from the following of sources, among others:
Directly from you or from those acting on your behalf. Examples include account forms, loan applications, job applications, vendor service agreements, or information requests that you complete online, by telephone, on paper or verbally.
Data that you choose to make public on the internet via social media sites.
Third-party vendors such as credit services or background-check services.
Publicly available data from law enforcement agencies, court records or other government entities.
Data automatically collected from internet or other network activity regarding your use of our websites and applications. We also may collect information from your interactions with third-party systems that we give you access to as a client, including banking, trading or custodial services.
Uses for the Personal Information We Collect
For clients, we use the personal information we collect primarily to conduct our investment management and banking activities on your behalf. We also may use your personal information to verify your identity, personalize the services and communications we provide and as an aid in developing new products and services. For employees, job applicants, vendors or firm directors, we use personal information to evaluate your background in connection with your current or potential responsibilities at the firm. In addition, we use personal information to administer such services as payroll, benefits or accounts payable.
The firm may provide your personal information to regulators and law enforcement agencies when required.
Third Parties We May Share Your Personal Information With
We may share your Personal Information with the following third parties, among others:
Vendors that facilitate our ability to provide you with our banking and wealth management services. These may include, but are not limited to, banking service vendors, payment facilitators such as ACH and Fedwire, clearing firms, custodians, mutual funds, insurance companies or private placement sponsors. Background-check services, payroll providers, benefit providers. Government, legal or regulatory entities, law enforcement agencies, other entities in connection with legal
proceedings.
Sale of Personal Information and Opting Out
Fieldpoint Private does not sell your Personal Information as outlined in the CCPA, so we do not provide an opt-out option.
Limits to Your Rights under CCPA
Note that the CCPA includes certain exemptions that may apply to our use or collection of your Personal Information and some of your information may be excluded from a request to receive or delete your Personal Information. Additionally, certain Personal information that we must collect or that we are required to retain to remain in compliance with other regulations than the CCPA is may be excluded from your rights under the CCPA.
Changes to this Policy
We may change or update this disclosure as regulations or our practices change and will post the revised disclosure here.
Terms of Use
Fieldpoint Private Bank and Trust and Fieldpoint Private Securities, LLC (together, “Fieldpoint Private”) maintains this site (the “Site”) for our Members’ and guests’ personal, information, education, and communication. Please feel free to browse the Site. The viewer may not distribute, modify, transmit, reuse, repost, or use the content of the Site for public or commercial purposes, including the text, images, audio, and video.
Access to and use of the Site is also subject to the following terms and conditions (“Terms and Conditions”) and all applicable laws. By accessing and browsing the Site, the viewer Accepts, without limitation or qualification, the following:
1. The viewer should assume that everything on the Site is copyrighted, unless otherwise noted, and may not be used except as provided in these Terms and Conditions. Fieldpoint Private neither warrants nor represents that use of materials displayed on the Site will not infringe rights of third parties not owned by or affiliated with Fieldpoint Private.
2. While Fieldpoint Private uses reasonable efforts to include accurate and up to date information in the Site, Fieldpoint Private makes no warranties or representations as to its accuracy. Fieldpoint Private assumes no liability or responsibility for any errors or omissions in the content of the Site.
3. Use of and browsing the Site is at the viewer’s own risk. Neither Fieldpoint Private nor any other party involved in creating, producing, or delivering the Site is liable for any direct, incidental, consequential, indirect, or punitive damages arising out of access to, or use of, the Site. Without limiting the foregoing, everything on the Site is provided “AS IS” WITHOUT WARRANTY OF ANY KIND, EITHER EXPRESSED OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON INFRINGEMENT. Please note that some jurisdictions may not allow the exclusion of implied warranties, so some of the above exclusions may not apply to the viewer. Check local laws for any restrictions or limitations regarding the exclusion of implied warranties.
4. Fieldpoint Private also assumes no responsibility, and shall not be liable for, any damages to, or viruses, that may infect, the viewer’s computer equipment or other property on account of the viewer’s access to, use of, or browsing of the Site or downloading of any materials, data, text, images, video, or audio form on the Site.
5. Any communication or material the viewer transmits to the Site by electronic mail or otherwise, including any data, questions, comments, suggestions, or the like is, and will be treated as, non-confidential and non-proprietary. Anything the viewer transmits or posts may be used by Fieldpoint Private or its affiliates for any purpose, including but not limited to, reproduction, disclosure, transmission, publication, broadcast, and posting. Furthermore, Fieldpoint Private is free to use any ideas, concepts, know-how, or techniques contained in any communication submitted to the Site for any purpose whatsoever, including, but not limited to, developing, manufacturing, and marketing products using such information.
6. Images of people or places displayed on the Site are either the property of, or used with permission by Fieldpoint Private. The use of these images is prohibited. Any unauthorized use of the images may violate copyright laws, trademark laws, the laws of privacy and publicity, and communications regulations and statutes.
7. The trademarks, logos, and service marks (collectively the “Trademarks”) are displayed on the Site are registered and unregistered Trademarks of Fieldpoint Private and others. Nothing contained on the Site should be construed as granting, by implication, estoppels, or otherwise, any license or right to use any Trademark displayed on the Site. Misuse of the Trademarks displayed on the Site, or any other content on the Site, except as provided in these Terms and Conditions is strictly prohibited. Please be advised that Fieldpoint Private will aggressively enforce its intellectual property rights to the fullest extent of the law, including the seeking of criminal prosecution.
8. Fieldpoint Private may at any time update these Terms and Conditions by updating this posting. Viewers are bound by any such revisions and should therefore periodically visit this page to review the current Terms and Conditions.
Email Disclaimer
Important Information
Please read the following carefully as it contains the conditions governing any electronic communications between you and Fieldpoint Private Bank & Trust, Fieldpoint Private Securities, LLC, and all Fieldpoint Private Bank & Trust affiliates (firm and its affiliates). By messaging with the firm and its affiliates, you agree to these terms and conditions of use. The firm and its affiliates may amend these terms and conditions without notice. You should check this webpage from time to time to review the current terms and conditions because they are binding on you and if applicable, your organization.
Unless otherwise specifically indicated the contents of any electronic communication (including e-mail, instant messaging, text messaging etc.) and its attachments are for informational purposes only and should not be regarded as an offer to buy or sell securities, futures, options, investment products or other financial products or services; as an official confirmation of any transaction, an official valuation or an official statement of the firm and its affiliates. Attachments that are part of an electronic communication may have additional important disclosures and disclaimers, which you should read.
• Electronic Communications & Privileged Information
• Do Not Send Sensitive Information Electronically
• Information Subject to Change
• Archiving & Monitoring Electronic Communications
• Electronic Communications Does Not Take the Place of Financial Advice
• Local and State Taxation and IRS Circular230 Disclosure
• Conflict of Interest Disclosure
• Bank Disclosures
Electronic Communications & Privileged Information
Electronic communications may contain privileged or confidential information, or may be otherwise protected by work product immunity or other legal rules. No confidentiality or privilege is waived or lost by any erroneously transmitted communication. Access, copying or re-use of information by non-intended or non-authorized recipients is prohibited. If you are not an intended recipient of an electronic communication, please notify the sender, delete it and don’t read, act upon, print, disclose, copy, retain or redistribute any portion of such electronic communication any portion of such electronic communication. Electronic communications are not intended for distribution to, or use by, any person or entity in any location where such distribution or use would be contrary to law or regulation or would submit any firm affiliate to any registration requirement within such location. The firm and its affiliates do not waive any intellectual property rights in any electronic communication.
Do Not Send Sensitive Information Electronically
The firm and its affiliates cannot provide absolute assurances that all electronic transmissions (sent or received) are secure, error free, not corrupted, incomplete or virus free and/or they won’t be lost, mis-delivered, destroyed, delayed, or intercepted /decrypted by others. Therefore, the firm and its affiliates advise against sending sensitive or personally identifiable information via electronic communications and disclaims all liability with regard to electronic communications (and the contents therein) if they are corrupted, lost, destroyed, delayed, incomplete, mis-delivered, intercepted, decrypted or otherwise misappropriated by others.
Information Subject to Change
Information in an electronic communication is subject to change without notice and unless otherwise indicated the views expressed are the author’s and may differ from others within the firm and its affiliates. The information represents a view as of the date of the electronic communication and is subject to change and/ or withdrawal at any time without notice.
Archiving & Monitoring Electronic Communications
Any electronic communication that is conducted within or through the firm and its affiliate’s systems will be subject to being archived, monitored and produced to regulators and in litigation in accordance with the firm and its affiliate’s policies and local laws, rules, and regulations. Electronic communications may be archived in countries other than the country in which you are located, and may be treated in accordance with the laws and regulations of the country of each individual included in the entire message chain.
Electronic Communications Does Not Take the Place of Financial Advice
The information in an electronic communication is not intended to replace a recipient’s own internal business processes for evaluating proposed transactions. Recipients should seek financial advice regarding the appropriateness of investing in any securities referred to in an electronic communication and should understand that statements regarding future prospects of the instruments or the securities included in them may not be realized. There can be no assurance that the securities or other financial products or services mentioned in an electronic communication could be bought or sold at such prices by the firm and its affiliates on your behalf from other parties or market participants. Past performance is not necessarily indicative of future results. Fieldpoint Private and its affiliates do not provide tax, accounting, or regulatory advice.
Local and State Taxation and IRS Circular230 Disclosure:
Please be advised that any discussion of U.S. tax matters contained within this communication (including any attachments) is not intended or written to be used and cannot be used for the purpose of avoiding U.S. tax-related penalties or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. Please consult your advisor as to any tax, accounting or legal statements made herein.
Conflict of Interest Disclosure:
Under the Investment Advisers Act of 1940 (Adviser’s Act) an investment adviser has a duty to provide disinterested advice and disclose any material conflicts of interest to clients. In certain instances, the bank may select money managers that are deemed to be affiliated with the bank through an investment in the bank. We will disclose these instances to the client in advance of a client’s decision to invest in any such affiliated money manager. Additionally, we will provide a copy of our Adviser’s ADV which provides further detail outlining the affiliation between the money manager and the bank. The bank takes its fiduciary duty to provide disinterested advice very seriously and as noted above fully discloses all potential conflicts of interest under the adviser’s act to all its Members/Clients in an effort to assist Members/Clients in evaluating the objectivity of the recommendations provided.
Bank Disclosures:
According to the existing Networking Agreement made between Fieldpoint Private Bank & Trust, Inc. (Fieldpoint Private) and its wholly owned affiliate, Fieldpoint Private Securities, LLC (FPS), select Fieldpoint Private employees will be registered with FPS so that these dually employed persons may provide nondeposit services including securities services and transactions to Fieldpoint Private clients (Members).
Members opening securities accounts through the aforementioned dually employed Fieldpoint Private persons are hereby notified that in doing so they are opening a securities account with Nutmeg Securities, LLC and not with Fieldpoint Private Bank & Trust; and that securities products purchased or sold in this account are:
NOT INSURED BY THE FEDERAL DEPOSIT INSURANCE CORPORATION (FDIC)
NOT DEPOSITS OR OTHER OBLIGATIONS OF FIELDPOINT PRIVATE BANK & TRUST AND ARE NOT GUARANTEED BY FIELDPOINT PRIVATE BANK & TRUST
SUBJECT TO INVESTMENT RISKS, INCLUDING POSSIBLE LOSS OF THE PRINCIPAL INVESTED
Members also are hereby notified that the Securities Investor Protection Corporation, or SIPC, coverage on the securities account does not insure the market price of securities held in said account.
System Requirements
BASIC REQUIREMENTS
Operating System Requirements
Windows 7, 8, 10
Browser that supports 256-bit strong encryption
– IE (Internet Explorer) 11 or higher1
– Firefox 27.0 or higher
– Chrome 25.0 or higher
– Safari 7 or higher
Javµ 8 or higher
PDF Reader (eg. Adobe PDF)2
Mac Mac OS X 10.9 or higher
Browser that supports 128-bit strong encryption
– Safari 7 or higher
– Firefox 27.0
– Chrome 25.0
Javµ (latest version)
PDF Reader (eg. Adobe PDF)2
Tablet and smartphone users please note, while most of the site will function normally, some
functions may not be operational on tablets and mobile devices at this time.
1 “Compatibility View” must remain in its default disabled setting. See p. 2 for more information.
2 Any compatible PDF viewer will supce. For some operating systems (e.g. Mac OS X) and for some browsers (e.g.
Google Chrome) PDF viewing capabilities are available “out-of-the-box” without the need to install add
BROWSER CONFIGURATION
Internet Explorer1
Check that Compatibility Mode is turned oo
If on, this will cause images to not appear, menus to appear out of place, and text
boxes to be distorted.
Icon location in IE 9 and 10:
con location in IE 8:
Compatibility mode on :
Compatibility mode oo:
OTHER CONSIDERATIONS AND SETTINGS
Rapid Release Schedule
Web browsers (eg. Internet Explorer, Google Chrome, Safari), as well as Javµ and Adobe products
(Flash, PDF) are released on rapid release schedules, which means new revisions are released
between new versions of the Fieldpoint site and our application partners. Because it is unlikely that
these releases will negatively aoect Fieldpoint’s ooerings, we do not test every release against the
site and its supporting functions. When testing µ consumer release, Fieldpoint’s Private’s Quality
Assurance teams will test the ooering in the latest available version of the browser at time of the
release to ensure that the experience is optimized for that version of the browser.
Operating Systems
Unless otherwise noted, µ designation of supported applies to any browser/operating system
combination that is supported by the browser vendor. All system speciscations required by browser
or operating system vendors must be satissed.
Operating System Patch Releases
Due to the unpredictable and sporadic nature of operating system patches, issues relating to
operating system/browser conflicts will be handled on µ case-by-case basis. When formal patches are
released by an operating system vendor that impact supported browsers, Fieldpoint Private will
evaluate any issues and/or potential workarounds within µ reasonable amount of time.
Embedded Browsers
Some popular browsers may be embedded into various online services. For example, Americµ Online
(AOL) currently uses Internet Explorer within its desktop software application. Users should consider
these browsers to be unsupported, as we do not test them in embedded environments.
Mobile and Tablet Browsers
While most of the site will function normally on tablet computers and smartphones, some functions
are not operational on such devices at this time.
BROWSER SUPPORT POLICY UPDATES
Adoption of New Browsers
Our goal is to support as many of your customers/members as possible and to help maintain security
during their online sessions. We review industry browser usage trends, browser capabilities and
security information when deciding which browsers to consider certised or supported. We also utilize
browser usage datµ collected by our own solutions and focus our eoorts on supporting those
browsers that are most secure and have the highest market demand.
Discontinuation of Browser Support
From time-to-time, security considerations and functionality limitations may cause us to discontinue
support for certain browsers.
Download Our
Banking App
News
Careers
Contact
Member FDIC
Accessibility
The colleagues of Fieldpoint Private work hard to see to it that our website and services are accessible to all who wish to come here, including those who use assistive technology. We follow the requirements of Title III of the Americans with Disabilities Act (ADA), 42 U.S.C. 12181-12189, and the regulation implementing title III, 28 C.F.R. pt. 36. We do so by policy, but also by philosophy — we wish for no barrier to stand between our facilities, our technology, and those who wish to entrust us with their financial needs.
Our website is designed in accordance with ADA standards, and we have asked accessibility experts to challenge us toward making our sites and services reflect best practices for those with disabilities. For people who are blind or have low vision, Fieldpoint Private will, upon request and without charge, provide the following auxiliary aids and services:
• Qualified readers
• Printed information in large print
• Oral descriptions of action and visual information to ensure the accessibility or proceedings and presentations
• Notetakers
• Assistance in filling out forms
• An assistant to guide the person to find his/her way to an unfamiliar location or along an unfamiliar route within any of the Banks’ locations
For people who are deaf, or hard of hearing, or have speech impairments, Fieldpoint Private will, upon request and without charge, provide the following auxiliary aids and services:
• Qualified oral/sign language interpreters
• Written notes
• Notetakers
• Amplified and hearing aid compatible telephones
If you encounter any type of challenge or barrier to using our site or services, please let us know