cleverDome, Inc. Privacy Policy
cleverDome, Inc. (“cleverDome”) has the privilege of assisting its Members in protecting the confidentiality of cleverDome Members and their clients’ personal and financial information (“Confidential Information”) through the cleverDome software defined perimeter (“the Dome”). cleverDome Members collect and maintain Confidential Information from their clients and other sources which is shared with other cleverDome Members to provide services to their clients. This Confidential Information may include:
- Information the cleverDome Member receives from its client on the client agreement form and account applications. This information may include the client’s name, address, phone number, email address, Social Security number and date of birth, as well as details about the client’s interests, investments and investment experience;
- Information about the client’s transactions with the cleverDome Member or others, including a client’s financial representative;
- Information a cleverDome Member receives from third party service providers, clearing firms and custodians with respect to client accounts;
- Medical information submitted as part of an insurance application such as a traditional life or variable life policy;
- Information received from service bureaus or other third parties.
cleverDome takes its responsibility to protect the Confidential Information of its Members and their clients very seriously, and therefore is pleased to provide our policy on handling Confidential Information.
cleverDome Member Risk Management
cleverDome requires each cleverDome Member who shares Confidential Information with another cleverDome Member to (i) complete the cleverDome Due Diligence Program and comply with the cleverDome Minimum Cybersecurity Standards; (ii) use secure devices to access the Dome; and (ii) use the secure network to access, share send and receive Confidential Information within the Dome.
In addition, each cleverDome Member must comply with cleverDome Policies and Procedures regarding the authorization for other cleverDome Members to access, share, send and receive their Confidential Information.
Limitations and Controls Regarding Accessing, Sharing, Sending and Receiving Confidential Information of cleverDome Members and Their Clients
- cleverDome does not store or maintain Confidential Information. The Dome is used by cleverDome Members to access, share, send and receive their Confidential Inforamtion.
- cleverDome Members must authorize access, sharing, sending and receiving their Confidential Information through the Dome with other cleverDome Members through a controlled provisioning process, and Confidential Information is only accessed, shared, sent and received between cleverDome Members as authorized by each cleverDome Member.
- cleverDome Members may use the Dome to access, share, send and receive Confidential Information only through secure devices.
- cleverDome Members agree to confidentiality terms and are contractually obligated not to use or share Confidential Information for any other purpose.
cleverDome Provides These Additional Limitations and Controls
- Completes background checks on all employees and provides training regarding protecting Confidential Information
- Maintains physical, electronic and procedural safeguards to protect Confidential Information of cleverDome Members and their clients
- Conducts testing of its systems, procedures and controls
- Will under no circumstances sell any Confidential Information of cleverDome Members and their clients to any person or entity
cleverDome reserves the right to change its Privacy Policy at any time and maintains a current version of its Privacy Policy on its website at cleverdome.com.