This policy was last revised on August 4, 2021
The Company operates the desktop and mobile website https://indigoadvisorsllc.com/ (the “Site”). The Site provides information about the services that we offer and other information that may be of interest to you.
We collect your Personal Information when you provide it to us. For example, we collect Personal Information when you communicate with us via email or when you respond to our communications or requests for information. Personal Information may include, but is not limited to, your name, e-mail address, physical address, phone number, and information about the organization with which you are affiliated. We may also automatically collect certain Personal Information when you use, access, or interact with our Site as described below. We use your data to provide you with information that matches your interests and to improve the performance of the Site and to connect directly with users who contact us.
For people in California, we have also prepared a Supplemental Privacy Statement for California Consumers under CCPA (“California Statement”) in compliance with the California Consumer Privacy Act of 2018 (“CCPA”). Please review our California Statement attached below for more information.
We will review this policy regularly, and we may update it from time to time.
- When You Visit our Site. When you visit the Site located at https://indigoadvisorsllc.com, you are free to view the Site without providing any Personal Information. When you contact the Company through Site via email/, you may provide certain Personal Information about yourself.
2.3 Usage Data – Usage Data is data collected automatically either generated by the use of the Site or from the Site’s infrastructure itself (for example, the duration of a page visit).
2.4 Cookies – Cookies are small pieces of data stored on your device (computer or mobile device).
2.5 Data Controller – Data Controller means the person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Information are, or are to be, processed.
2.6 Data Processors (or Service Providers) – Data Processor (or Service Provider) means any natural or legal person who processes data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
2.7 Data Subject (or User) – Data Subject is any identified or identifiable individual who is using our Site and is the subject of Personal Information.
- Information Collection and Use. We collect several different types of information for various purposes to provide and improve our service to you.
- Types of Data Collected.
4.1 Personal Information. While using our Site, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Information”). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Your company name
- Area of Interest
- Any feedback, questions, or recommendations you provide
We may invite comments, questions, or feedback on certain public areas of the Site. If you provide information in those public areas of the Site, such information may be read, collected, and used by us and other users of the Site. If you provide information directly to us in other ways, such as by sending us an email, we may retain that information and add it with the other information we have collected from you.
We may use your Personal Information to contact you with newsletters, marketing materials and other information that may be of interest to you.
4.2 Types of Information Collected by Technology. We may receive and store certain types of information from you each time you use the Site. For example, we may automatically log your browser type, language preference, precise geographic location, the date and time of your visit to the Site, any actions you take on the Site, the date and time of your visit to specific listings on the Site, your Internet Protocol (IP) address, and the website you visited before our Site. In addition, we may receive and store information about your use of the Site. The technologies we use for this automatic data collection may include:
- Web Beacons. Web beacons are electronic images that may be used on our Site or in our emails. We use web beacons to deliver cookies, count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon.
- Clear Gifs. We may also use clear gifs or other data files or identifiers to collect information for statistical purposes and to improve and develop the Site. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are placed on a hard drive, clear gifs are embedded invisibly on web pages.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page here.
4.4 Do Not Track. Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. At this time we do not respond to browser-based “do not track” signals.
- Use of Your Data. In general, information you submit to us is used either to respond to requests that you make, or to aid us in serving you better. The Company uses and may use your information: to provide improved administration of our Site; to improve the quality of your experience when you interact with our Site; to send you e-mail notifications; to respond to your inquiries; to send Company updates and for other marketing purposes of the Company. We may create anonymous or aggregated data records from your information by excluding information that makes the data personally identifiable to you (such as your name) or by compiling information about you with information from other users. We use this anonymous or aggregated data to analyze request and usage patterns so that we may enhance the content of our Site and improve Site navigation. We reserve the right to use and disclose anonymous and aggregate data to third party companies for any purpose in our sole discretion. If you provide feedback on our Site to us, we may use such feedback for any purpose, provided we will not associate such feedback with your information.
- Disclosure of Your Information.
6.1 Disclosures. Regardless of any choices you make regarding your information (as described below), the Company may disclose information if it believes in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on the Company; or (b) protect or defend the rights or property of the Company, or any other party.
6.3 Disclosure to Third Parties. We may share your information with third party Service Providers that are contractually bound to safeguard your information. We may make such disclosure in order to provide you with Company updates and invitations to Company events. We may also share your information with any other party with your express consent.
We also may employ third party companies and individuals to facilitate our Site, to manage the Site on our behalf, to perform support-related services or to assist us in analyzing how our Site are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
6.5 We Never Sell Personal Information. We will never sell your Personal Information to any third party.
6.6 Use of Navigational Information. We may use Navigational Information to operate and improve the Site.
6.7 Testimonials and Comments. We may post customer testimonials and comments on our Site, which may contain Personal Information. We will obtain each customer’s consent via email prior to posting the customer’s name and testimonial.
6.8 Security of your Personal Information. We are committed to protecting the security of your information. We use a variety of industry-standard security technologies and procedures to help protect your information from unauthorized access, use, or disclosure. but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
- Your Choices Regarding Your Information.
7.1 Changes to Information. You may change any of your information by sending an e-mail to us at [email protected]. You may request deletion of your information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives.
7.2 To Unsubscribe from Our Communications. You may unsubscribe from our marketing communications by sending us email us at [email protected] or postal mail to:
Indigo Advisors LLC
601 Brickell Key Drive
Brickell Key, Suite 700
Miami, FL 33131
You cannot opt out of receiving transactional emails.
- 9. Children’s Privacy. Our Site does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children without verification of parental consent, we take steps to remove that information from our servers.
- 11. Questions. If you have any questions or concerns, please contact the Company by e-mail at [email protected]. We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation.
- Legal Basis for Processing Personal Information Under General Data Protection Regulation (GDPR)
The Company may process your Personal Information because:
- We need to perform a contract with you.
- You have given us permission to do so.
- The processing is in our legitimate interests and it is not overridden by your rights.
- To comply with the law.
The Company will also retain Usage Data for internal analysis purposes.
12.2 Transfer of Data. Your information, including Personal Information, may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside of the United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to the United States and process it there.
12.3 Disclosure of Data
The Company may disclose your Personal Information in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of the Company
- To prevent or investigate possible wrongdoing in connection with the Site
- To protect the personal safety of users of the Site or the public
- To protect against legal liability
12.4 Your Data Protection Rights Under General Data Protection Regulation (GDPR). If you are a resident of the EEA, you have certain data protection rights. The Company aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information.
If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us at [email protected].
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you. If you are unable to perform these actions yourself, please contact us to assist you at [email protected].
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Information.
- The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where the Company relied on your consent to process your Personal Information.
Please note that we may ask you to verify your identity before responding to such requests.
- You already have the information
- Providing you with the information would prove impossible or would involve a disproportionate effort
- We are under an EU or EU member state law obligation to obtain or disclose the information which provides appropriate measures to protect your legitimate interests
- We are obliged to keep the information confidential as a result of an obligation of professional secrecy regulated by EU or EU member state law
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the EEA.
- Supplemental Privacy Statement for California Consumers under CCPA.
Our business proudly serves or will serve certain natural persons residing in the State of California (each, a “consumer”). This California Statement explains rights that California consumers may have under the CCPA.
When we use the term “Personal Information” in this supplemental California Statement, we are using that term as CCPA defines it, which CCPA generally defines “Personal Information” to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. However, Personal Information does not include publicly available, deidentified, or aggregate consumer information (which are all defined in CCPA). Notably, the definition of “Personal Information” also does not apply to the collection of Personal Information from job applicants, employees – whether you are our employee or any employee of the entity arranging access to our Services for you, business owners, directors, officers, medical staff, or contractors.
13.1 Categories of Personal Information we collect, the sources of that information, purposes for why we collect it, who we share it with, and whether we sell that Personal Information. Where we act as a “business” under CCPA (meaning we determine the manner and reasons for why we process your Personal Information), we may be required to disclose additional information regarding the categories of Personal Information we collect, the sources where we obtain that information, the purposes for why we collect that information, who we share that information with, as well as whether we sell that Personal Information – all of which depends on the specific Service.
13.2. Your privacy rights. If you are a resident of California and are not a job applicant, employee/contractor, or employee/contractor of another company interacting with us in your job role, you have the right to request what information we collect, use, and disclose. You also have the right to request that we delete your information.
To make a request, you can contact us at [email protected]. Provide us enough information to verify your identify. We will use information you provide to us to verify your request. If we cannot initially verify your identity, we may request additional information to complete the verification process, such as, for example, a copy of your driver’s license and/or a recent utility or credit card bill. You can designate an agent to make a request on your behalf by either: (1) having your agent send us a letter, signed by you, certifying that the agent is acting on your behalf and showing proof that they are registered with the California Secretary of State; or (2) by you and the agent executing and sending us a notarized power of attorney stating that the agent is authorized to act on your behalf. Please note that we may still require you to verify your identity before we process a request submitted by your agent.
California residents also have certain rights regarding the sale of Personal Information. California residents have the right to opt out of the sale of their Personal Information by contacting us at [email protected].
We will not discriminate against you because you have exercised any of your privacy rights under the CCPA.