Strategic Gold places special importance upon client confidentiality. All client information is encrypted and stored on our secure servers. These servers are physically isolated and cannot be accessed through the Internet. Redundant backups are stored offsite in a secure facility. To ensure discretion and confidentiality, all statements and transactions are processed on our system by coded client identification number.
If you hold an interest in a Clear Title Account jointly with one or more other persons, you alone have the right to make the decisions concerning the use of Personal Information that pertains to you alone. You and the other person or persons, each acting alone, have the right to make decisions concerning the use of the information that pertains to you together.
Visitors can request to join a mailing list by completing a form on this site. We maintain this list of Strategic Gold Corporation to inform them of new information on this website. We do not sell, rent, lease, loan, trade or otherwise divulge the addresses on our lists to third parties or any unauthorized personnel.
LIMITS ON COLLECTION AND USE
We limit our collection, use and disclosure of Personal Information to what is necessary to run our business and to deliver superior service to you.
We will collect, use and disclose your Personal Information for the following purposes:
- to establish and maintain your account
- to communicate with you about your account, related matters and other matters
- to effect, administer and enforce a transaction involving or related to your account that you request or authorize
- to identify you in order to protect against fraud and guard against unauthorized access to your account
- to keep our information about you current and accurate
- to facilitate the preparation distribution of quarterly statements
We communicate with our clients by mail, overnight service, telephone, fax and e-mail. We use these communications to fulfill our obligations to our clients under our agreements with them. Our use of these communications reflects any consent our clients may have given in those agreements. We reserve the right to use any of these means to send you information relating to your account, including communications required by law.
We will protect the confidentiality of your Personal Information. We do not sell, rent or give away Personal Information to anyone. We do not exchange Personal Information with anyone.
We will release your Personal Information only (1) to a person we believe to be you or your authorized representative, (2) to someone else if you direct us to do so, (3) to cooperate with law enforcement authorities.
Applicable laws give people who are involved in lawsuits or other legal proceedings the right to require us to provide information to them. In such cases, we provide only the information that we are required to provide.
ACCESS AND ACCURACY
We will provide you with access to your Personal Information, and we will work with you to keep your Personal Information accurate. Please let us know (1) if you wish to access your Personal Information that we hold, (2) if you find an error in your Personal Information, or (3) if you need to make a change in your Personal Information. We will provide access or update our records promptly after hearing from you. Please allow approximately 10 business days for any information to be received or any changes to be made.
ANTI-MONEY LAUNDERING POLICY
It is the policy of the firm to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have derived from legitimate origins or constitute legitimate assets.
CLIENT IDENTIFICATION AND VERIFICATION
To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens and maintains an account. This means that we will collect the following information for all accounts, if applicable, for any person, entity or organization who is opening a new account (or is being granted authority over a new or existing account) and whose name is on the account or has authority over the account:
- the name and mailing and residential (or principal place of business) street address of the client
- the client’s date of birth;
Recognizing that different types of accounts pose different risks and trigger different requirements under the rules, we will gather the additional information specified below for each of the following categories of accounts we provide:
- Individual Accounts: We will obtain the client’s bank account information.
- Non-U.S. Person Accounts: We may inquire more fully depending on a number of factors, such as the country of origin of the account holder or persons authorized to trade.
- Domestic Operating or Commercial Entities: We will collect information sufficient to determine the corporate or business entity’s identity, and the authority of its business representative to act on its behalf.
- Domestic Trusts: We will identify the trustee, the activity the trust authorizes, and the authority of the trust’s representative to act on its behalf.
- Institutional Accounts, Hedge Funds, Investment Funds and Other Intermediary Relationships: While our AML procedures cover institutional clients, we recognize that certain types of institutional accounts are different from retail accounts. Institutional accounts often are opened for financially sophisticated customers who trade frequently, in volume, and usually through an intermediary, some of whose AML policies and procedures are sufficient and verifiable. In addition, in determining whether it is necessary to identify the investors of non-U.S. institutions, we will consider the regulation of the institution by its home country and whether the institution is located in a bank secrecy haven or a non-cooperative country.
CUSTOMERS WHO REFUSE TO PROVIDE INFORMATION
If a potential or existing customer either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, our firm will not open a new account and, after considering the risks involved, consider closing any existing account.
To the extent reasonable and practicable, we will ensure that we have a reasonable belief that we know the true identity of our customers. In verifying customer identity, we will analyze any logical inconsistencies in the information we obtain.
Appropriate documents for verifying the identity of natural persons include the following:
- An unexpired driver’s license, passport, or other government identification showing nationality, residence, and photograph or other biometric safeguard, or, for non-U.S. persons, an unexpired alien registration card or other government issued identification showing nationality, residence and photograph or other biometric safeguard.
The following documents are appropriate for verifying the identity of businesses:
- A certificate of incorporation, a government-issued business license, any partnership agreements, any corporate resolutions, or similar documents.
Should you have any questions regarding our Anti-Money Laundering program, please feel free to contact us at 239-692-9154.
ADDITIONAL POINTS FOR YOUR CONSIDERATION
Strategic Gold will willingly co-operate with international investigations into money laundering activity where investigation is being undertaken by the authorized agents of respected international governments.
Although we know of nothing specific, it is conceivable that the jurisdictions under which Strategic Gold operates might change their current reporting requirements. It is likely that such a change would be debated openly before being implemented. Where this occurs, and provided we are not prevented from doing so, we would advise you of any likely change.
TYPES OF INFORMATION WE COLLECT
In connection with your use of this Site, we may collect both personally identifiable information (“PII”) and non-personally identifiable information (“Non-PII”). PII includes information such as your name, address, phone number, zip code, email address, and similar information. Non-PII is non-personally identifiable information and may include, for example, your IP address, browser type, domain names, access dates and similar information. (PII and Non-PII will be collectively referred to as “Information”)
The Site is not intended for or directed to children under the age of 13. Children under 13 years of age should leave the Site. SGC does not knowingly collect, use or disclose any Information from children under the age of 13 years through our website. In the event SGC learns it has collected any Information from children under 13 without parental consent, we will take steps to delete such Information as quickly as reasonably possible.
We use “cookies” on this site. A cookie is a piece of data stored on a site visitor’s hard drive to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, you would not have to log in a password more than once, thereby saving time while on our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. Usage of a cookie is in no way linked to any personally identifiable information on our site. Most web browsers allow you to modify your settings to accept or deny cookies or to request your permission each time a site attempts to set a cookie.
COLLECTION OF INFORMATION
We may collect information from you through your voluntary submission to receive offers from the Site or access to certain resources on the Site. We also may collect information from your browser when you use the Site, using a variety of methods. The information that we might collect via automated methods may include, for example, IP address, a unique device or user ID, browser or system type, the content and pages that you access on the Site, and the address of the page from which you navigated to the Site. We may also use this information to administer, operate, and improve the Site and our other services and systems, and to provide services and content that are tailored to you.
USE AND SHARING OF INFORMATION
We may use the information you provide to us for any purpose, including but not limited to: (1) to provide you with materials or information that you have requested, (2) to send you administrative messages, content, and other services and features in which we believe you may be interested, (3) to personalize our contact with you, (4) to operate, provide, improve, and maintain the Site, (5) to develop new products and services, (6) to prevent abusive and fraudulent use of the Site; and (7) any other administrative and internal business purposes permitted by law.
PERMISSION TO CONTACT YOU AND YOUR RIGHT TO OPT OUT OF FURTHER CONTACT
Your provision of information to us through the Website will be considered a grant of permission for us to contact you through any means. You may opt-out of further promotional contact from us at any time by sending us a request at firstname.lastname@example.org. It may take up to 10 days for us to process your request.
PROTECTION OF YOUR INFORMATION
We maintain a variety of security measures to protect against the loss, misuse, and alteration of Information under our control. While we make good faith efforts to maintain security, we cannot guarantee that your information will remain free from unauthorized access, use, disclosure, or alteration. Further, we cannot guarantee that our security measures will prevent unauthorized persons from accessing or obtaining this information. We assume no liability to you or any other party in relation to the unauthorized access, use, or alteration of any information provided to us.
If we become aware of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Site or providing Information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If you believe that there has been a breach of the Site’s security, please contact us at email@example.com.
LINKS AND THIRD PARTY PRACTICES
CALIFORNIA PRIVACY RIGHTS
If you are a California resident and request information about how to exercise your third-party disclosure choices, send a request to firstname.lastname@example.org.