Privacy Statement

FACTS WHAT DOES DAVID LERNER ASSOCIATES, INC. DO WITH YOUR PERSONAL INFORMATION?

Why we collect your information

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What information we collect

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

  • Social Security number
  • account balances
  • income
  • account transactions
  • transaction history
  • wire transfer instructions
  • checking account information

When you are no longer our customer, we continue to share your information as described in this notice.

How we share

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons David Lerner Associates, Inc. chooses to share; and whether you can limit this sharing.

 

Reasons we can share your personal information

Does David Lerner Associates share?

Can you limit this sharing?

For our everyday business purposes
such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes

No

For our marketing purposes
to offer our products and services to you

Yes

No

For joint marketing with other financial companies

No

We don't share

For our affiliates’ everyday business purposes
information about your transactions and experiences

Yes

No

For our affiliates’ everyday business purposes
information about your creditworthiness

Yes

We don't share

For our affiliates to market to you

Yes

Yes

For non-affiliates to market to you

No

We don't share

To limit our sharing

Write us at: Privacy Compliance Office, 477 Jericho Turnpike, Syosset, New York 11791
Please note:
If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

WHAT WE DO

Who is providing this notice?

David Lerner Associates, Inc.

How does David Lerner Associates, Inc. protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

We conduct periodic reviews of our computer systems, including security features. Additionally, our employees are required to acknowledge their responsibility to maintain the confidentiality of Customer Information.

How does David Lerner Associates, Inc. collect my personal information

We collect your personal information, for example, when you

  • open an account
  • provide account information
  • give us your contact information
  • make a wire transfer
  • tell us where to send the money

We also collect your information from others, such as credit bureaus, affiliates, or other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only

  • sharing for affiliates’ everyday business purposes – information about your creditworthiness
  • affiliates from using your information to market to you
  • sharing for non-affiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See the “Other important information” section below for additional rights provided under state laws.

What happens when I limit sharing for an account I hold jointly with someone else?

Your choices will apply to you alone. Each account holder must opt out individually.

Does David Lerner Associates, Inc. sell my personal information?

David Lerner Associates, Inc. does not sell your personal information.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and non-financial companies.

  • Our affiliates include: Spirit of America Investment Fund, Inc.; Spirit of America Management Corp. and SRLA, Inc.; and The Great Art Fund, LLC.

Non-affiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.
  • David Lerner Associates Inc. does not share with non-affiliates so they can market to you.

Joint Marketing

  • David Lerner Associates, Inc. does not jointly market.
Other important information

California Privacy Notice

This California Privacy Notice supplements the information contained in the Privacy Statement of David Lerner Associates, Inc. (“DLA”) and applies solely to the rights of California residents with respect to “Personal Information” as defined in the California Consumer Privacy Act (“CCPA”).

Personal Information We Collect

As defined in the CCPA and as used in this California Privacy Notice, “personal information” means any “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.”

DLA has collected the following categories of personal information from consumers within the preceding twelve (12) months:

  1. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

    Source - DLA collects this data from the consumer, third party verification services, commercially available sources such as mailing list providers; and publicly available sources such as telephone directories, newspapers, social media or internet sites, and from government agencies, registries or public records.

    Business purpose for collection - DLA collects this data to market to clients and potential clients and service existing clients, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, preventing fraud, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services.

    Parties with whom this information was shared - DLA shares this information with service providers so that they can process information on our behalf. We also share this information with affiliates for marketing purposes, and with governmental entities.

  2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) such as name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

    Source - DLA collects this data from the consumer, third party verification services, commercially available sources such as mailing list providers; and publicly available sources such as telephone directories, newspapers, social media or internet sites, and from government agencies, registries or public records.

    Business purpose for collection – DLA collects this data to market to clients and potential clients and service existing clients, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, preventing fraud, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services.

    Parties with whom this information was shared - DLA shares this information with service providers so that they can process information on our behalf. We also share this information with affiliates for marketing purposes, and with governmental entities.

  3. Protected classification characteristics under California or federal law such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

    Source - DLA collects this data from the consumer, third party verification services, commercially available sources such as mailing list providers; and publicly available sources such as telephone directories, newspapers, social media or internet sites, and from government agencies, registries or public records.

    Business purpose for collection – DLA collects this data to market to clients and potential clients and service existing clients, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, preventing fraud, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services.

    Parties with whom this information was shared - DLA shares this information with service providers so that they can process information on our behalf. We also share this information with affiliates for marketing purposes, and with governmental entities.

  4. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

    Source - DLA collects this data from the consumer, the consumer’s transactions within an account, counterparties to these transactions, and from government agencies, registries or public records.

    Business purpose for collection – Business purpose for collection – DLA collects this data to comply with applicable law, market to clients and service clients including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, preventing fraud, processing payments, providing advertising or marketing services, or providing similar services.

    Parties with whom this information was shared - DLA shares this information with service providers so that they can process information on our behalf. We also share this information with affiliates for marketing purposes, and with governmental entities.

  5. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.

    Source - DLA collects this data from reviewing the consumer’s electronic browsing history on our website.

    Business purpose for collection – DLA collects this data to market to clients, provide advertising or marketing services, or similar services, and prevent fraud.

    Parties with whom this information was shared - DLA shares this information with service providers so that they can process information on our behalf.

  6. Geolocation data:

    Source - DLA collects this data from reviewing the geolocation data revealed when a consumer accesses our website.

    Business purpose for collection – DLA collects this data to market to clients, provide advertising or marketing services, or similar services, and prevent fraud.

    Parties with whom this information was shared - DLA shares this information with service providers so that they can process information on our behalf

  7. Audio, electronic, visual, thermal, olfactory, or similar information.

    Source - In compliance with any applicable notice requirements, DLA may record phone calls.

    Business purpose for collection – DLA collects this data as may be required by law or to verify trade or other instructions given to us.

    Parties with whom this information was shared - DLA shares this information with service providers so that they can store information on our behalf.

  8. Professional or employment-related information.

    Source - DLA collects this data from the consumer.

    Business purpose for collection – DLA collects this data to service existing clients, including maintaining or servicing accounts, providing advertising or marketing services, providing analytic services, or providing similar services.

    Parties with whom this information was shared - DLA shares this information with service providers so that they can process information on our behalf.

  9. Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).

    Source - DLA collects this data from the consumer.

    Business purpose for collection – DLA collects this data to service existing clients, including maintaining or servicing accounts, providing advertising or marketing services, providing analytic services, or providing similar services.

    Parties with whom this information was shared - DLA shares this information with service providers so that they can process information on our behalf.

  10. Inferences drawn from any of the above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

    Source - DLA collects this data from the consumer, third party verification services, commercially available sources such as mailing list providers; and publicly available sources such as telephone directories, newspapers, social media or internet sites, and from government agencies, registries or public records.

    Business purpose for collection – DLA collects this data to market to clients and potential clients, providing advertising or marketing services, providing analytic services, or providing similar services.

    Parties with whom this information was shared - DLA shares this information with service providers so that they can process information on our behalf.

Personal Information We Sell

DLA does not sell personal information and has not sold consumer’s personal information in the preceding twelve (12) months.

Consumer Rights under CCPA

The CCPA provides Consumers with certain rights regarding their Personal Information. If you are a Consumer (hereafter “you” or “your” refers to a Consumer), this notice describes your CCPA rights and explains how to exercise your rights.

Right to Access

You have the right to request, up to 2 times every 12 months, that DLA disclose to you the following:

  • The categories of personal information DLA has collected about you.
  • The categories of sources from which such personal information is collected.
  • The business or commercial purpose for collecting your personal information.
  • The categories of personal information about you disclosed for a business purpose during the last 12 months and the categories of third parties to whom such personal information was disclosed.
  • The specific pieces of personal information DLA has collected about you.

You have the right to request a portable copy of your Personal Information.

DLA will disclose the applicable information specified above to you upon receipt of your verifiable consumer request. See below, "Submitting a Verifiable Consumer Request".

Right to Deletion

You have the right to request that DLA delete any personal information about you which DLA has collected from you, subject to certain exceptions allowed under applicable law.

Submitting a Verifiable Consumer Request—How to Exercise Rights of Disclosure or Deletion

DLA is required to provide the information specified above to you, or delete information in response to your request, only upon receipt of a verifiable consumer request. Your request must provide information to DLA that enables DLA to verify your identity (and, as applicable, of your authorized representative) in order for DLA to respond to your request. Upon receiving a request pursuant to this Policy, DLA will confirm receipt within 10 days and provide you with information about how DLA will verify and process the request. DLA will take reasonable steps to verify your identity (or the identity and authority of your authorized representative) prior to responding to your requests under CCPA. You agree to respond to reasonable requests by DLA for additional information to enable us to verify your identity in connection with your requests for information or deletion of information under the CCPA.

You may submit a verifiable consumer request to DLA by:

  • Calling DLA using DLA’s CCPA toll-free number 1-800-920-2029
  • Mailing a written request to DLA at Privacy Compliance Office, 477 Jericho Turnpike, Syosset, New York 11797-9006
  • Emailing at privacy@DavidLerner.com

Once your request is verified, DLA will promptly take steps to disclose and deliver, free of charge to you, the personal information required by the CCPA. DLA will deliver the information to you by mail or electronically within 45 days of receipt of your request, or such additional time as may be permitted under the CCPA.

Right to Nondiscrimination

DLA shall not discriminate against you because you exercised to exercise any of your rights under the CCPA including, but not limited to:

  • Denying goods or services to you.
  • Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties on you.
  • Providing a different level or quality of goods or services to you.
  • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

None of the foregoing, however, prohibits DLA from charging you a different price or rate, or from providing a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to the consumer by the consumer’s data.