Privacy Policy

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Your privacy is important to us. WrapManager, Inc. DBA Assembly ("Assembly"), an investment adviser registered with the SEC, has adopted policies and procedures designed to protect our client’s non-public personal information obtained during the course of our relationship. Our Privacy Policy also covers how we collect, use, disclose, transfer and store information about anyone that visits an Assembly website.

Collection and Use of Personal Information

Personal information is data that can be used to identify or contact a single person. You may be asked to provide your personal information when in contact with Assembly. We may also combine it with other information to provide and improve our products, services, content, and advertising. You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.

What Personal Information We Collect

  • When you request information about Assembly or any of the money managers that we provide reports on, download educational materials, register for an event, contact us or participate in an online survey, we may collect a variety of information, including your name, mailing address, phone number, email address, contact preferences, and investment profile information.
  • When you share content with family and friends or invite others to participate in Assembly services or forums, WrapManager, Inc. DBA Assembly ("Assembly"), may collect the information you provide about those people such as name, email address, and phone number. Assembly will use such information to fulfill your requests, provide the relevant product or service.

How We Use Your Personal Information

  • The personal information we collect allows us to communicate Assembly's latest product announcements, updates, and upcoming events. If you don’t wish to be on our mailing list, you can opt out anytime
  • We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, and for anti-fraud purposes.
  • We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services.
  • From time to time, we may send important notices, such as communications about portfolios and changes to our terms, conditions, and policies. Because this information is important to your interaction with Assembly, you may not opt out of receiving these communications.
  • We may also use personal information for internal purposes such as auditing, data analysis, and research to improve Assembly's products, services, and customer communications.

Collection and Use of Non-Personal Information

We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:

  • We may collect information such as occupation, language, zip code, area code, unique device type, referrer URL, location, and the time zone where the WrapManager website is used so that we can better understand customer behavior and improve our services and advertising.
  • We may collect information regarding customer activities on our website and from our other events, products and services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and services are of most interest. Aggregated data is considered non‑personal information for the purposes of this Privacy Policy.
  • We may collect and store details of how you use our services, including search queries. This information may be used to improve the relevancy of information published.

If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

Non-Disclosure of Client Information

WrapManager, Inc. DBA Assembly ("Assembly") maintains safeguards to protect each client’s personal information. We do not share your personal information with any nonaffiliated third parties, except in the following circumstances:

  • As necessary to provide the service that you have requested or authorized, or to maintain and service your account, including but not limited to other professional advisors and /or service providers (i.e. attorney, accountant, insurance agent, broker-dealer, investment advisor, account custodian, administrative service providers, etc.); and
  • As required by regulatory authorities or law enforcement officials who have jurisdiction over WrapManager, Inc., or as otherwise required by any applicable law; and
  • To the extent reasonably necessary to prevent fraud and unauthorized transactions.

Employees are prohibited, either during or after termination of their employment, from disclosing, accessing, holding non-public personal information to any person or entity outside Assembly, including family members, except under the circumstances described above.

Because it is our policy not to share information outside of these circumstances, no opportunity to opt out is provided.

Why We Collect Information

WrapManager, Inc. DBA Assembly ("Assembly") collects information in an effort to fulfill our fiduciary responsibility and to best serve our clients. The information gathered helps us to:

  • Identify your investment objectives
  • Administer your account on an ongoing basis
  • Comply with certain laws and regulations

Categories of Nonpublic Personal Information that We Collect

The information we collect generally includes:

  • Information we receive from you during discussions or on applications or other forms you complete as part of the account opening process. This generally includes information such as your name, address, age, tax identification, income level, assets, investment objectives and goals, risk tolerance and investment experience; and
  • Information about your transactions with us or others; and
  • Other information gathered to assist us in upholding our fiduciary duty to you.

Safeguarding and Disposal of Client Information

WrapManager, Inc. DBA Assembly ("Assembly") restricts access to non-public personal information to those employees and service providers who need to know such information to provide requested services. Assembly maintains physical, electronic, and procedural safeguards to protect your personal information.
If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice.

Cookies and Other Technologies

Assembly's websites, online services, interactive applications, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help us better understand user behavior, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as non‑personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

Assembly also uses cookies and other technologies to remember personal information when you use our website, online services, and applications. Our goal in these cases is to make your experience with Assembly more convenient and personal. For example, knowing your email lets us autofill forms next time you request a report or eBook. And knowing your contact information, hardware identifiers, and information about your computer or device helps us provide you with better customer service.

If you want to disable cookies, please check with your provider for specific instructions.

As is true of most financial services, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data.

We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. Assembly may use this information to improve our marketing and advertising services.

In some of our email messages, we use a “click-through URL” linked to content on the Assembly website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.

Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

How to Contact Us

If you have questions or comments about this Privacy Notice, or about how your data is processed, please contact us here.


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