Online Privacy Policy

Protecting Your Personal Information is Important

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. 

Like most industries today, the financial services industry continues to be shaped by technology, which is literally changing the way we do business. To be successful in this environment, we must continue to insure that our clients are confident that we will manage their financial affairs expertly and confidentially.

This online privacy policy (“Privacy Policy”) is provided by Stack Financial Management, Inc.

(referred to herein as “SFM,” “our,” “us,” or “we”) and is addressed to any current clients and/or investors of SFM as well as any prospective clients or investors (“you” or “your”)  whose Personal Information (as defined below) SFM collects and controls to conduct its business on our website (“Site”).

This Privacy Policy describes how we collect and use Personal Information that may directly, or indirectly, identify you during and after your working relationship with us and/or through our Site (“Personal Information”). In particular, this Privacy Policy describes the basis upon which and for what purposes we process your Personal Information, as well as your privacy rights under certain privacy laws including, where applicable, under US privacy laws and the European Union’s (“EU”) General Data Protection Regulation (“GDPR”), and how we protect your Personal Information.

To affirm our continued commitment to the proper use of client information and protecting your privacy, we have set forth the following privacy policies.

By visiting this Site, you are accepting the practices described in the Privacy Policy. If you do not agree to this policy, please do not use this Site.

Changes to this Privacy Policy

This Privacy Policy may change from time to time and should be reviewed periodically. Such changes shall be effective immediately upon posting. The current version of this Privacy Policy can be accessed from the link on the bottom of our homepage, or at the bottom of our other Site pages. By accessing our Site after we have posted changes to this Privacy Policy, you are agreeing to the terms of the Privacy Policy as modified.

What Personal Information Do We Collect When You Visit Our Site?

We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our site, fill out a form, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, name, email address, phone number. Users may, however, visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.

How Is Your Personal Information Used?

We will only use your Personal Information for the purpose of providing services requested by you or persons authorized by you.

  • monitor, audit, evaluate and otherwise administer our services;
  • assist with the administrative, marketing (including direct marketing), planning, service development, quality control or research purposes of SFM and its contractors and service providers;
  • communicate with you and respond to your inquiries;
  • protect against, identify and prevent fraud, copyright infringement, unauthorized use and distribution of protected content and other unlawful activity, claims and liabilities;
  • perform data analyses (such as market and customer research); pursue our legitimate interests;
  • conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms; and/or
  • for other purposes required or authorized by law, including other purposes for which you have provided your consent.

In the event that we use Personal Information we collect for other purposes not identified above where direct client consent is required under applicable rules, laws and/or regulations we will provide specific notice at the time we collect such Personal Information.

Individual Rights

To the extent permitted by the applicable law of your jurisdiction, in relation to your Personal Information, you may request:

  • to have your Personal Information corrected, for example, if it is incomplete or incorrect;
  • to opt out of receiving marketing communications at any time;
  • the right to file a complaint with an applicable government regulator such as a Data Protection Authority.

In addition to the foregoing, if you are located in the European Economic Area (“EEA”), to the extent permitted by applicable law, in relation to your Personal Information, you may request:

  • to access the Personal Information held by us about you;
  • the right to restrict or object to the processing of your Personal Information, or request that your Personal Information is erased;
  • the right to receive a copy of the Personal Information which you have provided to our firm, in a structured, commonly used and machine-readable format (known as “data portability”);
  • have a copy of the Personal Information we hold about you provided to you or another controller where technically feasible;
  • where you have provided Personal Information voluntarily, or otherwise consented to its use, the right to withdraw your consent.

To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to your information.  

To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your Personal Information that we maintain.

Will Your Personal Information be Kept Accurate, Complete, and Up To Date?

We will endeavor to ensure your Personal Information is kept accurate, complete, up to date and relevant. Please let us know if any of your details change. If you feel your Personal Information is not accurate, complete or up to date, please notify us and we will take reasonable steps to ensure it is corrected. You can contact us using the details listed below.

Is Your Personal Information Secure

SFM continually updates and improves security standards and procedures to guard against anyone gaining unauthorized access to your Information, including through the Internet. We maintain physical, electronic and procedural safeguards to guard your Personal Information.

SFM maintains appropriate physical, electronic, and procedural safeguards that comply with applicable legal standards to protect its clients’ Personal Information. Through this policy and its underlying procedures, SFM attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.

As our Site is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any Personal Information or other information which you transmit to us online is transmitted at your own risk.

Links to Third-Party Websites

As a convenience to you, SFM may provide hyperlinks to websites operated by third parties. When you select these hyperlinks, you will be leaving our Site.

SFM has no control over third party websites, their content, or security. Accordingly, when you access these third party websites it is at your own risk. We encourage you to read the associated privacy policies by such third party websites to learn more about their data privacy management practices. SFM may, in its sole discretion, block links to our Site without prior notice.

Retention and Processing of Personal Information

To the extent permitted by applicable law, we retain your Personal Information for the period necessary to serve the purposes for which we obtained it. We may also retain your Personal Information beyond such period in accordance with applicable laws, regulations, or another lawful basis, including but not limited to, compliance with our contractual obligations, legal obligations, regulatory obligations, legal claims, or another legitimate interest.

Do We Use "Cookies" or Obtain Personal Information by Automated Means?

We may use “cookies” to help us tailor our Site to better suit your needs (for example, we may use cookies to enable us to save any personal preferences indicated by you) and to provide a more effective route to various components of our Site.

Cookies are small text files that are stored in your computer’s memory and hard drive when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website.

Automated Decision Making

Third Party Cookies – When you visit our Site, you may receive cookies that are set by third parties. These cookies are used for the purposes described in the bullet points above. We do not control the setting of these third party cookies, so we suggest you might wish to check the third party websites for more information about their use of cookies and how to manage them.

Ammending internet browser settings to disable cookiesYou can configure your browser to send accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies that have already been set. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. You are free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on our Site. In addition, a number of companies offer utilities designed to help you visit websites anonymously.

For more information about cookies and how to disable them please visit www.allaboutcookies.org, or you may consult the vendor documentation for your specific software.

For more information on how our firm utilizes cookies, please refer to our Cookies Policy.

We do not track users across time or over multiple websites, we do not receive, or respond to, browser do-not-track signals or other similar mechanisms.  However, as noted above, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.

How We Respond to Do Not Track Signals

Amending your internet browser’s Do Not Track signal: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers and is a way for users to inform websites and services that they do not want certain information about their web page visits collected over time and across Sites or online services.

To learn more about setting up Do Not Track Signals, please visit https://www.allaboutdnt.com

For more information on Do Not Track signals, please refer to our Cookies Policy

Information About Children

Notwithstanding the limited circumstances where we may collect Sensitive Information from our clients and/or investors, our Site is not directed to children under the age of 18 years. By using our Site, you represent and warrant that you are at least 18 years old.

In accordance with the Children’s Online Protection Act (“COPA”), we do not knowingly solicit or collect Personal Information on the Site from children under the age of 13 without prior verifiable parental consent.

Data Transfers

We may transfer the Personal Information we obtain about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. To the extent required by applicable law, when we transfer your information to recipients in other countries (such as the United States, United Kingdom, Ireland or Cayman Islands), we will protect that information as described in this Privacy Policy.

If you are located in the European Economic Area (“EEA”), we will comply with applicable legal requirements regarding the provision of appropriate safeguards for the transfer of Personal Information to recipients in countries for which the European Commission has not issued an adequacy decision.

Data Controller

As identified under applicable law, the data controller for this Site is SFM located at the address below.

Our Commitment

We want to assure you that we are committed to maintaining the confidentiality, integrity and security of your Personal Information. The safeguarding of client information is an issue we take seriously; whenever information is used, it is done with discretion.

We have developed these privacy policies to protect our clients. These policies are for general guidance and do not constitute a contract or create legal rights and do not modify or amend any agreement we have with our clients.

Whom Can You Contact at SFM?

If you have any questions regarding this Privacy Policy or would like to exercise your rights, you may contact our Chief Compliance Officer using the information below:

Attention: Jeanine Morreim
Chief Compliance Officer
Stack Financial Management
625 Wisconsin Avenue
Whitefish, Montana 59937

Telephone: (406) 862-8000
E-Mail: compliance@stackfinancialmanagement.com
Web: https://www.stackfinancialmanagement.com